36gl Privacy Policy

1. Introduction

This Privacy Policy (the "Policy") describes how 36gl (the "Company," "we," "us," or "our"), operating the online gaming platform at https://36gl.cam, collects, processes, uses, stores, discloses, and protects personal information provided by users (the "User," "you," or "your") in connection with accessing and using our Services.

36gl is committed to protecting the privacy and security of your personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as other applicable Philippine laws, regulations, and industry standards governing data protection and online gaming operations.

By creating an account, accessing the 36gl platform, or using any of our Services, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with any part of this Policy, you must immediately cease using the 36gl platform and Services.

This Privacy Policy should be read in conjunction with our Terms and Conditions, which govern your use of the 36gl platform and constitute part of the binding agreement between you and 36gl.

2. Information We Collect

2.1 Personal Information You Provide

When you register for a 36gl account or use our Services, we collect personal information that you voluntarily provide to us, including but not limited to:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers
• Contact Information: Email address, Philippine mobile phone number, residential address, city, province, and postal code
• Account Credentials: Username, password (stored in encrypted form), and security questions/answers
• Financial Information: Payment method details (GCash account, Maya account, bank account information, cryptocurrency wallet addresses), transaction history, deposit and withdrawal records
• Verification Documents: Copies of government-issued photo identification (passport, driver's license, UMID, Postal ID), proof of address documents (utility bills, bank statements), and selfie photographs for identity verification
• Communication Records: Chat transcripts with customer support, email correspondence, feedback submissions, and complaint records

2.2 Information Automatically Collected

When you access and use the 36gl platform, we automatically collect certain technical and behavioral information through cookies, web beacons, log files, and similar tracking technologies:

• Device Information: IP address, device type and model, operating system, browser type and version, screen resolution, device identifiers (IMEI, UDID, advertising IDs)
• Usage Data: Pages viewed, games played, betting patterns, session duration, click-through rates, navigation paths, search queries, and timestamps of activities
• Location Information: Approximate geographic location derived from IP address (country, city level) to ensure compliance with geographic restrictions and applicable regulations
• Performance Data: Application performance metrics, error logs, crash reports, and diagnostic information

2.3 Information from Third-Party Sources

We may receive additional information about you from third-party sources to verify your identity, prevent fraud, comply with legal obligations, or enhance our Services:

• Payment processors and financial institutions (transaction verification, anti-fraud checks)
• Identity verification service providers (age verification, document authentication)
• Credit reference agencies and anti-money laundering databases
• Marketing partners and affiliate networks (referral information, campaign performance data)
• Social media platforms (if you choose to connect your social media account to your 36gl account)

3. How We Use Your Information

36gl processes your personal information for the following purposes:

3.1 Account Management and Service Provision

• Creating, maintaining, and managing your 36gl user account
• Authenticating your identity and verifying your age (21+ requirement)
• Processing deposits, withdrawals, and financial transactions
• Providing access to gaming products (sports betting, live casino, slots, bingo)
• Managing bonuses, promotions, and loyalty rewards
• Facilitating customer support and responding to your inquiries

3.2 Legal and Regulatory Compliance

• Complying with Philippine gaming regulations and PAGCOR requirements
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
• Preventing, detecting, and investigating fraud, money laundering, and other illegal activities
• Enforcing our Terms and Conditions and other policies
• Responding to legal requests, court orders, and government inquiries
• Maintaining transaction records as required by law (typically 5-7 years)

3.3 Platform Security and Fraud Prevention

• Detecting and preventing unauthorized account access, hacking attempts, and security breaches
• Identifying duplicate accounts and bonus abuse
• Monitoring betting patterns to detect collusion, match-fixing, and unfair play
• Protecting the integrity of our gaming platform and ensuring fair play
• Conducting security audits and vulnerability assessments

3.4 Service Improvement and Analytics

• Analyzing user behavior and preferences to improve our Services
• Conducting market research and customer satisfaction surveys
• Testing new features, products, and promotional offers
• Optimizing platform performance, loading times, and user experience
• Generating aggregated, anonymized statistics and reports for business intelligence

3.5 Marketing and Communications

• Sending promotional emails, SMS messages, and push notifications about bonuses, new games, and special offers (only with your consent, which you may withdraw at any time)
• Personalizing content, recommendations, and advertisements based on your interests and gaming history
• Conducting targeted marketing campaigns and measuring their effectiveness
• Informing you about important updates, policy changes, and account-related notifications

3.6 Responsible Gaming

• Implementing deposit limits, session reminders, and self-exclusion tools
• Monitoring gaming behavior to identify potential problem gambling patterns
• Providing access to responsible gaming resources and support organizations
• Enforcing cooling-off periods and voluntary exclusion requests

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 36gl processes your personal information based on one or more of the following legal grounds:

4.1 Consent

You have given explicit, informed, and freely-given consent for us to process your personal data for specific purposes, such as receiving marketing communications or participating in optional surveys. You may withdraw your consent at any time by contacting our Data Protection Officer.

