Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how q36com ("we," "us," "our," or "the Company") collects, uses, stores, protects, and discloses personal information of users ("you," "your," or "Player") who access or use our online casino platform at https://q36com.cam (the "Website" or "Platform"). We are committed to protecting your privacy and ensuring the security of your personal data in accordance with Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

By registering an account, accessing our Website, or using any of our services, you acknowledge that you have read, understood, and consent to the collection and processing of your personal information as described in this Privacy Policy. If you do not agree with any aspect of this Policy, you must immediately discontinue use of q36com services. This Privacy Policy applies to all personal data collected through our Website, mobile applications, customer service channels, and any other platforms operated by q36com.

q36com operates as a licensed online gaming platform serving Filipino players throughout the Philippines. We recognize the importance of maintaining your trust and confidence, and we are dedicated to responsible data handling practices that respect your privacy rights while enabling us to provide secure, personalized gaming entertainment.

2. Information We Collect

q36com collects various categories of personal information necessary to provide our gaming services, comply with legal obligations, prevent fraud, and enhance your user experience. The information we collect includes but is not limited to:

2.1 Registration and Account Information

• Full legal name as it appears on government-issued identification
• Date of birth to verify age eligibility (21 years or older)
• Residential address including street, barangay, city, province, and postal code
• Email address for account communications and verification
• Mobile phone number for SMS verification and account security
• Username and encrypted password credentials
• Preferred language and communication settings

2.2 Identity Verification Documents

• Government-issued photo identification (Philippine Passport, Driver's License, National ID, PRC ID, Voter's ID, SSS/GSIS ID)
• Proof of address documents (utility bills, bank statements, government correspondence)
• Proof of payment method ownership (bank statements, screenshots of e-wallet accounts)
• Selfie photographs holding identification for enhanced verification

2.3 Financial and Transaction Information

• Payment method details (GCash account, PayMaya account, bank account information)
• Deposit and withdrawal transaction history including amounts, dates, and payment channels
• Betting activity and gaming history including wagers placed, games played, wins, and losses
• Bonus claims, promotional redemptions, and loyalty points accumulation
• Currency preferences and transaction limits

2.4 Technical and Usage Information

• IP address, device identifiers, and unique user identifiers
• Device type, operating system, browser type and version
• Session information including login times, session duration, and logout times
• Gameplay patterns, favorite games, and gaming preferences
• Pages visited, features used, and clickstream data
• Cookies, web beacons, and similar tracking technologies
• Geolocation data to verify you are playing from within permitted jurisdictions

2.5 Communications and Customer Support

• Live chat transcripts and customer service correspondence
• Email communications between you and q36com
• Phone call recordings with customer support (where legally permitted and with notice)
• Survey responses, feedback, and testimonials
• Marketing preferences and communication consent settings

3. How We Use Your Information

q36com processes your personal information for specific, legitimate purposes related to providing online gaming services, maintaining platform security, complying with legal obligations, and improving user experience. We use your information for the following purposes:

3.1 Account Management and Service Provision

• Creating and maintaining your player account
• Authenticating your identity and verifying account access
• Processing deposits, withdrawals, and financial transactions
• Providing access to casino games, sports betting, and other gaming products
• Tracking gameplay, calculating winnings, and maintaining account balances
• Administering bonuses, promotions, and loyalty rewards
• Sending transactional notifications regarding account activity

3.2 Legal Compliance and Regulatory Requirements

• Verifying age to ensure compliance with 21+ gambling restrictions
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by Philippine gaming regulations
• Maintaining records for audit purposes and regulatory inspections
• Reporting suspicious transactions to relevant authorities when legally required
• Responding to court orders, subpoenas, or lawful government requests
• Complying with PAGCOR licensing conditions and gaming regulations

3.3 Security, Fraud Prevention, and Risk Management

• Detecting and preventing fraudulent activity, money laundering, and identity theft
• Identifying duplicate accounts and violations of single-account policies
• Monitoring for bonus abuse, collusion, and unfair gaming practices
• Protecting against unauthorized account access and cyber attacks
• Implementing responsible gaming measures and identifying problem gambling patterns
• Investigating disputes, complaints, and Terms of Service violations

3.4 Customer Service and Communication

• Responding to your inquiries, questions, and support requests
• Providing technical assistance and troubleshooting account issues
• Sending important account notifications and service updates
• Communicating changes to Terms of Service, Privacy Policy, or platform features
• Conducting customer satisfaction surveys to improve service quality

3.5 Marketing and Personalization (With Your Consent)

• Sending promotional offers, bonuses, and special event notifications tailored to Filipino players
• Personalizing game recommendations based on your preferences and play history
• Providing information about new games, features, and platform updates
• Delivering targeted advertising on our platform and through email/SMS (with opt-in consent)
• You may opt out of marketing communications at any time through account settings or unsubscribe links

4. Legal Basis for Processing

Under Philippine data protection law, q36com processes your personal information based on the following legal grounds:

• Consent: You have provided explicit consent for us to collect and process your personal data when registering your account and accepting this Privacy Policy.
• Contract Performance: Processing is necessary to fulfill our contractual obligations under the Terms and Conditions, including providing gaming services and processing transactions.
• Legal Obligation: We are required by law to process certain information for regulatory compliance, AML/KYC requirements, and age verification under Philippine gaming regulations.
• Legitimate Interests: Processing is necessary for our legitimate business interests in fraud prevention, security, risk management, and improving our services, provided these interests do not override your privacy rights.

