Privacy Policy

Welcome to the 36gl Privacy Policy. 36gl ("we", "us", "our", "the Platform") is an online gaming platform serving Filipino players at 36gl.net. This Privacy Policy describes how 36gl collects, processes, stores, and protects the personal information of registered players and visitors to the Platform.

This policy applies to all personal data collected through the 36gl website at 36gl.net, any related mobile applications, customer support channels, and any other touchpoint through which you interact with 36gl. It covers both registered account holders and casual visitors who have not yet created an account.

By accessing or using the 36gl Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this policy, you should not use the Platform.

This Privacy Policy is intended to be read alongside the 36gl Terms & Conditions and Responsible Gaming Policy, both of which contain additional information relevant to your use of the Platform.

For the purposes of the Data Privacy Act of 2012, 36gl is the personal information controller responsible for your personal data collected through the Platform. As the data controller, 36gl determines the purposes and means of processing your personal information.

36gl has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection laws, handling data subject requests, and serving as the point of contact for the National Privacy Commission. Contact details for the DPO are provided in Section 16 of this policy.

36gl collects personal data across several categories depending on your level of interaction with the Platform. Below is a comprehensive breakdown of what we may collect:

3.1 Registration & Identity Data

• Full legal name (as it appears on a government-issued ID)
• Date of birth (to verify you are 21 years of age or older)
• Gender (optional, for personalisation purposes)
• Nationality and country of residence
• Residential address (barangay, city/municipality, province, ZIP code)
• Email address and mobile phone number
• Username and encrypted password

3.2 KYC & Verification Documents

• Copies of government-issued photo identification (Philippine National ID, passport, driver's licence, SSS/GSIS card, or PRC ID)
• Proof of residential address documents (utility bill, bank statement, or barangay certification)
• Proof of payment method ownership (e-wallet screenshots, bank statements)
• Source of funds declaration where required under AML guidelines
• Selfie or liveness verification photograph where requested

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction history
• Payment method identifiers (GCash mobile number, Maya account reference, bank account last digits)
• Transaction amounts, timestamps, and reference numbers
• Bonus and promotional credit history

3.4 Gaming & Behavioural Data

• Games played, bet amounts, game session durations, and win/loss records
• Responsible gaming tool usage (deposit limits set, self-exclusion requests)
• Login and logout timestamps and session duration
• Platform interaction logs including pages visited and features used

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Browser type, version, and operating system
• Device type (desktop, mobile, tablet) and device identifier
• Referring URL and pages visited prior to registration
• Cookie identifiers and session tokens (see Section 8)

3.6 Communications Data

• Customer support chat transcripts and email correspondence
• Survey responses and feedback submissions
• Promotion opt-in and opt-out preferences

36gl collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey.
• Automatically — through cookies, web beacons, server logs, and analytics tools when you browse the 36gl Platform, even prior to account registration.
• From third-party payment providers — GCash, Maya, GrabPay, BPI, BDO, Metrobank, 7-Eleven, Coins.ph, and USDT payment processors may share transaction confirmation data and payment method verification status with 36gl.
• From KYC and identity verification partners — third-party KYC service providers used to verify the authenticity of identity documents may share verification results with 36gl.
• From fraud prevention and AML screening services — 36gl uses third-party tools to screen for sanctioned individuals, politically exposed persons (PEPs), and fraud risk signals, which may involve cross-referencing provided data against external databases.
• From regulatory authorities — PAGCOR or other competent Philippine authorities may share information relevant to account compliance reviews.

36gl uses the personal data collected for the following purposes:

• Account creation and management — to register your player account, authenticate your identity on login, and maintain accurate account records.
• KYC and age verification — to confirm that you meet the 21+ age requirement for online casino gaming in the Philippines and that your identity is genuine.
• Payment processing — to facilitate deposits and withdrawals via your chosen payment methods, reconcile transactions, and prevent payment fraud.
• Regulatory compliance — to meet PAGCOR licensing obligations, Anti-Money Laundering Act reporting requirements, and National Privacy Commission registration and reporting duties.
• Fraud prevention and security — to detect and prevent unauthorised account access, multi-account abuse, bonus fraud, and other prohibited conduct as defined in the 36gl Terms & Conditions.
• Customer support — to respond to your enquiries, process complaints, and improve the quality of support interactions.
• Responsible gaming — to monitor player activity for indicators of problem gambling, administer self-exclusion and limit-setting tools, and comply with responsible gaming obligations.
• Platform improvement — to analyse aggregated usage patterns, identify technical issues, test new features, and improve the overall player experience on 36gl.
• Marketing and promotions — subject to your communication preferences, to send personalised bonus offers, promotions, and platform news via email, SMS, or in-app notification. You may opt out at any time.
• Legal proceedings — to establish, exercise, or defend legal claims involving 36gl where necessary.

