Scope: This Privacy Policy ("Policy") applies to all personal data collected and processed by 35ph ("35ph", "we", "us", "our") in connection with the operation of the 35ph online gaming platform at 35ph.asia, including all games, services, account features, and customer support interactions. By registering a 35ph account or using any 35ph service, you confirm that you have read and understood this Policy and consent to the data practices described herein.
Section 1
About This Policy
35ph takes the privacy and security of your personal data seriously. This Policy is designed to give you clear, honest information about how 35ph handles the personal information you share with us when you register, play, deposit, or contact us. We have written this Policy in plain language where possible, while maintaining the legal precision necessary for a regulated gaming operator.
This Policy should be read alongside the 35ph Terms & Conditions, which govern your use of the platform and are incorporated herein by reference. In the event of any conflict between the Terms & Conditions and this Privacy Policy on a data-related matter, this Privacy Policy shall prevail.
35ph processes personal data in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, as well as applicable PAGCOR licensing requirements regarding player data management.
Section 2
Personal Data We Collect
35ph collects personal data through several channels: directly from you during registration and account use, automatically through your use of the platform, and from third-party payment and identity verification providers where applicable. The categories of data we collect include:
Registration & Identity Data:
- Full legal name as it appears on your government-issued ID
- Date of birth (for age verification — all players must be 21 years of age or older)
- Registered email address and Philippine mobile number
- Username and encrypted account password
- Residential address in the Philippines
KYC & Verification Data:
- Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, UMID, PhilSys national ID, driver's license)
- Proof of address documents (e.g., utility bills, bank statements addressed to your registered address)
- Proof of payment method ownership where required
- Selfie verification images for identity matching purposes
Financial & Transaction Data:
- GCash account numbers, PayMaya account details, BPI/BDO/Metrobank account details (account number and name — not full card details)
- Deposit and withdrawal transaction history
- Cryptocurrency wallet addresses used for USDT transactions
Gameplay & Behavioral Data:
- Game session logs, bet histories, and win/loss records
- Bonus and promotion participation records
- Responsible gaming settings and self-exclusion records
Technical & Device Data:
- IP address and approximate geolocation at time of login
- Device type, operating system, and browser version
- Session timestamps and platform interaction logs
Communications Data:
- Records of customer support interactions via live chat, email, or other channels
- Feedback, complaints, and dispute records
Section 3
How We Use Your Personal Data
35ph processes your personal data for the following purposes:
- Account Management: To create, manage, and maintain your 35ph account, verify your identity, and authenticate your logins.
- Service Delivery: To make the 35ph games, live casino, bingo, and sports betting services available to you; to process deposits and withdrawals; and to administer bonuses and promotions.
- Age & Identity Verification: To verify that you meet the minimum age requirement of 21 years and that your identity matches the information provided at registration, in compliance with PAGCOR requirements.
- Fraud Prevention & Security: To detect, investigate, and prevent unauthorized account access, fraudulent activity, money laundering, and other illegal activity.
- Regulatory Compliance: To comply with applicable legal and regulatory obligations, including anti-money laundering (AML) record-keeping requirements and PAGCOR reporting obligations.
- Responsible Gaming: To monitor gameplay patterns for signs of problem gambling, enforce self-exclusion requests, and administer responsible gaming tools including deposit limits and session alerts.
- Customer Support: To respond to your inquiries, resolve complaints, and administer disputes.
- Platform Improvement: To analyze aggregate, anonymized gameplay and usage data for the purpose of improving 35ph products, features, and user experience.
- Marketing Communications: Where you have provided consent, to send promotional offers, bonus notifications, and platform updates via email or SMS. You may withdraw this consent at any time.
Section 4
Legal Basis for Processing
35ph processes personal data on the following legal grounds under the Philippine Data Privacy Act of 2012:
- Contractual Necessity: Processing necessary to perform the contract between you and 35ph — i.e., to provide the gaming platform, process financial transactions, and administer your account.
- Legitimate Interests: Processing necessary for the legitimate interests of 35ph, including fraud detection, security monitoring, AML compliance, and platform analytics — where those interests are not overridden by your data protection rights.
- Legal Obligation: Processing necessary to comply with applicable legal and regulatory obligations, including PAGCOR licensing conditions, AML laws, and tax reporting requirements.
- Consent: For optional processing activities such as marketing communications and certain cookie-based analytics, 35ph relies on your freely given, specific, and informed consent, which you may withdraw at any time without affecting the lawfulness of prior processing.
Section 5
Data Sharing & Third Parties
35ph does not sell your personal data to any third party. We share personal data only in the following limited circumstances:
- Payment Processors: GCash (GXI), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and cryptocurrency network infrastructure providers — for the purpose of processing your financial transactions.
- KYC & Identity Verification Providers: Third-party identity verification services used to authenticate player identities and conduct AML screening.
- Game Software Providers: Game providers such as Pragmatic Play, PG Soft, JILI, and Evolution Gaming receive limited session data necessary to deliver their games within the 35ph platform. These providers are contractually prohibited from using your data for any purpose other than game delivery.
- Regulatory & Legal Authorities: Where required by law, court order, or PAGCOR regulatory requirement, 35ph may disclose player data to competent authorities. 35ph will notify affected players of such disclosures where legally permitted to do so.
