mnl365 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how mnl365 ("mnl365," "we," "us," or "our"), the operator of the online gaming platform accessible at mnl365.club, collects, uses, stores, discloses, and otherwise processes the personal data of individuals ("Players," "you," or "your") who access or use our platform.

mnl365 is committed to protecting the privacy and personal data of all Filipino players in full compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR") as enforced by the National Privacy Commission ("NPC") of the Philippines.

By accessing mnl365.club and registering an account, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not access or use the mnl365 platform.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012, mnl365 is the personal information controller ("PIC") responsible for your personal data. All data processing activities described in this Policy are carried out by mnl365 or by authorised third-party processors acting on our instructions.

mnl365 has designated a Data Protection Officer ("DPO") as required under the DPA. The DPO oversees all data protection compliance activities and is the primary point of contact for all data privacy inquiries. Contact details for the DPO are provided in Section 14 of this Policy.

3. Personal Data We Collect

3.1 Registration Data

When you create a mnl365 account, we collect the following personal data: your Philippine mobile number; a username or display name of your choosing; date of birth (for age verification purposes); and optionally, your full legal name and government-issued ID details if you elect to complete full KYC verification.

3.2 Identity Verification Data (KYC)

To comply with PAGCOR and AMLA requirements, mnl365 may request government-issued identification documents before processing withdrawals above specified thresholds. Accepted Philippine ID documents include the PhilSys National ID, passport, driver's licence, SSS/GSIS ID, and PRC ID. Copies of these documents are processed and stored in accordance with this Policy and applicable law.

3.3 Transaction Data

We collect records of all financial transactions conducted through your mnl365 account, including deposit amounts, withdrawal requests, payment method identifiers (e.g., masked GCash number, bank account reference), transaction dates, and transaction outcomes.

3.4 Gaming Activity Data

mnl365 records your gaming activity on the platform, including games played, bet amounts, game outcomes, session duration, and responsible gaming settings. This data is used for platform operation, regulatory compliance, and responsible gaming monitoring.

3.5 Technical & Device Data

When you access mnl365, we automatically collect certain technical data including: IP address; device type, model, and operating system; browser type and version; pages visited and navigation paths within the platform; session timestamps; and approximate geographic location derived from IP address.

3.6 Communications Data

When you contact mnl365 customer support, we retain records of those communications — including live chat transcripts, support ticket content, and any information you voluntarily provide during those interactions.

4. How We Use Your Personal Data

mnl365 uses your personal data for the following purposes:

• Account creation and management: To register your account, verify your identity, and maintain your player profile on the mnl365 platform.
• Provision of gaming services: To operate the platform, process bets, calculate and credit winnings, and deliver all gaming services offered by mnl365.
• Payment processing: To facilitate deposits and withdrawals through GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment channels.
• Regulatory compliance: To fulfil our obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and other applicable Philippine law — including transaction reporting and record-keeping requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeovers, money laundering, and other prohibited conduct on the platform.
• Responsible gaming: To monitor gaming patterns for signs of problem gambling and to administer self-imposed responsible gaming tools such as deposit limits, cool-off periods, and self-exclusion requests.
• Customer support: To respond to your inquiries, resolve complaints, and improve the quality of our support services.
• Platform improvement: To analyse usage patterns, identify technical issues, and develop new features to improve the mnl365 player experience.
• Communications: To send you important service notifications, security alerts, and — where you have provided consent — promotional communications about mnl365 offers and updates.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, mnl365 processes your personal data under one or more of the following lawful bases:

• Contractual necessity: Processing is necessary for the performance of the contract between you and mnl365 (i.e., the Terms & Conditions governing your use of the platform).
• Legal obligation: Processing is necessary for mnl365 to comply with a legal obligation under Philippine law, including PAGCOR regulations and AMLA requirements.
• Legitimate interests: Processing is necessary for the legitimate interests of mnl365, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and interests.
• Consent: For optional processing activities — such as sending promotional communications — mnl365 relies on your freely given, specific, and informed consent, which you may withdraw at any time without affecting the lawfulness of prior processing.

6. Cookies & Tracking Technologies

mnl365 uses cookies and similar tracking technologies on the platform for the following purposes:

• Strictly necessary cookies: Required for core platform functionality, including maintaining your login session, remembering your game preferences, and ensuring platform security. These cookies cannot be disabled without impairing platform functionality.
• Analytics cookies: Used to collect anonymised data about how players navigate and use the platform, enabling mnl365 to identify and fix issues and improve user experience. No personally identifiable information is included in analytics data.
• Preference cookies: Used to remember your settings and preferences across sessions, such as language selection or responsible gaming display preferences.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair the functionality of the mnl365 platform.

