Privacy Policy

1. Introduction

th365 ("we," "us," or "our") operates an online casino and sports betting platform accessible at https://th365.cam (the "Platform"). We are licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR) to provide online gaming services to eligible residents of the Philippines.

This Privacy Policy outlines how th365 collects, processes, stores, and protects personal data from users ("you" or "Player") who register for and use our services. By creating an account on the th365 Platform, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

th365 is committed to full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, as well as PAGCOR's data protection and anti-money laundering guidelines. We treat your privacy as a fundamental right and implement industry-standard security measures to protect your personal information at all times.

2. Information We Collect

To provide you with a secure and compliant gaming experience, th365 collects various categories of personal information during account registration, verification, and ongoing use of the Platform. The information we collect includes:

2.1 Personal Identification Information

• Full Legal Name as it appears on your government-issued identification document
• Date of Birth to verify that you meet the legal age requirement of 21 years or above
• Residential Address including street, barangay, city/municipality, province, and postal code
• Email Address for account notifications, transaction confirmations, and marketing communications
• Mobile Phone Number for SMS verification, two-factor authentication, and account recovery
• Government-Issued ID such as Philippine Passport, Driver's License, PhilSys ID, or other PAGCOR-acceptable identification documents
• Selfie or Photo Verification to match your appearance with the identification document submitted

2.2 Financial and Transaction Information

• Payment Method Details including GCash mobile number, PayMaya account, bank account numbers (BPI, BDO, Metrobank, etc.), or credit/debit card information
• Transaction History including deposits, withdrawals, wagers, winnings, bonuses claimed, and account balance adjustments
• Source of Funds Information as required by anti-money laundering regulations under the Anti-Money Laundering Act (AMLA) and PAGCOR guidelines
• Tax Identification Number (TIN) where applicable under Philippine tax law for reportable gaming winnings

2.3 Technical and Usage Data

• IP Address and geolocation data to verify that you are accessing the Platform from within the Philippines
• Device Information including device type, operating system, browser type, screen resolution, and unique device identifiers
• Cookies and Tracking Technologies to maintain session state, remember preferences, and analyze user behavior on the Platform
• Game Activity Logs including games played, bet amounts, outcomes, timestamps, and session duration
• Platform Interaction Data such as pages visited, features used, clicks, navigation paths, and customer support interactions

2.4 Communication Records

• Customer Support Communications including live chat transcripts, email correspondence, and phone call records (where consent is provided)
• Marketing Preferences indicating whether you have opted in to receive promotional emails, SMS messages, or push notifications

3. How We Use Your Information

th365 processes your personal data for specific, legitimate purposes related to the provision of online gaming services. We use the information we collect to:

3.1 Account Management and Service Delivery

• Create, maintain, and manage your th365 account and user profile
• Verify your identity and age to ensure compliance with the 21+ legal requirement
• Process deposits and withdrawals via GCash, PayMaya, bank transfers, and other payment methods
• Enable you to play casino games, place sports bets, and participate in promotional offers
• Maintain accurate transaction records and account balance information
• Provide customer support and respond to inquiries, complaints, and feedback

3.2 Regulatory Compliance and Legal Obligations

• Comply with PAGCOR licensing requirements and ongoing regulatory oversight
• Fulfill anti-money laundering (AML) and counter-financing of terrorism (CFT) obligations under Philippine law
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC) where required
• Enforce responsible gaming measures including self-exclusion, deposit limits, and session time limits
• Respond to lawful requests from government authorities, courts, and regulatory bodies
• Comply with tax reporting obligations under the National Internal Revenue Code where applicable

3.3 Security and Fraud Prevention

• Detect, prevent, and investigate fraudulent activity, account abuse, bonus abuse, collusion, and money laundering
• Monitor gameplay for irregular patterns that may indicate cheating, match-fixing, or insider betting
• Protect the Platform from cyberattacks, hacking attempts, and unauthorized access
• Verify the legitimacy of withdrawals and prevent unauthorized fund transfers
• Block access from restricted jurisdictions or individuals on self-exclusion lists