4.2 Contract Performance

Processing is necessary to fulfill our contractual obligations to you under the Terms and Conditions, including creating and maintaining your account, processing transactions, providing gaming services, and paying out winnings.

4.3 Legal Obligation

Processing is required to comply with Philippine laws and regulations, including PAGCOR gaming regulations, anti-money laundering laws, tax obligations, and court orders or requests from law enforcement authorities.

4.4 Legitimate Interests

Processing is necessary for our legitimate business interests or those of third parties, provided such interests do not override your fundamental rights and freedoms. Legitimate interests include fraud prevention, network security, business analytics, and improving our Services.

4.5 Vital Interests

In rare cases, processing may be necessary to protect your vital interests or those of another person, such as preventing self-harm or responding to medical emergencies.

5. Data Sharing and Disclosure

36gl does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients when necessary to provide our Services, comply with legal obligations, or protect our legitimate interests:

5.1 Service Providers and Business Partners

• Payment Processors: GCash, Maya (PayMaya), banks (BPI, BDO, UnionBank), cryptocurrency payment gateways, and other financial service providers that process deposits and withdrawals
• Identity Verification Services: Third-party providers that authenticate identity documents, verify age, and conduct KYC/AML checks
• Game Providers: Software suppliers and content providers that power our casino games, slots, live dealer games, and sports betting platforms
• Cloud Service Providers: Infrastructure and hosting providers that store data and maintain our servers
• Customer Support Tools: Live chat software providers, helpdesk platforms, and communication services
• Analytics and Marketing Platforms: Tools that help us analyze user behavior, measure campaign performance, and deliver targeted advertising

All service providers are required to maintain confidentiality, implement appropriate security measures, and use your information only for the specific purposes for which it was disclosed. We enter into written agreements with service providers that include data protection obligations consistent with this Privacy Policy.

5.2 Regulatory and Law Enforcement Authorities

We may disclose your personal information to Philippine regulatory bodies (PAGCOR, Anti-Money Laundering Council), tax authorities, law enforcement agencies, courts, and other government entities when required by law, legal process, or to:

• Respond to subpoenas, court orders, or other legal demands
• Comply with gaming regulations, tax obligations, and anti-money laundering requirements
• Assist in criminal investigations, fraud prevention, or national security matters
• Enforce our Terms and Conditions or protect our legal rights
• Protect the safety, rights, or property of 36gl, our Users, or the public

5.3 Corporate Transactions

If 36gl undergoes a merger, acquisition, sale of assets, bankruptcy, or other corporate restructuring, your personal information may be transferred to the acquiring or successor entity as part of the transaction. We will notify you via email and/or prominent notice on our platform before your information is transferred and becomes subject to a different privacy policy.

5.4 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with business partners, advertisers, researchers, or the public for purposes such as industry analysis, market research, and performance reporting. This data does not constitute personal information under the Data Privacy Act.

6. Data Security

36gl takes the security of your personal information seriously and implements comprehensive technical, organizational, and physical safeguards to protect against unauthorized access, alteration, disclosure, or destruction of data:

6.1 Technical Security Measures

• Encryption: All data transmitted between your device and our servers is encrypted using industry-standard TLS/SSL protocols. Sensitive data (passwords, payment information) is encrypted at rest using AES-256 encryption
• Secure Authentication: Multi-factor authentication (2FA) options, password hashing using bcrypt or similar algorithms, and session management with timeout mechanisms
• Firewalls and Intrusion Detection: Network firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) to monitor and block malicious traffic
• Regular Security Audits: Penetration testing, vulnerability assessments, and code reviews conducted by independent security experts
• Data Loss Prevention: Automated backup systems, disaster recovery procedures, and redundant data storage