5. How We Share Your Information

q36com does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients under strictly controlled circumstances:

5.1 Service Providers and Business Partners

• Payment processors (GCash, PayMaya, bank payment gateways) to facilitate deposits and withdrawals
• Game providers and software suppliers who power our casino games and betting platforms
• Identity verification services that conduct KYC checks and document authentication
• Customer support platforms and communication service providers
• Cloud hosting services and IT infrastructure providers
• Marketing and analytics platforms (only with your consent)
• All service providers are bound by strict confidentiality agreements and are prohibited from using your data for any purpose other than providing services to q36com

5.2 Regulatory and Legal Authorities

• PAGCOR and other Philippine gaming regulatory bodies as required by licensing conditions
• National Privacy Commission upon lawful request
• Law enforcement agencies when legally required by court order or criminal investigation
• Anti-Money Laundering Council (AMLC) for suspicious transaction reporting as mandated by law
• Government tax authorities for compliance with Philippine tax obligations

5.3 Corporate Transactions

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity. You will be notified via email and prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

6. Data Security Measures

q36com implements comprehensive technical, physical, and administrative security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All sensitive data transmissions are protected using 256-bit SSL/TLS encryption technology. Passwords are stored using industry-standard hashing algorithms and are never stored in plain text.
• Secure Servers: Personal data is stored on secure servers located in protected data centers with physical access controls, surveillance, and environmental protections.
• Access Controls: Only authorized q36com personnel with legitimate business need can access personal data, and all access is logged and monitored.
• Firewall Protection: Network-level firewalls and intrusion detection systems protect against cyber attacks and unauthorized access attempts.
• Regular Security Audits: Independent third-party security assessments and penetration testing are conducted regularly to identify and address vulnerabilities.
• Employee Training: All staff members handling personal data receive mandatory data protection and security training.
• Incident Response: We maintain an incident response plan to quickly address any data security breaches and notify affected users as required by law.

While we employ industry-leading security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but remain committed to protecting your information using all reasonable and appropriate safeguards.

7. Data Retention

q36com retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal, regulatory, accounting, and reporting requirements. Specific retention periods include:

• Active Accounts: Personal data is retained for the duration of your active account relationship with q36com.
• Closed Accounts: After account closure, personal data is retained for five (5) years to comply with anti-money laundering regulations, resolve disputes, and maintain records for regulatory audits.
• Transaction Records: Financial transaction data is retained for seven (7) years as required by Philippine accounting and tax laws.
• Marketing Data: If you opt out of marketing communications, your email/phone number is retained on a suppression list to ensure we do not contact you again.
• Legal Holds: Data may be retained longer when subject to ongoing legal proceedings, investigations, or regulatory inquiries.

After applicable retention periods expire, personal information is securely deleted or anonymized in accordance with data protection best practices.

8. Your Privacy Rights

Under Philippine data protection law, you have the following rights regarding your personal information:

• Right to Access: You may request copies of the personal data we hold about you and information about how we process it.
• Right to Correction: You may request correction of inaccurate or incomplete personal information through your account settings or by contacting customer support.
• Right to Erasure: You may request deletion of your personal data, subject to legal retention obligations and legitimate business needs.
• Right to Object: You may object to processing of your personal data for marketing purposes or based on legitimate interests.
• Right to Data Portability: You may request a copy of your personal data in a structured, machine-readable format for 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 contact our Data Protection Officer at the contact information provided below. We will respond to your request within thirty (30) days as required by Philippine law.

9. Cookies and Tracking Technologies

q36com uses cookies, web beacons, and similar tracking technologies to enhance your browsing experience, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device that help us remember your preferences and improve functionality.

Types of cookies we use include:

• Essential Cookies: Required for platform operation, security, and account authentication.
• Functional Cookies: Remember your preferences, language settings, and account customizations.
• Analytics Cookies: Help us understand how visitors use our platform to improve performance and user experience.
• Marketing Cookies: Used to deliver relevant advertisements and track campaign effectiveness (only with your consent).

You may control cookie settings through your browser preferences. However, disabling essential cookies may affect platform functionality and your ability to access certain features.

10. International Data Transfers

Your personal information is primarily stored and processed within the Philippines. However, some of our service providers and technology partners may be located outside the Philippines. When transferring data internationally, we ensure appropriate safeguards are in place, including contractual protections and adherence to international data protection standards. Any international transfers comply with Philippine data protection law and ensure your information receives adequate protection equivalent to that provided under Philippine law.

11. Children's Privacy

q36com services are strictly intended for individuals 21 years of age or older. We do not knowingly collect personal information from minors. If we become aware that a user is under 21 years of age, we will immediately suspend the account, prevent further access, and delete all associated personal information. Parents or guardians who believe their child has provided information to q36com should contact us immediately.

12. Changes to This Privacy Policy

q36com reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our practices, services, legal requirements, or technological capabilities. When we make material changes, we will notify you by email (if you have provided an email address) and by posting a prominent notice on our Website at least thirty (30) days before the changes take effect. The "Last Updated" date at the top of this Policy will be revised accordingly. Your continued use of q36com services after changes become effective constitutes acceptance of the updated Privacy Policy.

13. Contact Information and Data Protection Officer

If you have questions, concerns, or complaints about this Privacy Policy or our data handling practices, or if you wish to exercise your privacy rights, please contact our Data Protection Officer:

• 24/7 Live Chat Support: Available on the q36com Website
• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"

We are committed to addressing your privacy concerns promptly and transparently. You may also file a complaint with the Philippine National Privacy Commission if you believe your data protection rights have been violated.