Privacy Policy

1. Who We Are

This Privacy Policy is issued by q36com ("q36com," "we," "us," or "our"), the operator of the online gaming platform accessible at https://q36com.app. q36com is headquartered in Makati City, Metro Manila, Philippines, and operates as a data controller in respect of the personal data of its registered players and website visitors.

This Privacy Policy applies to all personal data collected through the q36com website, mobile applications, customer support channels, and any other touchpoints through which you interact with q36com. It should be read alongside our Terms & Conditions and Responsible Gaming Policy.

If you have questions about this Privacy Policy or how q36com handles your personal data, you can reach our Data Protection Officer at [email protected].

2. Personal Data We Collect

q36com collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Identity & Contact Data

Full legal name as it appears on your government-issued ID;
Date of birth (to verify you are 21 years of age or older);
Nationality and country of residence;
Email address and mobile phone number;
Residential address, including barangay, city, and province.

2.2 Identity Verification (KYC) Data

Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, UMID, PhilSys National ID, driver's license, voter's ID);
Proof of address documents (e.g., utility bills, bank statements);
Selfie or liveness check images used for biometric verification where required.

2.3 Financial Data

Payment method details (e.g., GCash mobile number, PayMaya account, BPI, BDO, or Metrobank account details);
Transaction history, including deposits, withdrawals, and wager records;
Source of funds information where required by anti-money laundering regulations.

2.4 Technical & Usage Data

IP address and approximate geolocation;
Device type, operating system, and browser information;
Session logs, login timestamps, and platform activity records;
Game history, betting patterns, and session duration data.

2.5 Communications Data

Records of your communications with q36com customer support via live chat or email;
Feedback, survey responses, and promotional opt-in preferences.

3. How We Collect Your Data

q36com 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 participate in a promotion;
Automatically — through cookies, web beacons, and server logs when you browse or use the q36com platform;
From third parties — including KYC verification providers, payment processors, fraud detection services, and, where permitted by law, credit reference agencies or public databases.

4. How We Use Your Personal Data

q36com uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Identity, contact, and KYC data
Age and identity verification (21+ compliance)	Date of birth, KYC documents
Processing deposits and withdrawals	Financial and identity data
Fraud prevention and security monitoring	Technical, financial, and identity data
Anti-money laundering compliance	Financial and identity data
Customer support and dispute resolution	Communications and account data
Responsible gaming monitoring	Usage and gaming activity data
Platform improvement and analytics	Technical and usage data (anonymized where possible)
Marketing communications (with consent)	Contact and preference data
Legal and regulatory compliance	All categories as required

5. Legal Basis for Processing

Under Republic Act No. 10173 (Data Privacy Act of 2012), q36com processes your personal data on the following legal bases:

Contractual necessity — processing required to perform our contract with you, including account management, payment processing, and game provision;
Legal obligation — processing required to comply with applicable Philippine laws, including anti-money laundering regulations, tax obligations, and regulatory reporting requirements;
Legitimate interests — processing for fraud prevention, platform security, and responsible gaming monitoring, where our interests do not override your fundamental rights;
Consent — processing for marketing communications and certain cookie-based tracking, where you have provided explicit, informed consent that you may withdraw at any time.

6. Data Sharing & Disclosure

q36com does not sell your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

KYC and identity verification providers — to verify your identity and age in compliance with Philippine KYC regulations;
Payment processors — including GCash, PayMaya, BPI, BDO, and Metrobank, to facilitate deposits and withdrawals;
Fraud prevention and security services — to detect and prevent unauthorized access, money laundering, and other illegal activity;
IT infrastructure and hosting providers — who process data on our behalf under strict data processing agreements;
Regulatory and law enforcement authorities — where required by Philippine law, court order, or lawful request from a competent authority, including the Anti-Money Laundering Council (AMLC) and the National Privacy Commission (NPC);
Professional advisers — including lawyers, auditors, and accountants, where necessary for the conduct of our business.