6.2 Organizational Security Measures

• Strict access controls limiting employee access to personal data on a need-to-know basis
• Confidentiality agreements and security training for all employees and contractors
• Incident response procedures to detect, investigate, and respond to data breaches
• Vendor management program requiring third-party service providers to maintain equivalent security standards
• Appointment of a Data Protection Officer responsible for overseeing compliance with data protection laws

6.3 Your Responsibilities

While we implement robust security measures, you also play a critical role in protecting your account:

• Create strong, unique passwords and change them regularly
• Enable two-factor authentication (2FA) when available
• Never share your password or account credentials with anyone
• Log out of your account when using shared or public devices
• Be cautious of phishing emails, SMS messages, or phone calls impersonating 36gl
• Keep your email account and mobile phone number secure, as these are used for account recovery
• Report any suspicious activity or unauthorized access to customer support immediately

7. Data Retention

36gl retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements:

7.1 Active Accounts

Personal information associated with active accounts is retained for the duration of your relationship with 36gl and for a reasonable period thereafter to address any post-closure issues, comply with legal requirements, and prevent fraud.

7.2 Closed Accounts

When you request account closure or your account is terminated, we will retain certain personal information for the following minimum periods:

• Transaction Records: 5-7 years to comply with anti-money laundering regulations, tax obligations, and financial reporting requirements
• Identity Verification Documents: 5 years for regulatory compliance and to prevent duplicate account creation
• Communication Records: 3-5 years for dispute resolution and legal defense purposes
• Marketing Preferences: Until you withdraw consent or request deletion, up to 2 years after last interaction

7.3 Legal Holds and Investigations

If your account is subject to a legal hold, ongoing investigation, dispute, litigation, or regulatory inquiry, we will retain relevant information until the matter is resolved, even if this exceeds standard retention periods.

7.4 Data Deletion

Once the retention period expires and there is no longer a legitimate business or legal reason to retain your information, we will securely delete or anonymize it in accordance with our data deletion procedures. Anonymized data may be retained indefinitely for statistical and analytical purposes.

8. Your Rights Under Philippine Law

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal information. To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 14:

8.1 Right to Be Informed

You have the right to be informed about the collection, use, and disclosure of your personal data. This Privacy Policy serves as our primary means of providing such information.

8.2 Right to Access

You have the right to obtain confirmation of whether 36gl is processing your personal data and, if so, to access that data. You may request a copy of your personal information in a commonly used electronic format. We will respond to access requests within fifteen (15) calendar days.

8.3 Right to Rectification

You have the right to correct inaccurate or incomplete personal information. You can update most information directly through your account settings. For changes to verified identity information, you may need to provide supporting documentation.

8.4 Right to Erasure or Blocking

You have the right to request deletion or blocking of your personal data in certain circumstances, such as when:

• The data is no longer necessary for the purposes for which it was collected
• You withdraw consent and there is no other legal ground for processing
• The data has been unlawfully processed
• Erasure is required to comply with a legal obligation

However, we may refuse erasure requests if retention is necessary for legal compliance, establishment or defense of legal claims, or other legitimate purposes. In such cases, we will block the data from further processing where possible.

8.5 Right to Object

You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. If you object to marketing, we will cease such processing immediately. For other objections, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

8.6 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller when technically feasible.

8.7 Right to File a Complaint

If you believe 36gl has violated your data privacy rights, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. Contact details for the NPC are available at www.privacy.gov.ph.

8.8 Limitations on Rights

Your rights under this section are not absolute and may be limited by law. For example, we may refuse requests that are manifestly unfounded, excessive, or would adversely affect the rights and freedoms of others. We may charge a reasonable fee for repetitive or excessive requests.

9. Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files stored on your device when you visit a website. 36gl uses cookies and similar tracking technologies (web beacons, pixels, local storage) to enhance your experience, analyze platform usage, and deliver personalized content and advertising.

9.2 Types of Cookies We Use

• Essential Cookies: Necessary for platform functionality, including session management, authentication, security features, and load balancing. These cookies cannot be disabled without impairing core functionality
• Performance and Analytics Cookies: Collect information about how you use the platform, such as pages visited, time spent, and error messages. This data helps us improve performance and user experience
• Functional Cookies: Remember your preferences (language, currency, display settings) and provide enhanced, personalized features
• Advertising and Marketing Cookies: Track your browsing activity to deliver targeted advertisements, measure campaign effectiveness, and prevent duplicate ad impressions. These cookies may be placed by 36gl or by third-party advertising partners

9.3 Managing Cookie Preferences

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when cookies are being sent. Please note that disabling certain cookies may impair platform functionality and limit your ability to use some features. You can manage cookie preferences through:

• Your browser settings (Chrome, Firefox, Safari, Edge each provide cookie management tools)
• Our cookie consent banner (appears on first visit, allows you to customize preferences)
• Opt-out tools provided by advertising networks (e.g., Network Advertising Initiative, Digital Advertising Alliance)

9.4 Do Not Track Signals

Some browsers support "Do Not Track" (DNT) signals. Currently, there is no industry consensus on how to respond to DNT signals. 36gl does not alter its data collection practices in response to DNT signals.

