pn365 Privacy Policy

1. Data Controller Identity

pn365 ("we," "us," "our," or the "Company") is the data controller responsible for the personal information collected through the pn365 online gaming platform at pn365.cam. As data controller, pn365 determines the purposes and means of processing your personal data in connection with the registration, operation, and maintenance of your player account and your use of all pn365 services.

pn365 operates in compliance with Philippine law, including the Data Privacy Act of 2012 (RA 10173), the implementing rules issued by the National Privacy Commission (NPC), and all PAGCOR regulatory requirements concerning player data management.

Questions or concerns regarding this Privacy Policy or the processing of your personal data may be directed to our Data Protection Officer (DPO). Contact details are provided in Section 13 of this document.

2. Categories of Personal Data We Collect

The personal data pn365 collects falls into the following categories, depending on how you interact with our platform:

2.1 Identity and Registration Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify the 21+ age requirement mandated by PAGCOR regulations);
• Gender;
• Nationality and country of residence;
• Valid Philippine government-issued ID number (e.g., PhilSys ID, Passport, Driver's License, UMID);
• Residential address, including barangay, city or municipality, province, and ZIP code.

2.2 Contact Data

• Primary email address used for account registration and communications;
• Philippine mobile number (used for account notifications, OTP verification, and two-factor authentication);
• Alternative contact information where voluntarily provided.

2.3 Financial and Transaction Data

• GCash mobile number or registered Maya account details;
• Bank account information (account name, account number, bank name) for bank transfer transactions;
• Deposit and withdrawal transaction history, including amounts, timestamps, reference numbers, and payment method used;
• Wagering history, game transaction logs, bonus claims, and account balance records.

2.4 Technical and Usage Data

• IP address and approximate geolocation derived from network data;
• Device type, operating system, browser type and version;
• Session duration, pages visited, games played, features accessed, and click-path data;
• Login timestamps and logout records;
• Error logs and crash reports generated during platform use.

2.5 Communication Data

• Records of live chat conversations with pn365 customer support;
• Email correspondence submitted to pn365 support or compliance teams;
• Feedback, survey responses, and complaint submissions.

2.6 Verification and Compliance Data

• Copies of government-issued identification documents submitted for KYC (Know Your Customer) verification;
• Proof of address documents (e.g., utility bills, bank statements);
• Source of funds documentation where required for large transactions;
• Self-exclusion declarations and responsible gaming limit settings.

3. How We Collect Personal Data

pn365 collects personal data through the following methods:

• Direct Submission: Information you provide when registering for a pn365 account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or participating in promotions;
• Automated Collection: Technical data collected automatically when you visit pn365.cam or use the pn365 platform, including through cookies, pixel tags, web beacons, server logs, and similar tracking technologies (described in Section 9);
• Third-Party Sources: Identity verification data received from third-party KYC service providers; fraud risk scores from anti-fraud vendors; payment confirmation data from payment processors including GCash, Maya, and banking partners;
• Regulatory Sources: Exclusion list data received from PAGCOR or other competent gaming regulators to enforce self-exclusion and problem gambling protections.

4. Purposes of Personal Data Processing

pn365 processes your personal data for the following purposes:

5. Legal Basis for Processing

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

• Contract Performance: Processing necessary for the performance of the contract between you and pn365 — i.e., your player account agreement and the Terms and Conditions you accepted at registration. This covers account management, deposits, withdrawals, game access, and customer support;
• Legal Obligation: Processing required for compliance with Philippine legal obligations, including KYC and AML requirements under PAGCOR regulations and the Anti-Money Laundering Act;
• Legitimate Interests: Processing necessary for pn365's legitimate business interests, including fraud detection, platform security, abuse prevention, and service improvement — where such interests are not overridden by your rights and freedoms;
• Consent: Processing based on your explicit consent, particularly for direct marketing communications and non-essential cookie placement. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Disclosure and Sharing of Personal Data

pn365 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Personal data is shared only in the following circumstances and only to the minimum extent necessary:

6.1 Service Providers and Data Processors

pn365 engages carefully selected third-party service providers who process personal data on our behalf under binding data processing agreements. These include:

• Payment processors and e-wallet partners (GCash, Maya, BPI, BDO, Metrobank, and others) for transaction processing;
• Identity verification and KYC service providers;
• Anti-fraud and risk management vendors;
• Cloud hosting and data storage providers;
• Customer support platform providers;
• Analytics service providers used to improve platform performance.

All service providers are contractually obligated to process your data only for the specified purposes, to maintain appropriate security standards, and to comply with the Data Privacy Act.

6.2 Regulatory and Legal Disclosures

pn365 may disclose personal data to the following authorities when legally required or permitted:

• PAGCOR, in fulfillment of licensing and regulatory reporting obligations;
• The Anti-Money Laundering Council (AMLC) as required under RA 9160;
• The National Privacy Commission (NPC) in response to data privacy complaints or investigations;
• Philippine law enforcement agencies in response to lawfully issued court orders, subpoenas, or warrants;
• Other gaming regulators or exclusion registries for responsible gaming enforcement purposes.

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of all or substantially all of pn365's assets, personal data held by pn365 may be transferred to the acquiring entity, subject to at least the same data protection commitments set out in this Privacy Policy. You will be notified of any such transfer by a prominent notice on the pn365 website or by direct communication to your registered email address.

