Privacy Policy

1. Introduction and Scope

pg365 (the "Company," "we," "us," or "our") operates an online casino and sports betting platform serving Filipino players under a PAGCOR licence. We are committed to protecting your privacy and complying with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable PAGCOR data protection directives. This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you visit our website at pg365.cam, create an account, or use our services.

"Personal information" or "personal data" refers to any information, whether recorded in a material form or not, from which your identity is apparent or can be reasonably ascertained, including but not limited to your name, date of birth, address, contact details, government-issued identification numbers, financial information, and gambling activity records.

2. Data Controller and Contact Information

pg365 is the data controller responsible for the collection and processing of your personal information. For inquiries, complaints, or requests related to your personal data, please contact our Data Protection Officer:

• Email: [email protected] (plain text, not clickable)
• Mailing Address: pg365 Data Protection Officer, Manila, Philippines
• Response Time: We will respond to privacy requests within 15 business days in accordance with Philippine law.

3. Personal Information We Collect

3.1 Information You Provide Directly

When you register an account with pg365, we collect the following personal information:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued ID details (Philippine passport, driver's license, UMID, SSS, or TIN).
• Contact Information: Residential address, Philippine mobile number, and email address.
• Account Credentials: Username, password, and security questions/answers.
• Financial Information: Payment method details including GCash account number, Maya account, bank account numbers (BPI, BDO, Metrobank, etc.), and transaction history.
• Verification Documents: Copies of government-issued IDs, proof of address (utility bills, bank statements), and selfie photos for identity verification.
• Communication Records: Content of live chat conversations, emails, customer support tickets, and phone call recordings.

3.2 Information Collected Automatically

When you access pg365 services, we automatically collect technical and behavioral data:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifier (IMEI or UDID), and installed plugins.
• Connection Data: IP address, internet service provider (ISP), geolocation data (derived from IP address), and time zone settings.
• Usage Data: Pages visited, features used, time spent on site, click patterns, search queries, game preferences, bet history, deposit and withdrawal activity, and session duration.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, pixel tags, and local storage data. See Section 10 (Cookies Policy) for details.

3.3 Information from Third Parties

We may receive personal data from third-party sources:

• Payment Processors: GCash, Maya, BPI, BDO, and other financial institutions provide transaction confirmation, account verification status, and fraud alerts.
• Identity Verification Services: Third-party KYC providers verify your identity documents and cross-check against government databases and watchlists.
• Gaming Software Providers: Game developers (Evolution Gaming, Pragmatic Play, NetEnt, etc.) provide gameplay logs and technical data for game integrity monitoring.
• Affiliate Partners: Marketing affiliates may share referral data including referral codes and traffic source information.
• Public Databases: PAGCOR self-exclusion registries, AMLC watchlists, and publicly available data for anti-fraud screening.

4. How We Use Your Personal Information

4.1 Account Management and Service Delivery

We process your personal data to:

• Create and maintain your pg365 account
• Verify your identity and age to ensure compliance with 21+ gambling age restrictions
• Process deposits, withdrawals, and other financial transactions
• Provide customer support and respond to inquiries
• Facilitate gameplay, process bets, and calculate winnings
• Administer bonuses, promotions, and VIP rewards
• Send account notifications, transaction confirmations, and important service updates

4.2 Legal and Regulatory Compliance

pg365 is required by law to process personal data for:

• Compliance with PAGCOR licensing conditions and reporting requirements
• Anti-money laundering (AML) monitoring and suspicious transaction reporting to AMLC
• Age verification and prevention of underage gambling
• Self-exclusion program administration and responsible gaming enforcement
• Fraud detection, prevention, and investigation
• Cooperation with law enforcement investigations and court orders
• Tax reporting and withholding obligations under Philippine tax law

4.3 Security and Fraud Prevention

We analyze personal data to:

• Detect and prevent duplicate accounts, bonus abuse, and fraudulent activity
• Monitor betting patterns for signs of match-fixing, collusion, or unfair play
• Identify unauthorized account access and secure compromised accounts
• Verify payment method ownership and prevent payment fraud
• Conduct risk assessments and security audits

