345ph Privacy Policy

1. Introduction

345ph is committed to protecting the privacy and security of your personal information. This Policy has been prepared in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

This Policy applies to all personal data collected through the 345ph platform, including data collected via the website at 345ph.app, through our customer support channels, and through any other means by which you interact with 345ph. It covers all registered players, visitors, and any other individuals whose personal data is processed by 345ph in connection with the operation of the platform.

We encourage you to read this Policy carefully and in full. If you have any questions or concerns about our privacy practices, please contact us using the details provided in Section 15 of this Policy.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, 345ph acts as the personal information controller in respect of the personal data it collects and processes in connection with the operation of the 345ph platform.

As personal information controller, 345ph determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable data protection laws and regulations in the Philippines.

3. Data We Collect

345ph collects the following categories of personal data in connection with the operation of the platform and the provision of gaming services:

345ph does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive personal information is collected, it is processed with the highest level of care and security.

4. How We Collect Your Data

345ph collects personal data through the following means:

• Direct interactions: Data you provide when registering for a 345ph account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Technical and usage data collected automatically when you access and use the 345ph platform, including through cookies, web beacons, and similar tracking technologies (see Section 10);
• Third-party sources: Identity and fraud-screening data received from third-party KYC verification providers, payment processors (such as GCash and Maya), and regulatory databases, where permitted by applicable law;
• Public sources: Publicly available information used to verify identity or comply with AML obligations, such as government watchlists or sanctions databases.

5. How We Use Your Data

345ph uses the personal data it collects for the following purposes:

• Account management: To create, maintain, and manage your 345ph player account, including processing your registration and verifying your identity;
• Service delivery: To provide you with access to the games, features, and services available on the 345ph platform;
• Financial transactions: To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card, and to maintain accurate transaction records;
• Regulatory compliance: To fulfil our obligations under applicable Philippine gaming regulations, KYC requirements, and AML laws, including reporting obligations to PAGCOR and other competent authorities;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the platform;
• Responsible gaming: To monitor gaming behaviour, identify signs of problem gambling, and administer responsible gaming tools such as deposit limits and self-exclusion;
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance;
• Marketing and promotions: To send you information about 345ph promotions, bonuses, and new features, where you have consented to receive such communications;
• Platform improvement: To analyse usage patterns, conduct research, and improve the functionality and user experience of the 345ph platform.

6. Legal Basis for Processing

345ph processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012:

• Consent: Where you have given your express consent to the processing of your personal data for a specific purpose, such as receiving marketing communications;
• Contractual necessity: Where processing is necessary for the performance of the contract between you and 345ph, including the provision of gaming services and the processing of financial transactions;
• Legal obligation: Where processing is necessary for 345ph to comply with a legal obligation, including KYC verification, AML reporting, and regulatory compliance under applicable Philippine gaming laws;
• Legitimate interests: Where processing is necessary for the legitimate interests of 345ph, such as fraud prevention, platform security, and the improvement of our services, provided that such interests are not overridden by your rights and interests.

7. Data Sharing and Disclosure

345ph does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, Maya, and banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals;
• KYC and identity verification providers: Third-party service providers engaged to assist with identity verification and fraud screening;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulatory obligation;
• Technology and infrastructure providers: Cloud hosting, data storage, and platform technology providers engaged by 345ph to operate and maintain the platform, subject to contractual data protection obligations;
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by 345ph in connection with the operation of the platform;
• Law enforcement: Where required by a valid court order, subpoena, or other lawful request from a competent authority.

All third parties with whom 345ph shares personal data are required to process such data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

8. Data Retention

345ph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

In general, 345ph applies the following retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and gaming regulatory requirements;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable AML regulations;
• KYC verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction;
• Customer support communications: Retained for a period of two (2) years from the date of the communication, unless a longer period is required for dispute resolution or legal proceedings;
• Marketing data: Retained until you withdraw your consent to receive marketing communications, after which it will be deleted or anonymised.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with 345ph's data disposal procedures.

9. Data Security

345ph implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 345ph platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Access controls and role-based permissions limiting access to personal data to authorised personnel only;
• Regular security assessments, penetration testing, and vulnerability scanning of the platform;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Staff training on data protection obligations and information security best practices.

While 345ph takes all reasonable steps to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 345ph will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

10. Cookies & Tracking Technologies

The 345ph platform uses cookies and similar tracking technologies to enhance your experience, analyse platform usage, and support security and fraud prevention functions. A cookie is a small text file placed on your device when you visit a website.

345ph uses the following types of cookies:

• Strictly necessary cookies: Essential for the operation of the platform, including maintaining your login session and enabling core platform functionality. These cookies cannot be disabled;
• Performance and analytics cookies: Used to collect anonymised information about how visitors use the platform, helping us identify areas for improvement;
• Functional cookies: Used to remember your preferences and settings, such as language and display preferences;
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

You may control the use of non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 345ph platform. For more information on managing cookies, refer to your browser's help documentation.

11. Your Rights Under the Data Privacy Act

As a data subject under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 345ph:

• Right to be informed: The right to be informed of the existence of processing, the nature of the data collected, and the purposes for which it is being processed;
• Right of access: The right to obtain a copy of the personal data that 345ph holds about you, along with information about how it is being processed;
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data that 345ph holds about you;
• Right to erasure or blocking: The right to request the deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful;
• Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation, including processing for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe that your data protection rights have been violated.

To exercise any of the above rights, please contact the 345ph privacy team using the contact details provided in Section 15. We will respond to all valid requests within a reasonable timeframe and in accordance with the requirements of the Data Privacy Act of 2012. Please note that certain rights may be subject to limitations where processing is required for legal or regulatory compliance purposes.

12. Children's Privacy

345ph takes the protection of minors seriously. The platform is not directed at, and is not intended for use by, individuals under the age of 21. During the registration process, 345ph requires all applicants to confirm that they are at least 21 years of age and to provide a valid government-issued ID for age verification purposes.

If 345ph becomes aware that it has inadvertently collected personal data from an individual under the age of 21, it will take immediate steps to delete such data and close the associated account. If you believe that a minor may have registered on the 345ph platform, please contact our support team immediately.

13. Cross-Border Data Transfers

In the course of operating the 345ph platform, your personal data may be transferred to, stored in, or processed in countries other than the Philippines, including in connection with the use of cloud hosting infrastructure or third-party service providers located outside the Philippines.

Where personal data is transferred outside the Philippines, 345ph ensures that appropriate safeguards are in place to protect your data in accordance with the requirements of the Data Privacy Act of 2012. These safeguards may include contractual data protection clauses, adequacy determinations, or other mechanisms recognised by the National Privacy Commission.

By using the 345ph platform, you consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

14. Changes to This Privacy Policy

345ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or the features and services offered on the platform. The date of the most recent revision will be indicated at the top of this page.

Where material changes are made to this Policy, 345ph will notify registered players by posting a prominent notice on the platform or by sending an email to the address registered on your account. Your continued use of the 345ph platform following the posting of any revised Policy constitutes your acceptance of the changes.

We encourage you to review this Policy periodically to stay informed about how 345ph is protecting your personal information.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which 345ph processes your personal data, please contact our privacy team. We are committed to addressing all privacy-related enquiries promptly and in accordance with applicable law.

Privacy & Data Protection Enquiries:
[email protected]

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that your data protection rights have been violated. For more information about the NPC and your rights under the Data Privacy Act of 2012, please refer to the NPC's official resources.

For general platform support, visit our FAQ page. For information about responsible gaming tools and resources, visit our Responsible Gaming page.