35bmw Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 35bmw ("35bmw," "we," "us," or "the Platform") collects, uses, discloses, retains, and protects personal information relating to individuals ("you," "Player," or "User") who access or use the 35bmw website at 35bmw.org and all associated services, games, promotions, and features.

By registering an account on the 35bmw platform, you acknowledge that you have read and understood this Policy and consent to the collection, processing, and use of your personal data as described herein. If you do not agree with any part of this Policy, please refrain from using the 35bmw platform and contact player support to request account closure.

This Policy should be read together with the 35bmw Terms & Conditions, which also form part of the binding agreement between you and 35bmw. In the event of any conflict between this Policy and the Terms & Conditions with respect to privacy matters, this Policy shall prevail.

2. Data Controller Identity

For the purposes of applicable data protection legislation, the data controller responsible for your personal information collected through the 35bmw platform is the entity operating 35bmw as identified in the platform's regulatory and licensing documentation. Questions regarding the identity of the data controller may be directed to the 35bmw player support team via the contact details provided in Section 15 of this Policy.

35bmw has designated a data protection point of contact who is responsible for overseeing compliance with applicable data protection requirements. Inquiries relating specifically to data protection and privacy rights may be directed to 35bmw player support, who will escalate to the appropriate internal contact as necessary.

3. Personal Data We Collect

35bmw collects personal data through a variety of means, including information you provide directly, information collected automatically during platform use, and information received from third-party verification and payment service providers. The categories of personal data we collect are described below.

3.1 Data You Provide Directly

• Full legal name, date of birth, and nationality;
• Residential address (including city, province, and postal code);
• Email address and Philippine mobile phone number;
• Government-issued identification document details (e.g., passport number, driver's license number, SSS or PhilSys ID number);
• Payment information, including GCash wallet number, PayMaya details, or bank account numbers used for deposits and withdrawals;
• Source-of-funds information where requested for regulatory compliance;
• Communications sent to player support, including chat transcripts and email correspondence.

3.2 Data Collected Automatically

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type;
• Session data, including login timestamps, session duration, and pages visited;
• Game participation data, including game type, wager amounts, outcomes, and frequency of play;
• Deposit, withdrawal, and bonus activity on your account;
• Cookies and similar tracking technologies as described in Section 7.

3.3 Data from Third Parties

• Identity verification data from KYC service providers used to confirm the authenticity of your identification documents;
• Payment transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors;
• Fraud screening and anti-money laundering check results from compliance service providers;
• Self-exclusion and responsible gaming status information from applicable gaming regulatory databases where 35bmw is required to query such databases.

4. How We Use Your Personal Data

35bmw uses your personal data for the following purposes. Where a legal basis applies, it is identified in Section 5.

5. Legal Basis for Processing

35bmw processes your personal data on the following legal bases under applicable Philippine data protection legislation:

• Contract Performance: Processing is necessary to provide the services you have requested through your 35bmw account, including account management, game access, and payment processing.
• Legal Obligation: 35bmw is required to process certain personal data to comply with applicable laws, including Know Your Customer (KYC) identity verification requirements, anti-money laundering (AML) obligations, tax reporting obligations, and responsible gaming regulatory requirements.
• Legitimate Interests: 35bmw processes certain data to pursue its legitimate business interests where these do not override your rights, including fraud detection, platform security, abuse prevention, and internal analytics.
• Consent: Where required by applicable law — particularly for marketing communications and certain cookie deployments — 35bmw will seek your prior consent. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

6. Data Sharing & Disclosure

35bmw does not sell your personal data to unaffiliated third parties for their own marketing or commercial purposes. We share your personal data only in the following limited circumstances:

6.1 Service Providers

35bmw engages third-party service providers to support platform operations. These providers process personal data on 35bmw's behalf and are contractually bound to process data only as instructed by 35bmw and in compliance with applicable data protection requirements. Service provider categories include:

• Identity verification and KYC service providers;
• Payment processors (GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard);
• Fraud detection and anti-money laundering compliance platforms;
• Cloud hosting and data storage providers;
• Customer support technology platforms;
• Email and SMS communication service providers.

6.2 Regulatory and Legal Disclosure

35bmw may disclose personal data to regulatory authorities, law enforcement agencies, or other government bodies where required to do so by applicable Philippine law, court order, or regulatory mandate. This includes disclosures to the Anti-Money Laundering Council (AMLC) as required under Republic Act 9160 (Anti-Money Laundering Act) and its amendments.

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or similar corporate transaction involving 35bmw, your personal data may be transferred to the acquiring entity as part of that transaction, subject to the acquirer's commitment to honor the terms of this Privacy Policy or provide equivalent protections.

6.4 With Your Consent

35bmw may share your personal data with additional third parties in circumstances not described above where you have provided explicit prior consent to such sharing.

7. Cookies & Tracking Technologies

The 35bmw platform uses cookies and similar tracking technologies to operate the website, remember your preferences, analyze usage patterns, and support security functions. The types of cookies used on 35bmw include:

• Essential Cookies: Required for the platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings, game display preferences, and "remember me" login status.
• Analytics Cookies: Used to collect anonymized data about how players navigate and interact with the 35bmw platform. This data helps us improve performance, usability, and content.
• Security Cookies: Used to detect and prevent fraudulent activity, including session hijacking, bot activity, and unauthorized account access attempts.

You can manage non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect your ability to use some features of the 35bmw platform. 35bmw does not use cookies to deploy third-party advertising networks on its platform.

8. Data Retention

35bmw retains personal data for as long as is necessary to fulfill the purposes for which it was collected, to comply with applicable legal and regulatory obligations, and to resolve disputes or enforce agreements.

The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from account closure, in accordance with applicable AML record-keeping requirements under Philippine law.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required under applicable financial and gaming regulations.
• Player support communications: Retained for a minimum of two (2) years from the date of the communication, and longer where related to disputes or regulatory inquiries.
• Marketing preferences and consent records: Retained until you withdraw consent or request deletion, and for a reasonable period thereafter to maintain records of consent history.
• Self-exclusion records: Retained for the duration of the exclusion period and for five (5) years thereafter to enable enforcement of self-exclusion terms and compliance with responsible gaming obligations.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized so that it can no longer be attributed to an identifiable individual.

9. Security Measures

35bmw implements a comprehensive range of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, accidental loss, or destruction. These measures include:

• 256-bit TLS/SSL encryption for all data in transit between your device and the 35bmw platform;
• AES-256 encryption for sensitive data stored at rest, including payment information and government ID data;
• Bcrypt hashing of account passwords — plain-text passwords are never stored;
• Multi-factor authentication options for player accounts, including SMS OTP;
• Role-based access controls limiting staff access to personal data strictly to the minimum necessary for their function;
• Regular internal security assessments and penetration testing;
• Automated monitoring systems for anomalous login activity and unauthorized access attempts;
• Secure physical access controls for data center infrastructure.

Notwithstanding these measures, no data transmission over the internet or electronic storage system is completely secure. 35bmw cannot guarantee absolute security of your personal data. In the event of a data breach that poses a risk to your rights, 35bmw will notify affected players and relevant regulatory authorities in accordance with applicable legal requirements.

10. Your Data Rights

Under applicable Philippine data protection legislation, you have the following rights with respect to your personal data held by 35bmw. To exercise any of these rights, please contact 35bmw player support using the details in Section 15.