3n3n Privacy Policy

1. Introduction

This Privacy Policy describes how 3n3n ("we", "us", "our", or "the Platform") collects, uses, stores, discloses, and protects the personal information of individuals ("you", "Player", "User") who access or use the 3n3n online casino and sports betting platform available at 3n3n.net.

3n3n takes its data protection obligations seriously. We are committed to processing personal data lawfully, fairly, and transparently, and to ensuring that the data we hold is accurate, kept secure, and retained only for as long as necessary. We do not sell, rent, or trade your personal information to third parties for their own marketing purposes under any circumstances.

This Policy applies to all personal data collected through the 3n3n website, mobile-optimised platform, customer support channels, and any other touchpoints associated with the 3n3n brand. Please read this Policy carefully alongside our Terms & Conditions before using the Platform.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and applicable data protection laws, 3n3n acts as the personal information controller in respect of the personal data of its registered Players and site visitors. All inquiries regarding data processing, data subject rights requests, and privacy concerns should be directed to the 3n3n Data Protection Officer (DPO) via the contact details provided in Section 16 of this Policy.

3. Personal Data We Collect

3.1 Registration & Identity Data

When you create a 3n3n Account, we collect the following categories of personal data:

• Full legal name as it appears on a government-issued Philippine identification document;
• Date of birth (to verify the 21+ age requirement);
• Residential address within the Philippines;
• Valid Philippine mobile number;
• Email address;
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

To comply with Philippine anti-money laundering regulations and responsible gaming requirements, we collect:

• Copies of government-issued Philippine ID (e.g., PhilSys ID, Passport, Driver's License, UMID, SSS ID, Voter's ID);
• Proof of current Philippine address (utility bill, bank statement, or barangay certificate not older than three months);
• Source-of-funds documentation for large transactions where required by applicable law.

3.3 Financial & Transaction Data

We collect records of all deposits, withdrawals, bonuses, and wagers made through your Account, including the payment method used (e.g., GCash number, Maya account reference, BPI or BDO account identifier), transaction amounts in Philippine Pesos, timestamps, and transaction reference numbers.

3.4 Technical & Device Data

When you access the Platform, we automatically collect device identifiers, browser type and version, operating system, IP address, referring URL, session duration, and pages visited. This data is used to secure your Account, detect fraud, and improve platform performance.

3.5 Gameplay & Behavioural Data

We collect records of games played, bets placed, wagering patterns, session frequency, and responsible gaming tool usage. This data supports our regulatory compliance obligations, helps us identify problem gambling patterns, and allows us to personalise your gaming experience where you have consented to personalisation.

4. How We Collect Your Data

3n3n collects personal data through the following means:

• Directly from you — when you register an Account, complete KYC verification, contact customer support, participate in promotions, or update your Account profile;
• Automatically — through cookies, server logs, and analytics tools when you browse or use the Platform;
• From third-party service providers — including KYC verification partners, payment processors (GCash, Maya, BPI, BDO), and fraud detection services, where necessary to fulfil our contractual or regulatory obligations;
• From publicly available sources — where required for AML screening or regulatory compliance purposes, such as adverse media checks or government watchlists.

5. Purpose & Legal Basis for Processing

The table below sets out the primary purposes for which 3n3n processes your personal data and the corresponding legal basis under the Philippine Data Privacy Act:

6. Sharing Your Personal Data

6.1 Service Providers

3n3n engages trusted third-party service providers to support platform operations. These providers are granted access to personal data only to the extent necessary to perform their specific function and are contractually bound to process data solely on 3n3n's instructions, in compliance with Philippine data protection law. Categories of service providers include:

• Payment processors and e-wallet operators (GCash, Maya, GrabPay, BPI, BDO);
• KYC and identity verification technology providers;
• Casino game software and live dealer studio providers;
• Cloud hosting and cybersecurity service providers;
• Customer support platform providers;
• Analytics and fraud detection services.

6.2 Regulatory and Law Enforcement Authorities

3n3n may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other competent Philippine government authorities where required to do so by applicable law, court order, or regulatory direction.

6.3 No Sale of Personal Data

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 3n3n's business, personal data held by 3n3n may be transferred to the successor entity. In such cases, 3n3n will notify affected Players in advance and ensure that the receiving entity provides equivalent data protection commitments.

7. International Data Transfers

Some of 3n3n's service providers — including game software providers and cloud infrastructure partners — may be located outside the Philippines. Where personal data is transferred to a country or territory that does not provide a level of data protection equivalent to Philippine standards, 3n3n will implement appropriate safeguards, such as contractual data processing agreements that incorporate the standard contractual clauses recognised under the Data Privacy Act's Implementing Rules and Regulations.