4.4 Marketing and Communications (With Your Consent)

Subject to your consent, which you may withdraw at any time, we use your contact information to:

• Send promotional offers, bonuses, and exclusive VIP deals via email, SMS, or push notifications
• Inform you about new games, features, and tournaments
• Conduct customer satisfaction surveys and request feedback
• Personalize your experience based on gaming preferences and activity

You can opt out of marketing communications by clicking "unsubscribe" in emails, replying STOP to SMS messages, or adjusting notification settings in your account dashboard. Opting out of marketing does not affect transactional or service-related communications.

4.5 Analytics and Service Improvement

We analyze aggregated and anonymized data to:

• Understand user behavior and preferences
• Optimize website performance and user experience
• Identify technical issues and improve platform stability
• Develop new features and game offerings
• Conduct statistical analysis and business intelligence reporting

5. Legal Basis for Processing Personal Data

Under the Philippine Data Privacy Act, we process your personal data based on the following legal grounds:

• Consent: You have explicitly agreed to the processing for specific purposes (e.g., marketing communications).
• Contract Performance: Processing is necessary to fulfill our contractual obligations to provide gambling services, process payments, and manage your account.
• Legal Obligation: Processing is required to comply with Philippine laws, PAGCOR regulations, AML directives, and tax obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, and service improvement, provided these interests do not override your privacy rights.

6. How We Share Your Personal Information

6.1 Sharing Within pg365 Group

Your personal data may be shared among pg365 affiliated companies and subsidiaries for centralized account management, consolidated reporting, and shared fraud detection systems. All affiliated entities are bound by the same data protection standards described in this Privacy Policy.

6.2 Third-Party Service Providers

We engage trusted third-party service providers who process personal data on our behalf:

• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, and other financial institutions process deposits, withdrawals, and payment verifications.
• Identity Verification Providers: KYC services verify identity documents, conduct background checks, and screen against watchlists.
• Gaming Software Providers: Evolution Gaming, Pragmatic Play, NetEnt, and other game developers provide casino games and sports betting platforms.
• Cloud Hosting Providers: Data centers and cloud infrastructure providers store and process data on secure servers.
• Customer Support Tools: Live chat software, helpdesk platforms, and CRM systems manage customer interactions.
• Marketing and Analytics Platforms: Email service providers, SMS gateways, analytics tools, and advertising platforms (used only with your consent).

All third-party processors are contractually required to maintain confidentiality, implement appropriate security measures, and process data only according to our instructions and applicable data protection laws.

6.3 Regulatory and Law Enforcement Disclosures

We are legally obligated to disclose personal data to:

• PAGCOR: For licensing compliance, responsible gaming enforcement, and regulatory audits.
• Anti-Money Laundering Council (AMLC): For suspicious transaction reporting and AML investigations.
• Bureau of Internal Revenue (BIR): For tax reporting and withholding compliance.
• National Privacy Commission (NPC): In response to official data protection inquiries or complaints.
• Law Enforcement Agencies: In response to valid court orders, subpoenas, or lawful requests in criminal investigations.

6.4 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer, and the new entity will be required to handle your data in accordance with this Privacy Policy or provide you with a new privacy notice.

6.5 No Sale of Personal Data

pg365 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. Any data sharing described in this policy is strictly for service delivery, legal compliance, or security purposes.

7. Data Retention and Deletion

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Active Accounts: Personal data is retained for the duration of your account's active status.
• Closed Accounts: After voluntary account closure, personal data is retained for 5 years to comply with PAGCOR record-keeping requirements, AML obligations, and to resolve disputes or investigations.
• Transaction Records: Financial transaction data is retained for 10 years in accordance with Philippine banking and tax laws.
• Marketing Data: If you opt out of marketing, your contact information is retained only to honor your opt-out request and prevent future marketing.
• Self-Excluded Players: Self-exclusion records are retained for the exclusion period plus 5 years to prevent circumvention attempts.