10. Third-Party Services and Links

The 36gl platform may contain links to third-party websites, services, or applications that are not operated or controlled by 36gl. This Privacy Policy does not apply to such third-party services.

We are not responsible for the privacy practices, content, or security of third-party websites. We encourage you to read the privacy policies of any third-party sites you visit. Providing information to third-party services is at your own risk, and 36gl disclaims all liability for any harm arising from such disclosures.

Similarly, when you use payment services (GCash, Maya, banks), social media integrations, or other third-party features embedded in our platform, those providers may collect information about you according to their own privacy policies. We recommend reviewing the privacy policies of GCash, Maya (PayMaya), BPI, BDO, and other financial service providers you use.

11. Children's Privacy

The 36gl platform is intended solely for individuals who are at least twenty-one (21) years of age. We do not knowingly collect, use, or disclose personal information from individuals under 21 years of age.

If we become aware that we have inadvertently collected personal information from a minor, we will take immediate steps to delete such information from our systems and terminate the associated account. If you believe we have collected information from a minor, please contact our Data Protection Officer immediately at the contact details provided in Section 14.

Parents and guardians are urged to monitor their children's internet usage and prevent underage individuals from accessing online gaming platforms. 36gl employs age verification measures during registration, but parental supervision remains the primary means of preventing underage gambling.

12. International Data Transfers

36gl primarily operates within the Philippines and stores data on servers located in the Philippines or in secure cloud infrastructure within Southeast Asia. However, some of our service providers, including cloud hosting providers, payment processors, and analytics tools, may be located outside the Philippines.

When we transfer your personal data to countries outside the Philippines, we ensure that appropriate safeguards are in place to protect your information in accordance with the Data Privacy Act of 2012. These safeguards may include:

• Standard contractual clauses approved by the National Privacy Commission
• Adequacy determinations recognizing that the destination country provides an adequate level of protection
• Binding corporate rules for transfers within multinational corporate groups
• Certification schemes demonstrating compliance with recognized data protection standards

By using the 36gl platform, you consent to the transfer of your personal data to third countries where necessary to provide our Services, subject to the safeguards described above. You may request more information about international transfers and applicable safeguards by contacting our Data Protection Officer.

13. Changes to This Privacy Policy

36gl reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our data practices, legal requirements, technological developments, or business operations. When we make material changes to this Policy, we will notify you by:

• Posting the updated Privacy Policy on the 36gl website with a revised "Last Updated" date at the top of this page
• Sending an email notification to the email address associated with your account
• Displaying a prominent notice on the platform when you next log in

Your continued use of the 36gl platform after receiving notification of changes constitutes your acceptance of the updated Privacy Policy. If you do not agree to the changes, you must immediately cease using the platform and may request account closure and deletion of your personal information, subject to legal retention requirements.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information. Material changes will typically take effect thirty (30) days after posting, unless immediate implementation is required by law or to address security concerns.

14. Contact Information and Data Protection Officer

If you have questions, concerns, or complaints regarding this Privacy Policy, our data practices, or wish to exercise your rights under the Data Privacy Act of 2012, please contact our Data Protection Officer:

Data Protection Officer
36gl
Metro Manila, Philippines

Email: [email protected]
General Customer Support: [email protected] (24/7 live chat available)

We aim to respond to all privacy-related inquiries within fifteen (15) business days. For urgent matters involving potential data breaches or unauthorized account access, please contact customer support immediately via live chat for faster assistance.

If you are not satisfied with our response or believe your data protection rights have been violated, you have the right to file a complaint with the National Privacy Commission of the Philippines:

National Privacy Commission
5th Floor, Philippine International Convention Center (PICC),
Vicente Sotto Street, Pasay City, Metro Manila, Philippines
Website: www.privacy.gov.ph
Email: [email protected]