Under the Data Privacy Act of 2012, 36gl processes your personal data under one or more of the following lawful bases:

• Consent — where you have given clear, freely given, specific, and informed consent, such as opting in to marketing communications or agreeing to this Privacy Policy at registration.
• Contractual necessity — where processing is necessary to perform the contract between you and 36gl (i.e., the Terms & Conditions), such as processing deposits, running game sessions, and processing withdrawals.
• Legal obligation — where processing is required to comply with a legal obligation applicable to 36gl, including PAGCOR licensing conditions, AML reporting under RA 9160, and data subject rights administration under RA 10173.
• Legitimate interests — where processing is necessary for the legitimate interests of 36gl or a third party, such as fraud detection, platform security, and internal analytics — provided those interests are not overridden by your privacy rights.
• Vital interests — in limited circumstances where processing is necessary to protect the vital interests of the data subject or another natural person.

36gl does not sell your personal data. We share personal data only with the following categories of recipients and only to the extent necessary for the stated purpose:

• Payment service providers — GCash, Maya, GrabPay, BPI, BDO, Metrobank, 7-Eleven, Coins.ph, and USDT processors, strictly for the purpose of executing deposit and withdrawal transactions.
• KYC and identity verification providers — third-party service providers that assist 36gl in verifying the authenticity and validity of identity documents submitted during KYC processes.
• Fraud prevention and AML screening providers — services that assist 36gl in screening for sanctions lists, PEP databases, and fraud risk indicators as required by Philippine AML law.
• Game technology providers — licensed third-party game studios whose games are accessible via the 36gl Platform may receive anonymised session data for game performance and fairness auditing purposes.
• IT infrastructure and cloud service providers — companies that host, maintain, and secure the 36gl Platform infrastructure, operating under strict data processing agreements with 36gl.
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities where disclosure is required by law or court order.
• Professional advisors — lawyers, auditors, and consultants engaged by 36gl who require access to data in the performance of their professional services, subject to professional confidentiality obligations.

36gl uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, and analyse usage patterns. The following types of cookies may be placed on your device:

• Strictly necessary cookies — essential for the Platform to function. These include session authentication tokens, CSRF protection cookies, and load balancer cookies. They cannot be disabled without breaking core functionality.
• Functional cookies — remember your preferences such as language, preferred payment method, and responsible gaming settings. Disabling these may affect your experience.
• Analytics cookies — collect anonymised data about how players use the Platform to help 36gl improve navigation, game discovery, and overall usability. Data collected is aggregated and not linked to individual identities.
• Security and fraud prevention cookies — used to detect suspicious activity, bot traffic, and multi-account fraud attempts. These are a necessary component of 36gl's security infrastructure.

You can manage cookie preferences through your browser settings. Note that disabling all cookies may prevent certain features of the 36gl Platform from working correctly. A cookie consent banner is presented on your first visit to the Platform, allowing you to indicate your preferences for non-essential cookies.

36gl retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Specific retention periods are as follows:

• Account data and KYC documents — retained for a minimum of five (5) years from the date of account closure or the date of the last transaction, whichever is later, in accordance with PAGCOR licensing requirements and AML record-keeping obligations under RA 9160.
• Transaction records — retained for a minimum of five (5) years from the date of each transaction for AML reporting and audit purposes.
• Customer support communications — retained for three (3) years from the date of the last interaction, to support dispute resolution and service quality review.
• Gaming session logs — retained for two (2) years for responsible gaming monitoring, fraud investigation, and game integrity auditing.
• Marketing preference records — retained for the duration of your account and for two (2) years after account closure, to honour opt-out requests.
• Technical and device logs — retained for twelve (12) months for security and fraud investigation purposes.

Following the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. Anonymised aggregate data may be retained indefinitely for statistical analysis purposes.

