369club
Privacy Policy

1 Introduction

369club ("we," "us," "our," or "the Platform") is an online casino and sports betting platform accessible at 369club.asia, serving registered players across the Philippines. We operate under the regulatory framework established by the Philippine Amusement and Gaming Corporation (PAGCOR).

This Privacy Policy ("Policy") explains how 369club collects, uses, stores, discloses, and protects the personal data of individuals who visit or use the 369club platform, including registered players, prospective players who visit the site without registering, and individuals who contact our support team.

This Policy should be read together with the 369club Terms & Conditions and Responsible Gaming Policy, both of which are accessible via the links provided. Capitalized terms used in this Policy but not defined here carry the meanings assigned to them in the Terms & Conditions.

2 Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, the data controller responsible for your personal data is:

If you have questions or concerns specifically relating to the processing of your personal data, you may contact our designated Data Protection Officer (DPO) through the contact details set out in Section 15 of this Policy.

3 Personal Data We Collect

369club collects the following categories of personal data, depending on your interaction with the platform:

3.1 Registration and Account Data

• Philippine mobile number used for account registration and OTP verification;
• Username or account name;
• Date of birth (used for age verification — players must be 21 or older);
• Password (stored in hashed, non-reversible form — 369club never stores plain-text passwords).

3.2 Identity Verification (KYC) Data

• Full legal name as it appears on government-issued identification;
• Photograph of valid Philippine government-issued photo ID (e.g., PhilSys National ID, UMID, passport, or LTO driver's license);
• Selfie photograph for liveness verification;
• ID number, type, and expiry date;
• Residential address (where required for enhanced due diligence).

3.3 Financial Transaction Data

• GCash account number and registered name;
• PayMaya account details where used;
• Bank account details (BPI, BDO, Metrobank) where used for deposits or withdrawals;
• Transaction amounts, timestamps, reference numbers, and status records;
• Wallet balance history and transaction logs.

3.4 Gaming and Behavioural Data

• Game session records, including games played, wagers placed, outcomes, and session durations;
• Bonus claim history, wagering requirement progress, and promotional activity;
• Responsible gaming settings applied by the player (deposit limits, session limits, self-exclusion records);
• Sports betting history and live casino session records.

3.5 Technical and Device Data

• IP address and geolocation data (country/region level);
• Device type, operating system, and browser type;
• Session identifiers, login timestamps, and session duration;
• Cookie identifiers and similar tracking technologies (see Section 8).

3.6 Communications Data

• Content and records of support interactions via Live Chat, Messenger, Viber, or email;
• Player feedback, complaints, and dispute records;
• Records of marketing communications sent to and opted into by the player.

4 How We Collect Personal Data

369club collects personal data through the following means:

• Directly from you — when you complete the registration form, submit KYC documents, initiate a deposit or withdrawal, contact support, or update your account profile;
• Automatically during platform use — through cookies, server logs, session tracking, and device fingerprinting technologies as described in Section 8;
• From payment service providers — GCash, PayMaya, and banking institutions may transmit transaction confirmation data to 369club as part of payment processing;
• From identity verification service providers — third-party KYC technology partners who assist 369club in verifying the authenticity of identity documents;
• From fraud detection and AML monitoring services — automated and human-assisted tools that analyze transaction patterns and account behavior for compliance purposes.

5 Purposes of Processing Personal Data

369club processes your personal data for the following purposes:

6 Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, 369club relies on the following lawful bases for processing your personal data:

• Contractual necessity: Processing required to perform our obligations under the 369club Terms & Conditions and to deliver the services you have registered for, including account management, game access, and payment processing;
• Legal obligation: Processing required to comply with applicable Philippine laws, including the Anti-Money Laundering Act (AMLA), PAGCOR regulatory requirements, and tax reporting obligations;
• Legitimate interests: Processing necessary for fraud prevention, security monitoring, responsible gaming compliance, and platform improvement, where these interests are not overridden by your privacy rights;
• Consent: Where you have provided explicit consent, including for the receipt of optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing and Disclosure

369club does not sell, rent, or trade your personal data. We may share your personal data with the following categories of third parties only to the extent necessary for the specified purposes:

• Payment service providers (GCash, PayMaya, BPI, BDO, Metrobank, USDT network operators) — for processing deposit and withdrawal transactions;
• KYC and identity verification technology partners — to authenticate identity documents submitted during account verification;
• Game content providers (Pragmatic Play, PG Soft, Habanero, Spade Gaming, and others) — to deliver licensed game content and resolve game-related disputes;
• AML monitoring and fraud prevention service providers — to fulfill compliance obligations under the AMLA and PAGCOR requirements;
• Cloud infrastructure and hosting providers — to store and process data on secure server infrastructure;
• Regulatory authorities — including PAGCOR and the National Privacy Commission, where disclosure is required by law or regulatory direction;
• Law enforcement and government agencies — where disclosure is required by a valid court order, subpoena, or other legal process under Philippine law;
• Professional advisers — lawyers, accountants, and auditors acting in a professional capacity, bound by confidentiality obligations.

All third-party service providers who receive personal data from 369club are required to maintain appropriate data security measures and to process personal data only in accordance with 369club's instructions and applicable law.

