🔒 q36 Privacy Policy

1. Introduction

Welcome to q36. This Privacy Policy describes how q36 ("we," "us," or "our") collects, uses, discloses, and safeguards the personal information of users ("you" or "Player") who access or use the q36 online casino platform, including all games, features, and services available at q36 (the "Platform").

q36 is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

By registering for a q36 account or using the Platform, you acknowledge that you have read, understood, and agree to the collection and use of your personal information as described in this Privacy Policy. This Policy should be read together with our Terms & Conditions.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, q36 is the personal information controller responsible for your personal data collected through the Platform. Our designated Data Protection Officer (DPO) can be contacted at: [email protected]

If you have any questions, concerns, or requests relating to your personal data, please contact our DPO directly. We are committed to responding to all privacy-related inquiries within five (5) business days.

3. Personal Data We Collect

q36 collects the following categories of personal data from players:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license).
• Contact Data: Email address, Philippine mobile number, and residential address (city/municipality, province).
• Account Data: Username, encrypted password, account preferences, and communication preferences.
• Financial Data: GCash number, PayMaya account details, bank account information (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records.
• Gaming Data: Game history, bet amounts, win/loss records, session duration, and responsible gaming tool usage.
• Technical Data: IP address, device type, browser type and version, operating system, and platform access logs.
• Usage Data: Information about how you navigate and interact with the q36 Platform, including pages visited, features used, and time spent on the Platform.
• Communications Data: Records of your communications with q36 customer support, including live chat transcripts and support ticket history.

4. How We Collect Your Data

q36 collects personal data through the following means:

• Direct interactions: When you register a q36 account, complete identity verification (KYC), make deposits or withdrawals, contact customer support, or participate in promotions.
• Automated technologies: When you access the q36 Platform, we automatically collect Technical Data and Usage Data through cookies, server logs, and similar tracking technologies.
• Third-party sources: We may receive personal data about you from identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud prevention services, and regulatory authorities where permitted by law.

5. How We Use Your Personal Data

q36 uses your personal data for the following purposes:

• To create and manage your q36 account and verify your identity in compliance with Know Your Customer (KYC) requirements.
• To process deposits, withdrawals, and other financial transactions on the Platform.
• To provide, maintain, and improve the q36 gaming experience, including personalization of game recommendations.
• To detect, prevent, and investigate fraud, money laundering, and other illegal activities.
• To comply with our legal and regulatory obligations under Philippine law, including PAGCOR requirements and the Anti-Money Laundering Act (AMLA).
• To communicate with you about your account, transactions, promotions, and Platform updates.
• To enforce our Terms & Conditions and other applicable policies.
• To support responsible gaming initiatives, including monitoring for signs of problem gambling and administering self-exclusion requests.
• To analyze Platform usage and improve our services, security, and user experience.

6. Legal Basis for Processing

q36 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform our contract with you (i.e., to provide the q36 service as described in our Terms & Conditions).
• Legal obligation: Processing is necessary to comply with our legal obligations under Philippine law, including KYC, AMLA, and PAGCOR regulatory requirements.
• Legitimate interests: Processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided these interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent to process personal data (e.g., for marketing communications), you may withdraw your consent at any time by contacting us or updating your account preferences.

7. Data Sharing & Disclosure

q36 does not sell, rent, or trade your personal data to third parties for marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers to process your financial transactions.
• Identity verification providers: Third-party KYC and age verification service providers to verify your identity and age.
• Fraud prevention and security providers: Service providers that assist q36 in detecting and preventing fraud, money laundering, and other illegal activities.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where required by law or court order.
• IT and platform service providers: Cloud hosting, data storage, and platform infrastructure providers who process data on our behalf under strict data processing agreements.

All third parties with whom q36 shares personal data are required to handle your data securely and in accordance with applicable Philippine data protection law.

8. Data Retention

q36 retains your personal data for as long as your q36 account is active and for a period thereafter as required by applicable law. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Technical and usage data is retained for up to two (2) years from collection.
• Customer support communications are retained for up to three (3) years from the date of the communication.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

9. Data Security

q36 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the q36 Platform.
• Encryption of sensitive data (including financial data and passwords) at rest using industry-standard encryption algorithms.
• Access controls limiting access to personal data to authorized q36 personnel on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the q36 Platform.
• Incident response procedures to detect, report, and address personal data breaches in accordance with NPC notification requirements.

While q36 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your q36 account credentials.

10. Cookies & Tracking Technologies

q36 uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device when you visit q36. We use the following types of cookies:

• Essential cookies: Necessary for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Analytics cookies: Help us understand how players use the q36 Platform so we can improve performance and user experience.
• Preference cookies: Remember your settings and preferences (e.g., language, game preferences) to personalize your q36 experience.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the q36 Platform.

11. 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 q36:

• Right to be informed: The right to be informed about how your personal data is collected and processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data q36 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days.

12. Minors

The q36 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. q36 does not knowingly collect personal data from individuals under the age of 21.

If q36 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on q36, please contact us immediately at support@q 36.one.

13. Changes to This Privacy Policy

q36 reserves the right to update or amend this Privacy Policy at any time. When we make material changes, we will notify registered players via their registered email address or mobile number, and update the "Last Updated" date at the top of this page.

Your continued use of the q36 Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how q36 protects your personal data.

If you do not agree to the revised Privacy Policy, you must cease using the Platform and may request account closure in accordance with our Terms & Conditions.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by q36, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 via the q36 Platform
• Response Time: Within 5 business days for privacy-related inquiries

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have not been adequately addressed by q36.