3.4 Platform Improvement and Analytics

• Analyze user behavior to improve game offerings, user interface design, and overall user experience
• Conduct statistical analysis of game performance, payout percentages, and jackpot trends
• Test new features, payment methods, and promotional campaigns with select user groups
• Optimize server performance, loading times, and mobile compatibility

3.5 Marketing and Communications

• Send promotional emails, SMS messages, and push notifications about bonuses, tournaments, and new game releases (with your consent)
• Personalize marketing offers based on your gameplay preferences, VIP tier, and transaction history
• Notify you of changes to the Platform, new policies, scheduled maintenance, or important account updates
• Conduct customer satisfaction surveys and request feedback on your gaming experience

You may withdraw consent for marketing communications at any time by adjusting your account preferences or contacting customer support. Note that transactional and regulatory communications (e.g., withdrawal confirmations, KYC requests) cannot be opted out of as they are necessary for service delivery.

4. Data Sharing and Disclosure

th365 does not sell, rent, or trade your personal information to third parties for their independent marketing purposes. However, we may share your data with trusted third-party service providers and entities under the following circumstances:

4.1 Third-Party Service Providers

We engage reputable third-party companies to perform specific functions on our behalf, including:

• Payment Processors: GCash, PayMaya, InstaPay, PESONet, Visa, Mastercard, and banking partners to process deposits and withdrawals
• Identity Verification Services: KYC and AML compliance providers that verify identity documents and screen against sanctions lists
• Cloud Hosting Providers: Secure data centers and cloud infrastructure providers that store user data and Platform backups
• Game Providers: JILI Games, Pragmatic Play, PG Soft, Evolution Gaming, and other licensed game studios that deliver casino content
• Customer Support Platforms: Live chat, ticketing, and email management systems used by our support team
• Analytics and Marketing Tools: Platforms that help us understand user behavior, measure campaign performance, and deliver targeted advertisements

All third-party service providers are contractually obligated to handle your data securely, use it only for the specified purposes, and comply with applicable data protection laws.

4.2 Regulatory and Legal Disclosure

th365 may disclose your personal information to:

• PAGCOR: For regulatory audits, compliance verification, and investigations into suspected illegal activity
• Anti-Money Laundering Council (AMLC): To report suspicious transactions as required under AMLA
• Law Enforcement Agencies: When required by court order, subpoena, or other lawful requests from Philippine authorities
• Tax Authorities: Bureau of Internal Revenue (BIR) for tax reporting purposes where winnings exceed reportable thresholds
• Legal Counsel: To defend th365's legal rights or interests in disputes, litigation, or regulatory proceedings

4.3 Business Transfers

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 or prominent notice on the Platform of any such change in ownership and any choices you may have regarding your personal information.

5. Data Security Measures

th365 implements comprehensive technical and organizational security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. Our security framework includes:

5.1 Technical Security Controls

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption protocols
• Data Encryption at Rest: Sensitive information stored in our databases is encrypted using AES-256 encryption standards
• Firewall Protection: Multi-layered firewall systems monitor and block unauthorized access attempts
• Intrusion Detection Systems (IDS): Real-time monitoring tools detect and respond to potential security threats
• Two-Factor Authentication (2FA): Optional 2FA via SMS or authenticator app adds an extra layer of account protection
• Secure Payment Gateways: PCI DSS-compliant payment processors handle all financial transactions

5.2 Organizational Security Measures

• Access Controls: Employee access to personal data is restricted on a need-to-know basis and governed by role-based permissions
• Confidentiality Agreements: All employees and contractors sign non-disclosure agreements and undergo data protection training
• Regular Security Audits: Independent third-party security firms conduct periodic audits and penetration testing
• Incident Response Plan: Documented procedures for identifying, containing, and reporting data breaches
• Data Minimization: We collect only the information necessary for identified purposes and delete data when no longer required

While we employ industry-standard security practices, no method of transmission over the Internet or electronic storage is 100% secure. You also play a role in protecting your account by using a strong password, not sharing login credentials, and logging out after each session on shared devices.

6. Your Privacy Rights Under Philippine Law

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal information held by th365:

6.1 Right to Be Informed

You have the right to know whether th365 holds personal data about you, the purpose of processing, and the categories of data being processed. This Privacy Policy serves as our primary disclosure document.