8 Cookies and Tracking Technologies

The 369club platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, analyze platform performance, and support responsible gaming monitoring. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for platform operation, including session management, login authentication, and security functions. These cannot be disabled without affecting platform functionality;
• Functional Cookies: Remember your preferences and settings, such as language preferences and responsible gaming settings you have configured;
• Analytics Cookies: Collect aggregated, anonymized data about how players interact with the platform to help us improve site performance, navigation, and content. This data does not identify individual players;
• Security Cookies: Support fraud detection, device fingerprinting for account security, and detection of unusual login patterns.

You may manage non-essential cookies through your browser settings. Disabling strictly necessary cookies may affect your ability to access and use the 369club platform. 369club does not use advertising or cross-site tracking cookies for third-party advertising purposes.

9 Data Retention

369club retains personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following retention considerations:

• Active account data is retained for the duration of your account's active status plus a minimum of five (5) years after account closure, in compliance with AMLA record-keeping requirements;
• KYC and identity verification records are retained for a minimum of five (5) years after the completion of the customer relationship, as required under Philippine AML regulations;
• Transaction records are retained for a minimum of five (5) years to fulfill legal, regulatory, and audit obligations;
• Gaming session data is retained for a minimum of two (2) years for dispute resolution, responsible gaming analysis, and regulatory reporting purposes;
• Communications data is retained for a minimum of two (2) years after the closure of the relevant interaction or dispute;
• Marketing consent records are retained for the duration of the consent period plus a reasonable additional period to demonstrate compliance.

Following the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be attributed to an identifiable individual. Where data must be retained beyond standard retention periods due to ongoing legal proceedings or regulatory requirements, it will be flagged accordingly and access restricted to authorized personnel only.

10 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 369club:

To exercise any of these rights, please submit a written request to the 369club Data Protection Officer through the contact details in Section 15. 369club will respond to all verifiable data subject requests within thirty (30) days. Complex requests may require an extension of up to an additional thirty (30) days, of which you will be notified.

Note that certain rights are subject to exceptions under applicable law — in particular, data required to be retained for legal, regulatory, or AML compliance purposes cannot be deleted upon request alone.

If you believe your data protection rights have been violated and your concern has not been addressed satisfactorily by 369club, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11 Children's Privacy and Age Restrictions

Age verification is conducted at the point of registration through our KYC procedures. Where 369club discovers that personal data has been submitted by an individual under the age of 21, the relevant account will be immediately closed, all data will be securely deleted, and any funds deposited will be returned to the source payment method after verification.

If you have reason to believe that a minor has registered on the 369club platform or submitted personal data without authorization, please contact our support team immediately at the contact details provided in Section 15 so that the matter can be investigated and addressed without delay.

12 Security Measures

369club implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data in transit between your device and the 369club platform servers;
• Encryption at rest for sensitive data fields including identity documents, financial information, and authentication credentials;
• Password hashing using industry-standard cryptographic algorithms — plain-text passwords are never stored;
• Multi-factor authentication for account access, including OTP verification via registered Philippine mobile number on new or unrecognized devices;
• Role-based access controls limiting internal system access to authorized personnel on a need-to-know basis;
• Intrusion detection and monitoring systems that flag and alert on anomalous access patterns;
• Regular security audits and penetration testing of the platform infrastructure;
• Incident response procedures to manage and contain security incidents in accordance with NPC notification requirements.

While 369club takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are encouraged to use a strong, unique password for your 369club account, enable OTP verification on all devices, and contact support immediately if you suspect unauthorized access.

13 Cross-Border Data Transfers

Some of 369club's technical infrastructure providers, game content providers, and payment processors may be located outside the Philippines. Where personal data is transferred internationally, 369club ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Philippine law.

Such safeguards include:

• Contractual data processing agreements with all international service providers incorporating data protection obligations;
• Selection of service providers that operate under data protection regimes recognized as providing adequate protection;
• Regular review of international data transfer arrangements to ensure ongoing compliance.

You may request information about the specific safeguards applied to international transfers of your personal data by contacting the 369club Data Protection Officer.

14 Amendments to This Privacy Policy

369club reserves the right to amend this Privacy Policy at any time. When material changes are made to the Policy, we will notify registered players through in-platform notifications and, where required, by direct communication to your registered mobile number or email address.

The effective date of the current version is displayed at the top of this page. Where changes are made in response to legislative amendments or regulatory guidance from the National Privacy Commission, they will be implemented as required by applicable timelines. We encourage you to review this Policy periodically to stay informed about how your personal data is handled.

Continued use of the 369club platform following notification of material Policy changes constitutes your acknowledgment of the updated Policy. If you do not accept the amended Policy, you should discontinue use of the platform and contact support to arrange account closure.

15 Contact and Data Protection Officer

For all privacy-related inquiries, data subject rights requests, or concerns regarding the handling of your personal data by 369club, please contact us through the following channels:

If you wish to escalate a data privacy complaint that has not been resolved to your satisfaction by 369club, you may file a complaint with the National Privacy Commission (NPC) of the Philippines, the regulatory body responsible for enforcing the Data Privacy Act of 2012.