pn365 Casino – Privacy Policy

1. Introduction

pn365 ("pn365," "we," "us," "our") is an online casino and gaming platform serving Filipino adults in the Republic of the Philippines. We are committed to protecting the privacy and personal data of every registered player and website visitor in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, the issuances of the National Privacy Commission (NPC), and applicable PAGCOR data governance standards.

This Privacy Policy describes in plain terms: what personal data pn365 collects from you; the purposes and legal bases for processing that data; how long we retain it; with whom we share it; the security measures we apply; and the specific rights you hold as a data subject under Philippine law. Reading this policy fully is the best way to understand how pn365 handles your information.

This policy should be read alongside the pn365 Terms and Conditions, which govern the overall use of the Platform, and the Responsible Gaming Policy, which addresses the specific data handling that supports player protection tools such as deposit limits and self-exclusion.

2. Data Controller Identity

For the purposes of the Data Privacy Act of 2012, pn365 acts as the Personal Information Controller (PIC) in respect of all personal data collected through the Platform. As PIC, pn365 determines the purposes and means by which your personal data is processed.

Where pn365 engages third-party service providers to process personal data on its behalf — such as payment processors, game software providers, identity verification services, or cloud infrastructure providers — those entities act as Personal Information Processors (PIPs) and are contractually bound to process your data only on pn365's instructions and in compliance with applicable Philippine data protection law.

pn365 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection law. Contact details for the DPO are provided in Section 15 of this Policy.

3. Personal Data We Collect

pn365 collects the following categories of personal data from registered players and website visitors. The specific data collected depends on the nature of your interaction with the Platform.

3.1 Identity and Registration Data

• Full legal name as it appears on your government-issued identification document;
• Date of birth (for mandatory 21+ age verification);
• Gender (where voluntarily provided);
• Nationality and country of residence;
• Username chosen at registration.

3.2 Contact Data

• Email address used for account registration and communications;
• Philippine mobile number used for OTP verification and two-factor authentication;
• Residential address (required for KYC verification and in accordance with anti-money laundering obligations).

3.3 Identity Verification (KYC) Data

• Copy of a valid Philippine government-issued photo ID (PhilSys National ID, driver's license, passport, or UMID);
• Proof of address documents (utility bill, bank statement, or equivalent dated within 90 days);
• Source of funds documentation where required for compliance review;
• Facial image or selfie where required for biometric identity verification.

3.4 Financial and Transaction Data

• GCash or PayMaya account details (phone number associated with the e-wallet);
• Bank account details where bank transfer is used;
• Deposit history, withdrawal history, and current wallet balance;
• Transaction reference numbers and timestamps.

3.5 Gaming Activity Data

• Game session history including titles played, bet amounts, win/loss outcomes, and session durations;
• Sports betting selections, stakes, and outcomes;
• Bonus and promotion claim history;
• VIP tier status and loyalty point accumulation.

3.6 Technical and Usage Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser information;
• Login timestamps and session duration;
• Pages visited and navigation behavior within the Platform;
• Error logs and technical diagnostics relevant to platform performance.

4. How We Collect Your Data

pn365 collects personal data through the following methods:

• Directly from you — information you provide at registration, during KYC verification, when contacting customer support, or when participating in promotions;
• Automatically — technical data collected through cookies, session logs, and server-side analytics as you use the Platform;
• From third parties — identity verification data returned by accredited KYC service providers; fraud risk scores from anti-fraud screening services; payment status updates from GCash, PayMaya, or banking partners.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, pn365 processes personal data on the following legal bases:

6. How pn365 Uses Your Personal Data

pn365 uses the personal data it collects strictly for the purposes described in this Policy. Specifically:

• Account Services — to create, maintain, and secure your pn365 account; to verify your identity and age; to process your login requests and manage session security;
• Payment Processing — to process deposits received from GCash, PayMaya, BPI, BDO, Metrobank, and other supported channels; to execute approved withdrawal requests to your verified payment method;
• Regulatory Compliance — to fulfill pn365's obligations under PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), and other applicable Philippine law; to submit required reports to regulatory authorities;
• Fraud Prevention and Security — to detect, investigate, and prevent unauthorized access, identity fraud, money laundering, bonus abuse, and other prohibited conduct;
• Responsible Gaming — to administer deposit limits, loss limits, session reminders, and self-exclusion tools at your request; to monitor for signs of problematic gambling behavior as required by PAGCOR responsible gaming obligations;
• Customer Support — to respond to your queries, complaints, and support requests; to maintain records of support interactions;
• Promotions and Rewards — to administer bonus offers, cashback, VIP tier progression, and promotional campaigns for which you are eligible and have not opted out;
• Platform Improvement — to analyze aggregated usage data to improve the Platform's performance, game library, and user experience.

7. Data Sharing and Disclosure

pn365 shares personal data with third parties only where necessary and only with appropriate safeguards in place. Recipients of your personal data may include:

• Payment Processors — GCash (Mynt), PayMaya (Maya Bank), BPI, BDO, Metrobank, and USDT wallet infrastructure providers, for the purpose of processing deposits and withdrawals in PHP or cryptocurrency;
• Identity Verification Providers — accredited KYC and anti-money laundering screening services used to verify your identity and age and to screen against sanctions and adverse media databases;
• Game Software Providers — licensed game developers (such as PG Soft, JILI, Pragmatic Play) receive minimal technical identifiers to deliver game content; they do not receive your full identity or payment data;
• Cloud Infrastructure and Hosting Providers — pn365 uses enterprise-grade cloud hosting for Platform operations; these providers act as data processors under contract and have no independent right to use your data;
• Regulatory and Law Enforcement Authorities — PAGCOR and other Philippine government agencies, including the Anti-Money Laundering Council (AMLC), where pn365 is legally required to report suspicious transactions, underage gambling, or other regulated matters; courts and law enforcement agencies under valid legal process;
• Professional Advisors — lawyers, auditors, and compliance consultants who are bound by professional confidentiality obligations.