- Professional Advisors: Lawyers, auditors, and accountants retained by 35ph, subject to binding confidentiality obligations.
All third-party service providers who process personal data on behalf of 35ph are required to maintain appropriate data security standards and are prohibited from using 35ph player data for their own purposes beyond the agreed service scope.
Section 6
Cookies & Tracking Technologies
35ph uses cookies and similar tracking technologies to improve platform functionality, maintain your login session, and analyze aggregate usage patterns. The types of cookies used include:
- Strictly Necessary Cookies: Required for core platform functions such as maintaining your authenticated session and remembering your language and display preferences. These cannot be disabled without impairing platform functionality.
- Performance & Analytics Cookies: Used to collect anonymized data about how players navigate the 35ph platform — which pages are visited most often, where users encounter errors, and how navigation flows perform. This data is used solely to improve the platform experience.
- Functionality Cookies: Enable personalization features such as remembering your game preferences and recent play history to populate the "Recently Played" section of your account dashboard.
You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use certain 35ph platform features, including the login session management system.
Section 7
Data Retention
35ph retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to applicable legal and regulatory retention requirements. Specific retention periods are as follows:
- Account Data: Retained for the lifetime of your active 35ph account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements applicable to gaming operators.
- Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine anti-money laundering regulations.
- KYC Documents: Retained for the period required by applicable regulations — typically five (5) years from the end of the customer relationship.
- Customer Support Records: Retained for three (3) years from the date of the interaction, or longer if the matter relates to an unresolved dispute or regulatory investigation.
- Marketing Consent Records: Retained until consent is withdrawn and for a period thereafter sufficient to demonstrate that consent was obtained.
When personal data is no longer required, 35ph will securely delete or anonymize it in accordance with our internal data deletion procedures.
Section 8
Data Security
35ph employs a range of technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration. These measures include:
- TLS 1.3 / 256-bit SSL encryption for all data in transit between your device and 35ph servers
- AES-256 encryption for sensitive data at rest, including identity documents and financial records
- Access controls limiting personal data access to authorized 35ph personnel with a legitimate operational need
- Behavioral anomaly detection to identify and flag unusual account activity patterns
- Regular third-party security audits and penetration testing of the 35ph platform
- Two-factor authentication available to all players as an additional account security layer
While 35ph implements industry-standard security measures, no system is completely immune to security breaches. In the event of a personal data breach that poses a significant risk to affected players, 35ph will notify affected individuals and report to the National Privacy Commission (NPC) within the timeframe required under the Data Privacy Act of 2012.
Section 9
Your Data Rights
Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 35ph:
- Right to Be Informed: The right to be informed of how your personal data is collected, used, retained, and disclosed — fulfilled through this Privacy Policy.
- Right to Access: The right to request a copy of the personal data 35ph holds about you, together with information about how that data is processed.
- Right to Correction: The right to request correction of any inaccurate or incomplete personal data in your 35ph account. Many corrections can be made directly within your account settings.
- Right to Erasure ("Right to be Forgotten"): The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected — subject to legal and regulatory retention requirements that may require 35ph to retain certain data notwithstanding a deletion request.
- Right to Object: The right to object to the processing of your personal data for marketing purposes at any time. You may withdraw marketing consent through your account notification settings or by contacting support.
- Right to Data Portability: The right to receive a copy of certain personal data you have provided to 35ph in a structured, commonly used, machine-readable format.
- Right to Lodge a Complaint: The right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe that 35ph has violated your data privacy rights.
To exercise any of the above rights, contact 35ph's Data Privacy Officer at: [email protected]. 35ph will respond to all data rights requests within 15 business days of receipt.
Section 10
Children & Minors
The 35ph platform is strictly intended for adults aged 21 years and above. 35ph does not knowingly collect personal data from individuals under the age of 21. If 35ph discovers or is notified that a registered account belongs to an individual who is under 21 years of age, the account will be immediately suspended, all associated balances will be withheld pending investigation, and the personal data associated with the account will be securely deleted following the conclusion of any required AML review.
If you believe that a minor has registered a 35ph account, please contact our support team at [email protected] immediately. We will investigate and act promptly.
Section 11
Changes to This Privacy Policy
35ph reserves the right to update this Privacy Policy at any time. Where changes are material — for example, if we begin processing a new category of personal data or change how existing data is used — we will notify registered players via email or platform notification prior to the changes taking effect. The "Last updated" date at the top of this page will reflect the most recent revision.
Continued use of the 35ph platform following notification of a revised Privacy Policy constitutes your acceptance of the changes. If you do not accept the revised Policy, you must discontinue use of the platform and contact support to request account closure and data deletion where applicable.
Section 12
Contact & Data Privacy Officer
For any questions, concerns, or requests relating to this Privacy Policy or 35ph's data processing practices, please contact us through the following channels:
- Email: [email protected]
- Live Chat: Available 24/7 via the chat widget on 35ph.asia
- Response Time: Data privacy requests are acknowledged within 24 hours and resolved within 15 business days.
35ph's Data Privacy Officer (DPO) oversees compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. The DPO is reachable through the email address above, clearly marked "Attention: Data Privacy Officer."