After retention periods expire, personal data is securely deleted or anonymized. You may request early deletion of your data by contacting our Data Protection Officer, but we may be unable to delete data if retention is legally required.

8. Data Security Measures

pg365 implements industry-standard technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmissions are encrypted using TLS 1.3 (Transport Layer Security). Sensitive data stored in databases is encrypted at rest using AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized personnel on a need-to-know basis. Multi-factor authentication (MFA) is required for administrative access.
• Firewalls and Intrusion Detection: Network security measures include firewalls, intrusion detection systems (IDS), and real-time threat monitoring.
• Regular Security Audits: Independent security audits and penetration testing are conducted annually to identify and address vulnerabilities.
• Employee Training: All staff with access to personal data receive mandatory data protection and security training.
• Data Breach Response Plan: In the event of a data breach, we will notify affected users and the National Privacy Commission within 72 hours as required by law.

While we implement robust security measures, no system is completely secure. You are responsible for maintaining the confidentiality of your account credentials and should immediately report any suspected unauthorized access to customer support.

9. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal data:

• Right to Access: You may request a copy of all personal data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data, subject to legal retention requirements.
• Right to Object: You may object to processing of your personal data for direct marketing or other purposes.
• Right to Data Portability: You may request your personal data in a structured, machine-readable format to transfer to another service provider.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission if you believe your privacy rights have been violated.

To exercise any of these rights, please submit a written request to [email protected] (plain text, not clickable) with the subject line "Privacy Rights Request." We will verify your identity and respond within 15 business days. Some requests may require additional time if they are particularly complex or voluminous.

10. Cookies and Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They allow the website to recognize your device and remember your preferences, login status, and browsing activity. pg365 uses cookies and similar tracking technologies to provide a personalized and secure user experience.

10.2 Types of Cookies We Use

• Essential Cookies: Required for core functionality such as logging in, session management, and transaction processing. These cannot be disabled.
• Security Cookies: Detect fraudulent activity, prevent unauthorized access, and protect against security threats.
• Performance Cookies: Collect anonymous usage data to analyze website performance, identify errors, and improve user experience.
• Functional Cookies: Remember your preferences such as language settings, display options, and notification preferences.
• Marketing Cookies (Consent Required): Track your browsing activity across websites to deliver personalized advertising and measure campaign effectiveness. These are only activated with your explicit consent.

10.3 Managing Cookies

You can manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, but disabling essential cookies may impair your ability to use certain features of pg365. To opt out of marketing cookies, adjust your preferences in your account dashboard or use browser privacy settings.

11. International Data Transfers

pg365 primarily operates within the Philippines and stores data on servers located in Philippine data centers. However, some third-party service providers (such as cloud hosting providers and gaming software developers) may process data on servers located outside the Philippines. When data is transferred internationally, we ensure that:

• The receiving country has adequate data protection laws recognized by the National Privacy Commission, or
• Contractual safeguards such as Standard Contractual Clauses are in place to protect your data, or
• You have provided explicit consent for the international transfer.

12. Children's Privacy

pg365 services are strictly prohibited for individuals under 21 years of age, in compliance with Philippine gambling laws. We do not knowingly collect personal data from minors. If we become aware that a user is under 21, we will immediately suspend the account, void all transactions, and delete associated personal data. If you believe a minor has accessed pg365 services, please contact us immediately at [email protected] (plain text, not clickable).

13. Changes to This Privacy Policy

pg365 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated to users via email, account notification, or prominent website notice at least 30 days before taking effect. Continued use of pg365 services after changes are published constitutes acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically.

14. Contact Information and Complaints

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Data Protection Officer:

• Email: [email protected] (plain text, not clickable)
• Response Time: We aim to respond to all privacy inquiries within 15 business days.

If you are not satisfied with our response or believe your privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission:

• National Privacy Commission
• 5th Floor, Philippine International Convention Center (PICC), Vicente Sotto Street, Pasay City, Metro Manila, Philippines
• Email: [email protected]
• Hotline: (02) 8234-2228