All third-party data processors engaged by pn365 are required to maintain data security standards consistent with the Data Privacy Act and to process your data only for the specific purposes for which they are engaged.

8. Data Retention

pn365 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, subject to applicable legal and regulatory minimum retention requirements.

Specifically:

• Active account data is retained for the duration of your account relationship with pn365 and for a minimum of five (5) years after account closure, in accordance with PAGCOR record-keeping requirements and RA 9160 AMLA obligations;
• Transaction records (deposits, withdrawals, wagers) are retained for a minimum of five (5) years in compliance with anti-money laundering legislation;
• KYC documentation is retained for five (5) years following account closure or the last transaction, whichever is later;
• Support interaction records are retained for up to three (3) years following the interaction;
• Technical and usage logs are retained for up to twelve (12) months unless required longer for security investigation or legal proceedings;
• Promotional communication consent records are retained until consent is withdrawn plus a reasonable period to document the withdrawal.

Upon expiry of the applicable retention period, pn365 will securely delete or anonymize your personal data in a manner that prevents reconstruction or re-identification.

9. Data Security

pn365 implements a layered set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS/SSL) — all data transmitted between your device and pn365 servers is encrypted in transit using current TLS standards;
• Encryption at Rest — sensitive personal data including KYC documents and payment identifiers is encrypted when stored on pn365 systems;
• Access Controls — access to personal data is restricted on a strict need-to-know basis; pn365 staff are granted only the minimum data access necessary for their role;
• Two-Factor Authentication — available on all pn365 player accounts and enforced on internal staff systems handling personal data;
• Activity Monitoring — automated systems monitor for unusual access patterns, potential data exfiltration, and unauthorized login attempts;
• Vendor Security Assessments — third-party processors are assessed for security compliance before engagement and monitored on an ongoing basis.

10. Cookies and Tracking Technologies

pn365 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small data files stored on your device by your browser when you visit a website.

pn365 uses the following types of cookies:

• Strictly Necessary Cookies — required for the Platform to function; these include session authentication tokens and security cookies. These cannot be disabled without breaking core platform functionality;
• Functional Cookies — remember your preferences such as language and display settings to improve your experience on return visits;
• Analytics Cookies — collect aggregated, anonymized data about how players use the Platform to help pn365 identify performance issues and popular features. These do not identify you personally;
• Security and Fraud Prevention Cookies — assist in detecting and preventing bot activity, multi-accounting, and other prohibited behavior.

pn365 does not use third-party advertising cookies or behavioral profiling cookies for the purpose of serving targeted advertising on external websites. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair or prevent your use of the Platform.

11. Your Data Subject Rights

As a data subject under the Data Privacy Act of 2012, you hold the following specific rights with respect to your personal data processed by pn365. These rights may be exercised by contacting the pn365 Data Protection Officer at the contact details in Section 15.

12. Minors and Age Restriction

Age verification through KYC documentation is mandatory for all pn365 accounts before withdrawal access is granted. pn365 treats this obligation as absolute and applies it without exception in compliance with PAGCOR's minimum age requirements for licensed gambling services in the Philippines.

Parents or guardians who have reason to believe that a minor has registered on pn365 should contact the Data Protection Officer immediately at the contact details in Section 15 for prompt investigation and account suspension.

13. International Data Transfers

In operating the Platform, pn365 may transfer personal data to service providers whose infrastructure is located outside the Philippines — including cloud hosting providers and certain game platform operators with regional data centers in Southeast Asia or globally.

Where personal data is transferred outside the Philippines, pn365 ensures that appropriate safeguards are in place in accordance with the Data Privacy Act's requirements for cross-border data transfers. These safeguards may include: contractual data transfer agreements incorporating NPC-approved standard clauses; transfers to jurisdictions with an adequate level of data protection as recognized under Philippine law; or other legally approved transfer mechanisms.

pn365 does not transfer personal data to jurisdictions that lack adequate data protection standards without implementing the safeguards described above. If you have questions about the specific safeguards applicable to data transferred outside the Philippines, please contact our Data Protection Officer.

14. Changes to This Privacy Policy

pn365 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The "Last Updated" and "Effective Date" shown in the table of contents will be revised whenever the Policy is materially changed.

Where changes to this Policy are material — affecting your rights or how your data is used in ways that differ significantly from this version — pn365 will notify registered players by email to the address on file and/or by a prominent notice on the Platform, providing a reasonable period to review the changes before they take effect.

Your continued use of pn365 after the effective date of an updated Privacy Policy constitutes your acceptance of the changes. If you disagree with any updated terms, you may close your account in accordance with the process described in the Terms and Conditions, and data subject to mandatory retention will be handled as described in Section 8.

15. Contact Us and Data Protection Officer

For any queries, requests to exercise your data subject rights, or concerns about pn365's handling of your personal data, please contact us using the following information. All privacy-related requests are acknowledged within 3 business days and responded to within 15 business days in accordance with NPC guidelines.

• Privacy Email: [email protected] (plain text — not a clickable link)
• Subject Line for Privacy Requests: Please use "[DATA PRIVACY REQUEST] – [Your Account Username]" when emailing
• Live Chat: 24/7 via the pn365 Platform — reference "Data Privacy Request" in your opening message
• Response Commitment: All data subject access requests acknowledged within 3 business days; full responses within 15 business days

If you are not satisfied with pn365's response to a privacy concern or request, you have the right to file a complaint directly with the National Privacy Commission of the Philippines (NPC). The NPC's contact details and complaint procedures are available on the NPC's official website.