All third-party service providers who process personal data on behalf of q36com are required to implement appropriate technical and organizational security measures and to process data only in accordance with q36com's documented instructions.

7. Cookies & Tracking Technologies

q36com uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and deliver relevant content. The types of cookies we use include:

Strictly necessary cookies — essential for the platform to function, including session management and security tokens. These cannot be disabled.
Functional cookies — used to remember your preferences such as language settings and display options.
Analytics cookies — used to understand how players interact with the platform so we can improve the user experience. Data collected is aggregated and anonymized where possible.
Marketing cookies — used to deliver relevant promotional content. These are only set with your explicit consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the q36com platform.

8. Data Retention

q36com 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. Our standard retention periods are as follows:

Account and KYC data — retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering regulations;
Transaction records — retained for a minimum of five (5) years from the date of the transaction;
Customer support communications — retained for three (3) years from the date of the interaction;
Marketing preferences — retained until you withdraw your consent or close your account;
Technical and usage logs — retained for up to twelve (12) months, after which they are anonymized or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized in accordance with q36com's data disposal procedures.

9. Your Data Subject Rights

As a data subject under Republic Act No. 10173, you have the following rights in respect of your personal data held by q36com:

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Right to Access

Request a copy of the personal data q36com holds about you and information about how it is being processed.

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Right to Rectification

Request correction of inaccurate or incomplete personal data held about you.

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Right to Erasure

Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.

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Right to Object

Object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.

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Right to Data Portability

Receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.

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Right to be Indemnified

Claim compensation for damages sustained due to inaccurate, incomplete, outdated, or unlawfully obtained personal data, as provided under RA 10173.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. q36com will respond to all verified requests within fifteen (15) business days. We may require proof of identity before processing your request.

If you believe q36com has not handled your personal data in accordance with RA 10173, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

10. Data Security

q36com implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

TLS 1.2 / 1.3 encryption for all data in transit between your device and q36com servers;
AES-256 encryption for sensitive data stored at rest;
Multi-factor authentication requirements for account access and administrative systems;
Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
Regular penetration testing and vulnerability assessments conducted by independent security firms;
24/7 security monitoring and intrusion detection systems;
Documented incident response procedures in compliance with NPC breach notification requirements.

While q36com takes all reasonable steps to protect your data, no system is completely immune to security risks. You are responsible for keeping your account credentials confidential. If you suspect unauthorized access to your account, contact us immediately at [email protected].

11. Children's Privacy

q36com is strictly an adult platform. In accordance with Philippine regulations governing casino-style online gaming, you must be at least 21 years of age to register and use q36com. We do not knowingly collect personal data from individuals under the age of 21.

If q36com becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data, and report the matter to the appropriate authorities where required. If you believe a minor has registered on q36com, please notify us immediately at [email protected].

12. Cross-Border Data Transfers

q36com primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed by service providers located outside the Philippines — for example, cloud infrastructure providers or international KYC verification services.

Where such transfers occur, q36com ensures that appropriate safeguards are in place in accordance with the requirements of RA 10173 and the implementing rules of the National Privacy Commission. This may include contractual clauses requiring the recipient to apply data protection standards equivalent to those applicable in the Philippines.

13. Updates to This Privacy Policy

q36com reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform features. When material changes are made, q36com will notify registered players via email to their registered address and/or via a prominent notice on the platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically. Your continued use of the q36com platform following any update constitutes your acceptance of the revised Privacy Policy.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or q36com's data processing practices, please contact our Data Protection Officer:

Email: [email protected]
Live Chat: Available 24/7 via the q36com platform
Postal Address: Data Protection Officer, q36com, Makati City, Metro Manila, Philippines

q36com aims to acknowledge all privacy-related enquiries within two (2) business days and to resolve them within fifteen (15) business days. For unresolved complaints, you may escalate to the National Privacy Commission of the Philippines.

Our Privacy Commitments