Privacy Policy

1. Introduction

35bmw ("35bmw," "we," "us," "our") is committed to protecting the privacy and personal data of all players and visitors who use the 35bmw Platform at https://35bmw.club. This Privacy Policy ("Policy") explains what personal data we collect, how we use it, who we share it with, and what rights you have over your personal information.

This Policy applies to all personal data collected through the 35bmw website, mobile-optimized interfaces, 35bmw Login portal, account registration and verification processes, customer support interactions, and any other service provided by 35bmw to players in the Philippines and elsewhere.

This Policy should be read together with our Terms and Conditions, which are available at 35bmw Terms & Conditions. Capitalized terms used in this Policy that are not defined herein have the meanings given to them in the Terms and Conditions.

2. Data Controller

35bmw is the data controller responsible for your personal data collected and processed through the Platform. For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations ("DPA"), 35bmw determines the purposes and means of processing your personal data.

If you have any questions about how 35bmw handles your personal data, or if you wish to exercise any of your rights as a data subject, please contact us using the details provided in Section 15 of this Policy.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register for a 35bmw account, complete the 35bmw Login process, or otherwise use the Platform, you may provide us with the following categories of personal data:

• Identity Data: Full legal name, date of birth, gender, nationality, government-issued identification number (e.g., Philippine National ID, passport number, driver's license number)
• Contact Data: Email address, mobile phone number, residential address (including barangay, city or municipality, province, and postal code)
• Account Data: Username, password (stored in hashed form — never in plain text), account preferences and settings
• Financial Data: GCash account details, PayMaya account details, bank account information (BPI, BDO, Metrobank, and others), Visa or Mastercard details (card number, expiry, and CVV are tokenized and not stored directly by 35bmw)
• KYC Documentation: Copies of government-issued identification documents, proof of address documents, selfie or video verification footage, and any other documentation submitted for identity verification purposes
• Communications Data: Records of your communications with 35bmw customer support, including live chat transcripts, emails, and any feedback or complaints submitted

3.2 Data Collected Automatically

When you access and use the 35bmw Platform, we automatically collect certain technical and usage data, including:

• Technical Data: IP address, browser type and version, operating system, device identifiers, screen resolution, and time zone
• Usage Data: Pages visited, features used, games played, session duration, click patterns, search queries within the Platform, and 35bmw Login timestamps
• Transaction Data: Details of all deposits, withdrawals, bonuses claimed, bets placed, and game outcomes associated with your account
• Cookie Data: Information stored in cookies and similar tracking technologies, as described further in Section 9

4. How We Use Your Personal Data

35bmw uses your personal data for the following purposes:

• To create, verify, and maintain your 35bmw account and process your 35bmw Login requests
• To provide and improve the Platform's games, features, and overall service quality
• To process deposits, withdrawals, and other financial transactions
• To verify your identity and age for KYC compliance and PAGCOR regulatory requirements
• To detect, prevent, and investigate fraud, money laundering, bonus abuse, and other prohibited activities
• To comply with applicable laws and regulations, including PAGCOR licensing requirements, the Philippine Anti-Money Laundering Act (AMLA), and the Data Privacy Act
• To provide customer support and respond to your inquiries and complaints
• To send you account-related communications, including transaction confirmations, security alerts, and policy updates
• To enforce our Terms and Conditions and other applicable policies
• To analyze Platform usage and player behavior for internal reporting and product improvement purposes (using aggregated or anonymized data wherever possible)
• To implement responsible gaming measures, including administering deposit limits, loss limits, and self-exclusion requests

5. Legal Bases for Processing

Under the Philippine Data Privacy Act, 35bmw processes your personal data on the following legal bases:

• Contractual Necessity: Processing necessary to perform our contract with you, including operating your account, processing transactions, and delivering Platform services
• Legal Obligation: Processing required to comply with applicable laws, including PAGCOR regulations, AML/CTF obligations, and the Data Privacy Act
• Legitimate Interests: Processing necessary for 35bmw's legitimate business interests, including fraud prevention, security monitoring, and Platform improvement, where such interests are not overridden by your data protection rights
• Consent: Processing based on your freely given, specific, and informed consent, including for marketing communications where you have opted in

6. Sharing Your Personal Data

35bmw does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash (Mynt), PayMaya (Maya Bank), BPI, BDO, Metrobank, Visa, and Mastercard — to process your financial transactions
• KYC and Identity Verification Providers: Third-party identity verification services that assist 35bmw in meeting PAGCOR and AMLA compliance requirements
• Game Providers: Software providers whose games are integrated into the 35bmw Platform may receive limited transactional data necessary to operate their games fairly
• Technology Service Providers: Cloud hosting, cybersecurity, analytics, and customer support software providers engaged by 35bmw to operate the Platform
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies where disclosure is required by law or court order
• Professional Advisers: Legal, accounting, and auditing firms engaged by 35bmw, subject to professional confidentiality obligations