Players who wish to obtain information about the specific safeguards applied to international transfers of their data may submit a request to the 3n3n Data Protection Officer using the contact details in Section 16.

8. Data Retention

3n3n retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following indicative retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years following Account closure, in compliance with AML record-keeping requirements;
• Transaction records: Retained for five (5) years from the date of the transaction;
• Customer support records: Retained for three (3) years from the date of the last interaction;
• Marketing preferences: Retained until you withdraw consent or close your Account, whichever is earlier;
• Technical and device logs: Retained for thirteen (13) months for security and fraud analysis purposes.

On expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be linked to any individual.

9. Security Measures

3n3n implements a layered information security programme designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Key measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 3n3n servers;
• Encryption of sensitive data at rest, including KYC documents and financial identifiers;
• OTP-based two-factor authentication for Account login;
• Role-based access controls ensuring that only authorised personnel can access Player data on a need-to-know basis;
• Regular internal and third-party security audits and vulnerability assessments;
• Comprehensive audit logging of all access to and changes made to Player personal data;
• Incident response procedures with mandatory breach notification protocols in accordance with NPC requirements.

10. Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device by the 3n3n platform to facilitate session management, remember your preferences, and collect analytics data. 3n3n also uses similar technologies such as web beacons and local storage objects.

10.2 Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function, including session authentication and security tokens. These cannot be disabled.
• Analytics Cookies: Used to understand how Players navigate the Platform — which games are most popular, how long sessions last, and where errors occur. This data is aggregated and anonymised wherever possible.
• Preference Cookies: Store your language and display preferences to personalise your experience on return visits.
• Responsible Gaming Cookies: Track session duration data to support display of session time reminders where you have enabled this feature.

10.3 Managing Cookies

You can control non-essential cookies through your browser settings. Note that disabling analytics or preference cookies may affect the functionality of certain features on the Platform. Instructions for managing cookies in major browsers are available through the browser's own help documentation.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in respect of your personal data held by 3n3n:

To exercise any of the above rights, please contact the 3n3n Data Protection Officer using the details in Section 16. We may need to verify your identity before processing your request. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

12. Minors & Age Restriction

The 3n3n platform is strictly intended for individuals aged 21 years and above in accordance with Philippine gaming regulations. 3n3n does not knowingly collect personal data from any individual under the age of 21. If we become aware that personal data has been submitted by or on behalf of a person under 21, we will immediately close the associated Account, forfeit any winnings, return any deposits to the originating payment method, and securely delete the minor's personal data.

Parents and guardians are advised to implement appropriate device-level parental controls to prevent minors from accessing gambling platforms, including 3n3n.

13. Marketing Communications

3n3n may send you promotional emails, SMS messages, or in-platform notifications about new games, bonuses, and special offers — but only where you have given your explicit consent to receive such communications during registration or through your Account notification settings.

You may withdraw your consent to marketing communications at any time by:

• Updating your notification preferences in the 3n3n Account settings panel;
• Clicking the unsubscribe link included in any marketing email;
• Contacting 3n3n customer support and requesting to be removed from all marketing lists.

Withdrawal of consent to marketing communications does not affect the lawfulness of processing carried out prior to withdrawal, nor does it affect operational communications necessary to manage your Account (such as deposit confirmations, withdrawal notifications, or important security alerts).

14. Third-Party Links

The 3n3n platform does not include links to external third-party websites for commercial purposes. Any links to third-party content that may appear in informational or support contexts (such as references to PAGCOR guidelines or responsible gaming resources) are provided solely for convenience. 3n3n has no control over the privacy practices of third-party websites and accepts no responsibility for their content or data handling. Players who navigate to any third-party website do so at their own risk and should review those sites' own privacy policies.

15. Changes to This Privacy Policy

3n3n reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or operational requirements. Where changes are material, 3n3n will provide advance notice via email to your registered address or through 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 Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically. Continued use of the 3n3n platform after the effective date of any update constitutes your acknowledgment of and consent to the revised Policy.

16. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or 3n3n's data processing practices, you may contact our Data Protection Officer (DPO) through the following channels:

• Email: [email protected] — please include "Privacy / DPO Request" in the subject line;
• Live Chat: Available 24/7 through your logged-in 3n3n Account;
• Support Hours: 24 hours a day, 7 days a week, in English and Filipino.

If you are not satisfied with 3n3n's response to your privacy inquiry or data subject rights request, you may escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which has authority over personal data processing matters under RA 10173.