1 Introduction
73216pnl ("we," "us," or "our") operates the online gaming platform accessible at https://73216pnl.org (the "Platform"). This Privacy Policy describes how 73216pnl collects, uses, stores, shares, and protects the personal information of players and visitors who access or use the Platform.
This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. By registering an account or using the 73216pnl Platform, you consent to the collection and processing of your personal data as described in this Privacy Policy.
If you do not agree with any part of this Privacy Policy, please discontinue use of the 73216pnl Platform immediately. Continued use of the Platform constitutes your acceptance of this policy in full.
2 Personal Data We Collect
73216pnl collects the following categories of personal data from players and Platform visitors:
Identity and Contact Data:
- Full legal name as it appears on a government-issued identification document
- Date of birth (for age verification purposes — 73216pnl requires players to be 21 years of age or older)
- Email address and mobile phone number
- Residential address, city, and province (e.g., Manila, Cebu, Davao, Quezon City, Makati)
- Government-issued identification document number (e.g., Philippine passport, driver's license, SSS/GSIS ID)
Financial Data:
- GCash account number or registered mobile number
- PayMaya account details
- Bank account details for BPI, BDO, or Metrobank transactions
- Transaction history, including deposit and withdrawal records in Philippine Peso (₱)
Technical and Usage Data:
- IP address and approximate geographic location
- Device type, operating system, and browser information
- Session duration, pages visited, and game activity logs
- Login timestamps and account activity records
3 How We Collect Your Data
73216pnl collects personal data through the following means:
- Direct collection: Information you provide when registering your 73216pnl account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
- Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
- Third-party sources: Identity verification data from document verification service providers, fraud prevention data from anti-money laundering screening services, and payment data from GCash, PayMaya, and banking partners.
4 How We Use Your Personal Data
73216pnl processes your personal data for the following purposes:
- To create, verify, and manage your 73216pnl player account
- To process deposits and withdrawals in Philippine Peso via your chosen payment method
- To verify
your age and identity in compliance with Philippine gambling regulations requiring players to be 21 years of age or older
- To detect and prevent fraud, money laundering, and other prohibited activities on the Platform
- To provide customer support and respond to your inquiries
- To send you transactional communications, including deposit confirmations, withdrawal notifications, and account security alerts
- To send promotional communications about 73216pnl bonuses and offers, where you have consented to receive such communications
- To comply with applicable Philippine laws and regulations, including anti-money laundering obligations and reporting requirements
- To analyze Platform usage and improve the 73216pnl gaming experience
- To enforce our Terms & Conditions and other applicable policies
5 Legal Basis for Processing
73216pnl processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:
- Contractual necessity: Processing required to fulfill our obligations to you under the 73216pnl Terms & Conditions, including account management, payment processing, and game delivery.
- Legal obligation: Processing required to comply with applicable Philippine laws, including age verification, anti-money laundering obligations, and regulatory reporting.
- Legitimate interests: Processing necessary for fraud prevention, platform security, and improving the 73216pnl gaming experience, where such interests are not overridden by your rights.
- Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
6 Data Sharing and Disclosure
73216pnl does not sell, rent, or trade your personal data to third parties for their own 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 Privacy Policy:
- Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions.
- Identity verification providers: Third-party KYC (Know Your Customer) and document verification services used to confirm your identity and age.
- Fraud prevention and AML services: Providers that assist 73216pnl in detecting and preventing fraudulent activity and money laundering.
- Technology and hosting providers: Cloud infrastructure and software service providers who process data on our behalf under strict data processing agreements.
- Regulatory and law enforcement authorities: Philippine government agencies, including the National Privacy Commission, and law enforcement bodies, where disclosure is required by law or court order.
All third-party service providers engaged by 73216pnl are contractually required to process your personal data only in accordance with our instructions and to implement appropriate technical and organizational security measures.
7 Data Retention
73216pnl retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law or legitimate business purposes. Specifically:
- Account and identity data is retained for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering regulations.
- Transaction records are retained for a minimum of five (5) years from the date of each transaction.
- Customer support communications are retained for three (3) years from the date of the interaction.
- Technical and usage logs are retained for up to twelve (12) months, after which they are anonymized or deleted.
Upon expiry of the applicable retention period, 73216pnl will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.
8 Cookies and Tracking Technologies
73216pnl uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. We use the following categories of cookies:
- Strictly necessary cookies: Essential for the Platform to function correctly, including maintaining your login session and enabling secure transactions. These cannot be disabled.
- Analytics cookies: Used to collect anonymized data about how players use the 73216pnl Platform, helping us identify areas for improvement. These are only set with your consent.
- Preference cookies: Used to remember your Platform settings and preferences, such as language and display options.
You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 73216pnl Platform. For detailed information on the specific cookies we use, please refer to our Cookie Notice available on the Platform.
73216pnl does not use cookies to track your activity on third-party websites or to serve targeted advertising on external platforms.
9 Your Data Rights
Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 73216pnl:
- Right to be informed: You have the right to know what personal data 73216pnl collects about you and how it is processed.
- Right of access: You may request a copy of the personal data 73216pnl holds about you at any time.
- Right to rectification: You may request correction of any inaccurate or incomplete personal data in your 73216pnl account.
- Right to erasure: You may 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.
- Right to object: You may object to the processing of your personal data for direct marketing purposes at any time.
- Right to data portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
- Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.
To exercise any of these rights, please contact the 73216pnl Data Privacy Officer using the contact details provided in Section 13 of this Privacy Policy. We will respond to all verified requests within thirty (30) days of receipt.
10 Data Security
73216pnl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:
- 256-bit SSL/TLS encryption for all data transmitted between your device and the 73216pnl Platform
- Encryption of sensitive data at rest, including financial information and identity documents
- Role-based access controls limiting employee access to personal data on a strict need-to-know basis
- Regular security audits, vulnerability assessments, and penetration testing
- Intrusion detection and prevention systems monitoring the Platform infrastructure
- Multi-factor authentication requirements for administrative access to systems holding personal data
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 73216pnl will notify the National Privacy Commission and affected players in accordance with the timeframes and procedures prescribed by the Data Privacy Act of 2012 and its Implementing Rules and Regulations.
11 Children's Privacy
The 73216pnl Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling laws. 73216pnl does not knowingly collect personal data from individuals under the age of 21. If we become 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 are a parent or guardian and believe that a minor has registered on the 73216pnl Platform or provided us with personal data, please contact our support team immediately at the contact details provided in Section 13. We take the protection of minors very seriously and will act promptly on all such reports.
12 Changes to This Privacy Policy
73216pnl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.
The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how 73216pnl protects your personal data. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.
13 Contact Our Data Privacy Officer
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 73216pnl, please contact our Data Privacy Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.
Data Controller: 73216pnl
Platform: https://73216pnl.org
Response Time: Within 30 days of receipt of a verified request
Support Hours: 24 hours a day, 7 days a week
You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with our response to your privacy concern.