7. International Data Transfers

Some of 35bmw's third-party service providers and game suppliers may be located outside the Philippines. Where personal data is transferred to recipients in other countries, 35bmw takes reasonable steps to ensure that appropriate data protection safeguards are in place, consistent with the requirements of the Philippine Data Privacy Act. This may include contractual provisions requiring overseas recipients to maintain data protection standards equivalent to those required under Philippine law.

8. Data Retention

35bmw retains personal data for as long as necessary to fulfill the purposes described in this Policy, and in any event for the minimum periods required by applicable law. Specific retention periods include:

• Account Data: Retained for the duration of your active account relationship with 35bmw, and for a period of at least five (5) years following account closure, as required by PAGCOR and AMLA regulations
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA record-keeping requirements
• KYC Documents: Retained for five (5) years following the termination of the business relationship
• Customer Support Records: Retained for three (3) years from the date of the interaction
• Usage and Technical Logs: Retained for up to twelve (12) months for security and fraud prevention purposes

When personal data is no longer required, 35bmw will securely delete or anonymize it in accordance with our data destruction procedures.

9. Cookies and Tracking Technologies

35bmw uses cookies and similar technologies (including web beacons and local storage) on the Platform. Cookies are small data files stored on your device when you visit the Platform. We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function, including maintaining your 35bmw Login session and security features. These cannot be disabled without affecting Platform functionality.
• Performance Cookies: Collect anonymized data about how players use the Platform, helping 35bmw improve performance, identify errors, and optimize the user experience.
• Functionality Cookies: Remember your preferences and settings, such as language preferences and game display options, to personalize your experience.
• Analytics Cookies: Used to understand aggregate usage patterns on the Platform. Data collected through analytics cookies is anonymized and does not identify individual players.

You can control and delete cookies through your browser settings. Disabling certain cookies may affect the functionality of the Platform, including the 35bmw Login process. Please refer to your browser's help documentation for instructions on managing cookies.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 35bmw:

• Right to Be Informed: The right to be informed about how your personal data is being processed by 35bmw
• Right of Access: The right to request a copy of the personal data 35bmw holds about you
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal data under certain circumstances, subject to 35bmw's legal retention obligations
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible
• Right to Damages: The right to be indemnified for damages sustained as a result of inaccurate, incomplete, or unlawfully obtained personal data

To exercise any of these rights, please contact 35bmw at the email address provided in Section 15. We will respond to your request within thirty (30) days of receipt. In some cases, we may need to verify your identity before processing your request.

If you are not satisfied with 35bmw's handling of your personal data or your data subject rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Security Measures

35bmw implements appropriate technical and organizational 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 35bmw Platform, including during the 35bmw Login process
• Hashing of account passwords using industry-standard cryptographic algorithms — passwords are never stored in plain text
• Tokenization of payment card data — card details are processed by PCI DSS-compliant payment processors and are not stored directly on 35bmw's servers
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure
• Two-factor authentication (2FA) availability for all player accounts

While 35bmw takes data security seriously, no system is completely immune to breach. In the event of a personal data breach that is likely to adversely affect your rights and freedoms, 35bmw will notify affected players and the National Privacy Commission in accordance with the Data Privacy Act's breach notification requirements.

12. Children's Privacy

The 35bmw Platform is strictly intended for individuals aged 21 years and above, as required by PAGCOR regulations. 35bmw does not knowingly collect personal data from individuals under the age of 21. If 35bmw discovers that personal data has been collected from a person under 21, such data will be deleted promptly and the relevant account will be permanently closed. Parents or guardians who believe their minor child may have provided personal data to 35bmw should contact us immediately using the details in Section 15.

13. Third-Party Links and Services

The 35bmw Platform may contain references to third-party services (such as payment processors or game providers). These third parties have their own privacy policies, and 35bmw is not responsible for their data practices. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of 35bmw.

14. Changes to This Privacy Policy

35bmw reserves the right to update or modify this Privacy Policy at any time. When material changes are made, 35bmw will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect, and will update the "Last Updated" date at the top of this document. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

15. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or 35bmw's data processing practices, please contact our Data Protection Officer:

You may also submit a complaint to the National Privacy Commission of the Philippines if you believe 35bmw has not handled your personal data in compliance with the Data Privacy Act of 2012.