36gl implements a layered security framework to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• TLS/SSL encryption — all data transmitted between your browser or device and the 36gl Platform is encrypted using Transport Layer Security (TLS 1.2 or higher).
• AES-256 encryption at rest — sensitive data stored in 36gl databases, including identity documents and financial records, is encrypted at rest.
• Access controls — access to personal data is restricted to authorised 36gl personnel and contractors on a strictly need-to-know basis. Role-based access controls and audit logging are maintained.
• Two-factor authentication (2FA) — available to all players for account login security, and mandatory for administrative access by 36gl staff.
• Penetration testing and security audits — 36gl engages third-party security firms to conduct regular penetration tests and vulnerability assessments of the Platform.
• Data breach response plan — 36gl maintains an incident response plan. In the event of a personal data breach, affected players and the National Privacy Commission will be notified in accordance with RA 10173 requirements.

While 36gl takes all reasonable and appropriate measures to secure your data, no online platform can guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying 36gl immediately if you suspect unauthorised access to your account.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 36gl:

To exercise any of the above rights, contact 36gl's Data Protection Officer using the details in Section 16. 36gl will respond to all verified data subject requests within fifteen (15) calendar days. Requests that are complex or numerous may be extended by a further fifteen (15) days with prior notification.

The 36gl Platform is strictly for individuals aged 21 years and above. 36gl does not knowingly collect personal data from individuals under the age of 21. The minimum age of 21 is mandated by PAGCOR regulations governing online casino gaming in the Philippines.

Age verification is performed during the KYC process, and 36gl uses date of birth validation at the point of registration to screen out underage applicants. Any account subsequently found to belong to a person under the age of 21 will be immediately suspended, all data collected will be deleted in accordance with applicable law, and the matter will be escalated to 36gl's compliance team.

If you are a parent or guardian and believe that a minor has registered on the 36gl Platform using false information, please contact our Data Protection Officer immediately at the address provided in Section 16.

36gl primarily stores and processes personal data within data centres located in Southeast Asia. However, some of our third-party service providers — including cloud infrastructure partners, KYC verification providers, and fraud prevention services — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, 36gl ensures that appropriate safeguards are in place to protect the data in a manner consistent with the Data Privacy Act of 2012. Such safeguards may include:

• Standard contractual clauses approved by the National Privacy Commission or equivalent competent authority;
• Data processing agreements with the receiving party that impose obligations equivalent to those under RA 10173;
• Transfer to jurisdictions that the NPC has determined to provide an adequate level of data protection.

You may request further information about the specific safeguards applied to cross-border transfers by contacting the 36gl Data Protection Officer at the details provided in Section 16.

With your consent, 36gl may send you promotional communications about bonuses, new game releases, tournaments, special events, and other platform updates via email, SMS, or in-app push notifications. Your consent to receive marketing communications is collected separately during registration and is entirely optional — declining does not affect your ability to use the Platform.

You may withdraw your consent to marketing communications at any time through any of the following methods:

• Updating your communication preferences in the Account Settings section of your 36gl profile;
• Clicking the "Unsubscribe" link included in every promotional email sent by 36gl;
• Contacting 36gl customer support via live chat and requesting removal from all marketing lists;
• Emailing the Data Protection Officer at the address in Section 16 with the subject line "Marketing Opt-Out".

Opt-out requests will be processed within five (5) business days. Please note that even after opting out of marketing communications, 36gl may still send you transactional and account-related messages such as deposit confirmations, withdrawal notifications, security alerts, and policy update notices — these are not promotional in nature and cannot be disabled while your account remains active.

36gl reserves the right to update or amend this Privacy Policy at any time in response to changes in applicable law, regulatory guidance, business operations, or data processing practices. The "Last Updated" date at the top of this page will reflect the most recent revision.

For material changes that significantly affect how your personal data is processed or that reduce your privacy rights, 36gl will provide advance notice via email to your registered address and/or a prominent notice on the Platform no less than fourteen (14) calendar days before the changes take effect.

For minor, non-material amendments — such as corrections to typographical errors, clarifications to existing practices, or updates to contact details — 36gl may update this page without prior individual notice. Continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the personal data 36gl holds about you, please contact us through any of the following channels:

• Live Chat: Available 24/7 directly on the 36gl Platform — the fastest way to reach our support and privacy teams.
• Email: [email protected] — for general privacy enquiries, data subject access requests, and formal complaints. Use the subject line "Privacy Request" or "Data Subject Request" for prioritised handling.
• Data Protection Officer: Address your correspondence to the 36gl DPO specifically by writing "Attention: Data Protection Officer" in your email subject line or opening line.

If you are not satisfied with 36gl's response to your privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines:

36gl is committed to responding to all privacy-related enquiries and data subject requests within fifteen (15) calendar days of receipt. We take every privacy concern seriously and are dedicated to maintaining the trust of every Filipino player on our Platform.