Privacy Policy — 369club

1. Introduction

369club (hereinafter "369club," "we," "us," or "our") is committed to protecting the privacy and personal data of all users ("Users," "Players," or "you") who access and use the 369club platform at 369club.biz. This Privacy Policy ("Policy") sets out in detail how 369club collects, processes, stores, shares, and protects your personal information, and describes the rights you hold under applicable Philippine privacy law.

This Policy is to be read together with the 369club Terms and Conditions and Responsible Gaming Policy, both of which are available on this website. By registering for a 369club account or continuing to use the Platform, you acknowledge that you have read, understood, and agree to the collection and use of your personal data as described in this Policy.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, 369club is the data controller responsible for personal data collected through the Platform. Decisions regarding the purpose and means of processing your personal data are made by 369club in accordance with this Policy and applicable Philippine regulations, including those issued by the National Privacy Commission (NPC) and the Philippine Amusement and Gaming Corporation (PAGCOR).

3. Personal Data We Collect

3.1 Registration and Identity Data

When you register a 369club account, we collect: full legal name, date of birth, nationality, residential address, email address, mobile phone number (Philippine number), and a copy of at least one valid government-issued identification document (e.g., Philippine national ID, passport, driver's licence, SSS/GSIS card).

3.2 Financial and Transaction Data

To facilitate deposits and withdrawals, we collect: GCash or PayMaya account numbers or registered mobile numbers, bank account numbers (BPI, BDO, Metrobank, or other Philippine banks), transaction amounts and timestamps, and records of all deposits, withdrawals, and wagers conducted through your 369club account.

3.3 Gameplay and Platform Activity Data

369club collects data on your gameplay activity including: games played, wager amounts, session durations, betting history, and bonus utilisation. This data is used for account management, fraud detection, responsible gaming monitoring, and compliance with PAGCOR reporting obligations.

3.4 Technical and Device Data

We automatically collect technical data when you access the Platform, including: IP address, device type, operating system, browser type and version, session tokens, login timestamps, and pages visited within the Platform. This data is used for security, fraud prevention, and platform performance optimisation.

3.5 Communications Data

When you contact 369club's customer support via live chat, email, or any other channel, we retain records of those communications for quality assurance, training, dispute resolution, and compliance purposes.

4. How We Collect Personal Data

369club collects personal data through the following means:

• Directly from you — during registration, KYC verification, payment setup, and when you contact our support team;
• Automatically — through cookies, session tracking, and server logs when you use the Platform;
• From third-party verification providers — KYC and identity verification services, payment processors, and fraud detection partners who may confirm or supplement data you have provided;
• From regulatory authorities — in the course of complying with PAGCOR licensing requirements or AMLC reporting obligations.

5. Purpose and Legal Basis for Processing

369club processes your personal data for the following purposes and on the following legal bases:

• Contract performance — to operate your account, process transactions, deliver games, and provide customer support;
• Legal obligation — to comply with PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, KYC mandates, and NPC-issued data privacy regulations;
• Legitimate interests — to detect and prevent fraud, abuse, and cheating; to improve platform security; to manage responsible gaming obligations; and to conduct platform analytics;
• Consent — for marketing communications, where you have provided explicit consent. You may withdraw marketing consent at any time by contacting support.

6. Data Sharing and Disclosure

6.1 Payment Processors

369club shares necessary financial data with Philippine payment service providers including GCash (G-Xchange, Inc.), PayMaya (PayMaya Philippines, Inc.), and partner banks (BPI, BDO, Metrobank) solely for the purpose of processing deposits and withdrawals. These providers operate under their own privacy policies and are subject to Philippine financial data regulations.

6.2 KYC and Compliance Partners

Identity verification data may be shared with 369club's authorised KYC and AML compliance service providers for the purpose of verifying player identity and complying with AMLA obligations. All such providers are contractually obligated to maintain the confidentiality of your data.

6.3 Regulatory Authorities

369club will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other competent Philippine regulatory bodies where required by law, court order, or lawful regulatory demand.

6.4 No Commercial Sale of Data

369club does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. Data is never shared with external advertisers without your explicit consent.

7. International Data Transfers

Where personal data is processed or stored outside the Philippines — for example, by cloud infrastructure providers or international game software providers — 369club ensures that appropriate safeguards are in place, including contractual data protection clauses consistent with the requirements of RA 10173 and NPC-issued circulars governing cross-border data transfers. Transfers are made only to countries or organisations offering an adequate level of data protection.

8. Data Retention

369club retains personal data for as long as your account remains active and for a minimum period of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AMLA record-keeping obligations. Financial transaction records may be retained for longer periods where required by applicable law. Where personal data is no longer needed, it is securely deleted or anonymised.

9. Security Measures

369club implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your browser and the 369club Platform;
• Encryption of sensitive data at rest, including financial records and identity documents;
• Role-based access controls limiting data access to authorised personnel only;
• Regular security audits and vulnerability assessments;
• Two-factor authentication options for player accounts.

While 369club takes all reasonable steps to protect your data, no internet transmission is completely secure. You are responsible for maintaining the confidentiality of your 369club login credentials and for notifying us immediately of any suspected unauthorised access to your account.

10. Cookies and Tracking Technologies

369club uses cookies and similar technologies for the following purposes:

• Essential cookies — required for the Platform to function, including session management, authentication, and security features;
• Performance cookies — used to analyse how players use the Platform, identify technical issues, and improve performance (data is aggregated and anonymised);
• Preference cookies — used to remember your settings and personalisation choices within the Platform.

369club does not use third-party advertising or behavioural tracking cookies. You may control cookie settings through your browser; however, disabling essential cookies may impair Platform functionality. By continuing to use the Platform, you consent to the use of cookies as described above.

11. Your Data Rights Under RA 10173

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 369club:

• Right to be Informed — the right to know that your personal data is being collected and processed, and the purposes thereof;
• Right to Access — the right to obtain a copy of your personal data held by 369club and information about how it is processed;
• Right to Rectification — the right to request correction of inaccurate or incomplete personal data;
• Right to Erasure / Right to be Forgotten — the right to request deletion of your personal data, subject to legal retention obligations;
• Right to Object — the right to object to the processing of your personal data for certain purposes, including direct marketing;
• Right to Data Portability — the right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint — the right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, contact the 369club Data Protection Officer at [email protected]. We will respond to all verifiable data requests within fifteen (15) business days, or as otherwise required by NPC regulations.

12. Children and Minors

The 369club Platform is strictly intended for adults aged twenty-one (21) years and above in compliance with PAGCOR regulations. 369club does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please notify us immediately at [email protected].

13. Third-Party Links

The 369club Platform may contain links to third-party websites or services (for example, payment provider portals). This Privacy Policy applies solely to data processed by 369club through the Platform. 369club is not responsible for the privacy practices of third-party websites and encourages you to review their respective privacy policies before providing any personal data.

14. Changes to This Privacy Policy

369club reserves the right to update or amend this Privacy Policy at any time to reflect changes in legal requirements, regulatory guidance from PAGCOR or the NPC, or our data processing practices. Updated versions of this Policy will be posted on this page with a revised "Last Updated" date. Material changes will be communicated to registered players via email or in-platform notification. Your continued use of the Platform following the posting of any amendment constitutes your acceptance of the updated Policy.

15. Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by 369club, please contact our Data Protection Officer:

Email: [email protected]

Our support and DPO team is available 24/7. We are committed to resolving all data privacy concerns promptly and in accordance with our obligations under RA 10173 and its Implementing Rules and Regulations. For unresolved complaints, you retain the right to escalate your concern directly to the National Privacy Commission of the Philippines through their official channels.