6.2 Right to Access

You may request a copy of the personal information th365 holds about you. To exercise this right, submit a written request through our customer support channels. We will provide the requested information in a commonly used electronic format within thirty (30) days.

6.3 Right to Rectification

If you believe any personal information we hold about you is inaccurate, incomplete, or outdated, you may request correction. You can update certain information directly through your account settings, or contact support for assistance with identity verification fields.

6.4 Right to Erasure

You may request deletion of your personal data under specific circumstances, such as when the data is no longer necessary for the purposes collected, or you withdraw consent. However, this right is subject to legal limitations — we may retain data required for regulatory compliance, dispute resolution, or fraud preventio n under legal obligations.

6.5 Right to Data Portability

You may request that th365 provide your personal data in a structured, commonly used, and machine-readable format, or transfer it directly to another controller where technically feasible.

6.6 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where your individual rights and freedoms override those interests.

6.7 Right to File a Complaint

If you believe th365 has violated your data privacy rights, you may file a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph. We encourage you to contact us first so we can attempt to resolve the matter directly before escalating to the NPC.

To exercise any of the above rights, contact our Data Protection Officer (DPO) by email at [email protected] with the subject line "Data Privacy Request" and include your registered email address and a brief description of your request.

7. Cookies and Tracking Technologies

th365 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and analyze usage patterns. Here is how we use each category:

7.1 Essential Cookies

These cookies are strictly necessary for the Platform to function correctly. They enable core features such as session authentication, security tokens, shopping cart state, and load balancing. Essential cookies cannot be disabled without breaking the Platform's functionality.

7.2 Functional Cookies

Functional cookies remember your preferences and settings, such as your preferred language, display resolution, and game sound settings, so you do not need to reconfigure them on every visit.

7.3 Analytics Cookies

We use analytics cookies to understand how players interact with the Platform — which pages are visited most, how long sessions last, where users drop off, and how different features are used. This data is aggregated and anonymized where possible and used solely to improve the Platform.

7.4 Marketing Cookies

With your consent, marketing cookies allow us to deliver personalized promotional content and measure the effectiveness of advertising campaigns. You may withdraw consent for marketing cookies at any time via your browser settings or the th365 Cookie Preferences panel.

Most browsers allow you to manage cookie preferences through their settings. Note that disabling certain cookies may affect the functionality of the Platform. For full details on the cookies we use, visit the Cookie Preferences section in your account settings.

8. Data Retention

th365 retains personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce agreements. Specific retention periods are as follows:

• Account Information: Retained for the duration of your account plus a minimum of five (5) years after account closure, as required by PAGCOR and AMLC regulations
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in line with anti-money laundering recordkeeping requirements under Philippine law
• KYC and Identity Documents: Retained for a minimum of five (5) years after your last transaction or account closure, whichever is later
• Customer Support Communications: Retained for three (3) years from the date of each interaction
• Marketing Preferences and Consent Records: Retained for the duration of your account and two (2) years after account closure
• Cookies and Session Data: Retained according to each cookie's expiry period as described in our Cookie Policy; session cookies expire when you close your browser

After applicable retention periods expire, personal data is securely deleted or anonymized in a manner that prevents re-identification.

9. Changes to This Privacy Policy

th365 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or PAGCOR regulatory requirements. When material changes are made, we will:

• Post the updated Privacy Policy on this page with a revised "Last Updated" date
• Send an email notification to your registered email address summarizing the key changes
• Display a prominent notice on the Platform for a reasonable period following the update

Your continued use of the th365 Platform after any changes to this Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you may close your account and request deletion of your data subject to applicable retention requirements.

10. Contact Us and Data Protection Officer

If you have questions, concerns, or requests related to this Privacy Policy or the way th365 handles your personal data, please contact our Data Protection Officer:

• Email: [email protected] (Subject: "Privacy / Data Protection Enquiry")
• Live Chat: Available 24/7 through the th365 Platform
• Response Time: We aim to respond to all data privacy requests within 5–10 business days

For complaints that remain unresolved after contacting us, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines.