35ph Privacy Policy

This Privacy Policy ("Policy") describes how 35ph ("the Platform," "we," "us," or "our"), operating through the website 35ph.net, collects, uses, stores, and protects the personal information of players and visitors ("you" or "your") who access or use our online gaming services.

35ph is committed to safeguarding the privacy of all individuals who interact with our platform. We recognize the importance of personal data protection, particularly in the context of online gaming, and we take our obligations under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations seriously.

This Policy should be read alongside our Terms and Conditions, which govern your use of the 35ph platform. If you do not agree with the practices described in this Policy, please discontinue use of the platform.

For the purposes of the Philippine Data Privacy Act of 2012, 35ph acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players and visitors to the platform.

As the Personal Information Controller, 35ph determines the purposes and means by which your personal data is processed. We are responsible for ensuring that your data is handled in accordance with applicable data protection laws and the commitments set out in this Policy.

35ph collects the following categories of personal data from players and platform visitors:

35ph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and interact with the 35ph platform, including through cookies, log files, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from security partners; payment data from payment processors such as GCash and PayMaya.
• Publicly available sources: In limited circumstances, we may verify information against publicly available records to fulfill our legal and regulatory obligations.

35ph uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your 35ph player account, including verifying your identity and eligibility to use the platform.
• Service delivery: To provide access to games, process bets, credit winnings, and deliver the full range of 35ph gaming services.
• Financial transactions: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Legal and regulatory compliance: To fulfill our obligations under Philippine law, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and gaming regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: To monitor gameplay patterns and identify players who may be at risk of problem gambling, and to enforce self-exclusion and limit-setting tools.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the 35ph platform.
• Marketing communications: To send you promotional offers, bonuses, and platform updates — only where you have provided consent or where we have a legitimate interest to do so, and always with the option to opt out.

Under the Philippine Data Privacy Act of 2012, 35ph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you agreed to when registering your 35ph account — including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and gaming regulatory requirements.
• Legitimate interests: Processing carried out for the legitimate interests of 35ph, including fraud prevention, platform security, and service improvement — provided such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent — particularly for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

35ph does not sell, rent, or trade your personal data to third parties. We may share your data only in the following limited circumstances:

• Service providers: Third-party vendors who assist us in operating the 35ph platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC verification providers, IT infrastructure providers, and customer support tools. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.
• Game providers: Third-party game developers and live casino operators whose games are available on the 35ph platform may receive limited technical data necessary to deliver their games.
• Regulatory and law enforcement authorities: Where required by Philippine law, court order, or regulatory authority — including PAGCOR and the Anti-Money Laundering Council (AMLC) — 35ph may disclose your personal data without prior notice.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 35ph's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

35ph uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and analyze platform usage. The following types of cookies may be used:

• Essential cookies: Strictly necessary for the platform to function. These include session cookies that keep you logged in and security cookies that protect against fraudulent activity. These cannot be disabled.
• Functional cookies: Remember your preferences and settings — such as language and display preferences — to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how players use the 35ph platform, helping us identify areas for improvement. This data does not identify you personally.
• Marketing cookies: Used to deliver relevant promotional content. These are only activated where you have provided consent.

35ph retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Active account data: Retained for the duration of your account relationship with 35ph, plus a minimum of five (5) years following account closure, in accordance with Philippine AML and gaming regulatory requirements.
• Transaction records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC documents: Identity verification documents are retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer support records: Support communications are retained for up to three (3) years from the date of the interaction.
• Marketing data: Retained until you withdraw your consent or opt out of marketing communications, after which it will be deleted or anonymized within a reasonable period.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymized so that it can no longer be associated with you.

35ph implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the 35ph platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Access controls ensuring that personal data is accessible only to authorized 35ph personnel who require it to perform their duties.
• Regular security assessments and penetration testing of the 35ph platform infrastructure.
• Staff training on data protection obligations and secure data handling practices.
• Incident response procedures to detect, report, and address personal data breaches promptly.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 35ph will notify the National Privacy Commission (NPC) and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 35ph:

The 35ph platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 35ph does not knowingly collect personal data from individuals under the age of 21.

If you are a parent or guardian and believe that a minor has provided personal data to 35ph or accessed the platform without authorization, please contact our support team immediately so that we can take prompt corrective action.

35ph employs age verification procedures during the registration process and reserves the right to request documentary proof of age at any time. Providing false information about your age constitutes a material breach of our Terms and Conditions.

35ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this page.
• Notify registered players via email or an in-platform notification where the changes are significant.
• Where required by law, seek your renewed consent before processing your data under the revised terms.

We encourage you to review this Privacy Policy periodically to stay informed about how 35ph protects your personal data. Your continued use of the platform following the posting of any changes constitutes your acceptance of the updated Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 35ph handles your personal data, please contact our Data Protection Officer or support team using the details below.

For responsible gaming concerns, self-exclusion requests, or account limit settings, please visit our Responsible Gaming page or contact our support team directly.