7. Data Retention

pn365 retains personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, and in accordance with applicable legal and regulatory requirements. The following general retention periods apply:

• Active Account Data: Retained for the duration of your active pn365 account plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML regulations;
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years following the transaction date, as required by the Anti-Money Laundering Act;
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following account closure or the last transaction date, whichever is later;
• Support Communications: Customer support records are retained for a minimum of three (3) years from the date of the interaction;
• Marketing Data: Data used for marketing purposes is retained until you withdraw your consent or for a maximum of three (3) years from your last meaningful interaction with pn365 marketing content, whichever occurs first.

Upon expiry of the applicable retention period, personal data is securely deleted, anonymized, or pseudonymized in a manner that prevents re-identification.

8. Data Security Measures

pn365 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and pn365 servers is protected using TLS (Transport Layer Security) encryption. Sensitive data at rest, including payment credentials and identity documents, is stored using industry-standard encryption protocols;
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. pn365 employees and contractors with data access undergo background checks and are bound by confidentiality obligations;
• Two-Factor Authentication: pn365 supports two-factor authentication (2FA) for player accounts and mandates strong authentication controls for all administrative access to production systems;
• Infrastructure Security: pn365 systems are hosted in secure, access-controlled data centers with redundant security controls, intrusion detection, and regular vulnerability assessments;
• Incident Response: pn365 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights, pn365 will notify the National Privacy Commission within seventy-two (72) hours and will notify affected players without undue delay.

While pn365 employs robust security measures, no internet-based system can guarantee absolute security. You are responsible for maintaining the security of your own pn365 login credentials and for using secure networks when accessing the platform.

9. Cookies and Tracking Technologies

pn365 uses cookies and similar tracking technologies on its website to enhance your browsing experience, maintain session continuity, and gather analytical insights. The categories of cookies we use are:

• Strictly Necessary Cookies: Essential for the operation of the pn365 platform, including session management, authentication state, security tokens, and load balancing. These cookies cannot be disabled without impeding core platform functionality;
• Functional Cookies: Used to remember your preferences such as language settings, display preferences, and last-visited game categories. Disabling these cookies may affect the personalization of your experience;
• Analytical Cookies: Used to collect aggregated statistical data about how players navigate and use the pn365 platform, enabling us to improve performance, identify technical issues, and optimize the user experience;
• Marketing Cookies: Used to track your interactions with pn365 promotional content and to deliver personalized offers. These are used only with your explicit consent.

You may manage your cookie preferences through the cookie consent tool available on pn365.cam, or through your browser settings. Please note that disabling strictly necessary cookies will prevent you from using certain features of the pn365 platform.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pn365:

• Right to Be Informed: The right to be informed that your personal data is being collected and processed, including the purposes and legal basis for processing — which this Privacy Policy fulfills;
• Right of Access: The right to request a copy of the personal data pn365 holds about you, along with information about how it is processed. You may submit an access request through pn365 customer support;
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you. Certain corrections (such as name or date of birth changes) may require supporting documentation;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn your consent (where consent was the legal basis), or where processing was unlawful. This right is subject to overriding legal retention obligations, particularly AML and PAGCOR record-keeping requirements;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format for transfer to another controller, where technically feasible and applicable;
• Right to Object: The right to object to processing based on pn365's legitimate interests, including direct marketing. Where you object to marketing, pn365 will cease marketing communications immediately;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe pn365 has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, contact our Data Protection Officer using the details in Section 13. pn365 will respond to all verified privacy rights requests within fifteen (15) business days. Complex requests may require up to thirty (30) business days, in which case you will be notified of the extended timeline.

11. Processing of Data Relating to Minors

pn365 does not knowingly collect or process personal data from individuals under the age of 21. Our platform is intended exclusively for adults who meet the legal age requirement for online gaming in the Philippines as prescribed by PAGCOR.

If pn365 discovers that personal data has been inadvertently collected from an individual who does not meet the 21+ age requirement, we will immediately close the relevant account, void all transactions, and securely delete the associated personal data. Parents or guardians who believe their child may have created a pn365 account should contact our Data Protection Officer immediately using the contact details in Section 13.

12. Changes to This Privacy Policy

pn365 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or regulatory guidance. Material changes will be communicated to you through one or more of the following channels: a prominent notice on pn365.cam, an in-platform notification, or an email to your registered address.

The "Last Updated" date at the top of this document indicates when the most recent revision was made. Your continued use of pn365 services following any modification constitutes your acceptance of the revised Privacy Policy. If you do not agree to the updated terms, you should cease using pn365 services and may request account closure.

13. Contact the Data Protection Officer

For all privacy-related inquiries, requests to exercise your data rights, concerns about how pn365 handles your personal data, or to report a potential data breach, please contact our Data Protection Officer:

• Live Chat: Available 24/7 through the pn365 platform (fastest response for urgent matters)
• Email: [email protected] (plain text — not a clickable link)
• Expected Response: Acknowledgement within 24 hours; substantive response within 15 business days

If you are not satisfied with pn365's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which maintains a formal complaint mechanism for data privacy violations involving Philippine-based data controllers.