7. Data Sharing & Disclosure

mnl365 does not sell, rent, or trade your personal data to third parties. We share personal data only in the following limited circumstances:

• Payment processors: We share the minimum necessary data with payment service providers (including GCash / Maya Philippines, BPI, BDO, and Metrobank) solely to process your deposits and withdrawals.
• Identity verification providers: We may use third-party KYC service providers to verify the authenticity of identity documents submitted by players.
• Regulatory authorities: We are required by Philippine law to disclose certain transaction data and player information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other regulatory bodies upon lawful request.
• Technology service providers: We engage third-party technology vendors who provide infrastructure, analytics, fraud detection, and support tools under strict data processing agreements that prohibit them from using your data for any purpose other than providing services to mnl365.
• Legal proceedings: We may disclose personal data where required by a valid court order, subpoena, or other lawful judicial or administrative process under Philippine law.

All third parties with whom mnl365 shares personal data are required to handle such data in accordance with the DPA and in a manner consistent with this Policy.

8. Data Security

mnl365 implements a comprehensive set of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit TLS/SSL encryption for all data in transit between your device and mnl365 servers.
• AES-256 encryption for sensitive data at rest, including identity documents and financial records.
• Multi-factor authentication (OTP-based) for account login from new or unrecognised devices.
• Role-based access controls ensuring that mnl365 staff can only access player data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing by qualified security professionals.
• Intrusion detection and real-time fraud monitoring systems operating continuously across the platform.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that poses a real risk to your rights and freedoms, mnl365 will notify the National Privacy Commission and affected players within the timeframes required by the DPA.

9. Data Retention

mnl365 retains your personal data for as long as your account is active and for such additional period as required by applicable law. Specific retention periods include:

• Account registration data: For the duration of your account plus 5 years after account closure, in compliance with PAGCOR record-keeping requirements.
• Transaction records: A minimum of 5 years from the date of each transaction, as required by AMLA and PAGCOR regulations.
• KYC / identity documents: For the duration of the account relationship plus a minimum of 5 years, or as otherwise required by applicable Philippine law.
• Customer support communications: Up to 3 years from the date of the relevant interaction.
• Gaming activity logs: Up to 3 years, unless retention for a longer period is required for regulatory or legal purposes.

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

10. 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 mnl365:

• Right to be informed: The right to know what personal data mnl365 collects, how it is used, and with whom it is shared — as set out in this Policy.
• Right of access: The right to request a copy of all personal data mnl365 holds about you, including the source of that data where practicable.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to mnl365's legal obligations to retain certain records.
• Right to object: The right to object to specific processing activities, including direct marketing communications, at any time.
• Right to data portability: The right to receive a structured, machine-readable copy of personal data you have provided to mnl365.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

11. Children's Privacy

The mnl365 platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law and PAGCOR regulations. mnl365 does not knowingly collect personal data from individuals under the age of 21. If mnl365 discovers or is notified that a person under 21 has registered an account, that account will be immediately closed and any personal data collected will be deleted from our systems without undue delay.

If you have reason to believe that a minor has accessed the mnl365 platform and provided personal data, please contact our support team or DPO immediately.

12. International Data Transfers

Where it is necessary to transfer your personal data outside of the Philippines — for example, to cloud infrastructure providers or technology partners with operations in other jurisdictions — mnl365 will ensure that such transfers are made only to countries or organisations that offer a level of data protection equivalent to that provided under Philippine law, or pursuant to appropriate contractual safeguards consistent with NPC guidelines.

mnl365 will not transfer your personal data to any jurisdiction that does not provide adequate data protection without your explicit consent or a lawful basis under the DPA.

13. Updates to This Privacy Policy

mnl365 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, we will notify registered players via in-platform notification. The updated Policy will take effect upon publication at mnl365.club/privacy-policy.

The "Effective Date" shown at the top of this Policy indicates the date on which the current version came into force. We encourage you to review this Policy periodically to stay informed about how mnl365 protects your personal data.

14. Contact & Data Protection Officer

For all personal data inquiries, privacy rights requests, or complaints regarding mnl365's data processing practices, please contact our Data Protection Officer through the following channels:

• Email: [email protected] — Subject line: "Data Privacy Request"
• Live Chat: Available 24 hours a day, 7 days a week via the mnl365 platform support widget
• Response Time: All DPA-related requests will receive an initial response within 5 business days and be resolved within 15 business days.

If you are not satisfied with mnl365's response to a data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. Information about the NPC's complaint procedures is publicly available through official Philippine government channels.