9ph28 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by 9ph28 ("the Company," "we," "us," or "our") and applies to all personal data collected through the 9ph28 website at https://9ph28.net, including all associated pages, features, games, and services (collectively, the "Platform").

9ph28 is committed to protecting the privacy and personal data of all users of the Platform in accordance with the Data Privacy Act of the Philippines (Republic Act No. 10173, as amended), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC). Where applicable, we also observe internationally recognized data protection principles.

By registering an account on the 9ph28 Platform or by continuing to use the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection, use, and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and 9ph28.

2. Data Controller

For the purposes of the Data Privacy Act of the Philippines, 9ph28 acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes through the Platform. This means that 9ph28 determines the purposes and means of processing your personal data.

Where 9ph28 engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and game studios — those parties act as Personal Information Processors (PIPs) and are contractually bound to process your data only in accordance with 9ph28's instructions and this Policy.

If you have any questions about how 9ph28 processes your personal data, or if you wish to exercise any of your data subject rights, please refer to Section 15 (Contact & DPO) of this Policy.

3. Personal Data We Collect

9ph28 collects the following categories of personal data from users of the Platform:

9ph28 does not intentionally collect sensitive personal information as defined under the Data Privacy Act (e.g., health data, religious beliefs, political affiliations) unless specifically required by law or regulatory obligation. Where such data is incidentally disclosed, it will be handled with the highest level of protection.

4. How We Collect Your Data

9ph28 collects personal data through the following means:

• Direct Submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions.
• Automated Technologies: Data collected automatically when you access the Platform, including cookies, web beacons, pixel tags, and server logs. See Section 9 (Cookies & Tracking) for more details.
• Third-Party Sources: Data received from identity verification providers, payment processors, fraud prevention services, and publicly available sources, where permitted by law.
• Regulatory Sources: Data received from PAGCOR or other regulatory bodies in connection with licensing, compliance, or investigation requirements.

5. Purpose & Legal Basis for Processing

9ph28 processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of the Philippines:

• Account Registration & Management: To create and maintain your 9ph28 account, verify your identity, and provide access to Platform features. (Legal basis: Performance of contract; Compliance with legal obligation)
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card. (Legal basis: Performance of contract)
• KYC & AML Compliance: To verify your identity and age (21+), and to comply with the Anti-Money Laundering Act of the Philippines (RA 9160, as amended) and PAGCOR regulatory requirements. (Legal basis: Compliance with legal obligation)
• Responsible Gaming: To monitor gaming behavior, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling. (Legal basis: Legitimate interest; Compliance with legal obligation)
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats. (Legal basis: Legitimate interest; Compliance with legal obligation)
• Customer Support: To respond to your queries, complaints, and support requests. (Legal basis: Performance of contract; Legitimate interest)
• Marketing & Promotions: To send you information about 9ph28 promotions, bonuses, and new features, where you have consented to receive such communications. (Legal basis: Consent)
• Platform Improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the Platform. (Legal basis: Legitimate interest)
• Legal & Regulatory Compliance: To comply with applicable laws, regulations, court orders, and regulatory directives. (Legal basis: Compliance with legal obligation)

6. Sharing Your Personal Data

9ph28 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions.
• Identity Verification Providers: Third-party KYC and liveness-check service providers engaged to verify your identity and age in compliance with PAGCOR requirements.
• Game Studios & Software Providers: Licensed game providers whose games are available on the 9ph28 Platform, to the extent necessary to deliver game services and maintain game integrity.
• Fraud Prevention & Security Services: Third-party providers engaged to detect and prevent fraudulent activity on the Platform.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government agencies, where required by law or regulatory directive.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors engaged by 9ph28, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of 9ph28's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

7. Data Retention

9ph28 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Financial & Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC & Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Gaming History: Retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes.
• Support Communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 9ph28's data disposal procedures.

8. Security Measures

9ph28 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the 9ph28 Platform is protected using TLS (Transport Layer Security) encryption.
• Password Hashing: Account passwords are stored using industry-standard one-way hashing algorithms. 9ph28 staff cannot view your password in plain text.
• Access Controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-Factor Authentication: 9ph28 supports and encourages the use of two-factor authentication (2FA) to protect your account from unauthorized access.
• Intrusion Detection: Automated systems monitor the Platform for suspicious activity, unauthorized access attempts, and potential security breaches.
• Regular Security Audits: 9ph28 conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities.
• Data Minimization: We collect only the personal data that is strictly necessary for the stated purposes and do not retain data beyond the applicable retention period.

While 9ph28 takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. In the event of a personal data breach that is likely to result in serious harm to affected individuals, 9ph28 will notify the National Privacy Commission and affected data subjects in accordance with the requirements of the Data Privacy Act and NPC Circular No. 16-03.

9. Cookies & Tracking Technologies

9ph28 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and support security functions. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that prevent cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display options, and game favorites to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how users interact with the Platform — pages visited, time spent, and features used — to help us improve the Platform's performance and usability.
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate.

9ph28 does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

10. Your Data Subject Rights

Under the Data Privacy Act of the Philippines (RA 10173), you have the following rights in relation to your personal data held by 9ph28:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data 9ph28 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to any overriding legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interest.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of your data subject rights, please contact our Data Protection Officer using the details in Section 15 of this Policy. We will respond to all verified requests within fifteen (15) business days, in accordance with NPC guidelines.

11. Minors & Age Policy

The 9ph28 Platform is strictly intended for individuals who are at least 21 years of age, in compliance with PAGCOR regulations governing online casino gaming in the Philippines. 9ph28 does not knowingly collect personal data from individuals under the age of 21.

As part of our KYC process, all registered players are required to verify their age by submitting a valid government-issued identification document. Any account found to belong to a player under the age of 21 will be immediately suspended, all associated personal data will be securely deleted (subject to any mandatory retention obligations), and any deposits will be returned at the Company's discretion.

If you believe that a minor has registered an account on the 9ph28 Platform, please contact our support team immediately at [email protected] so that we can take prompt action.

12. Cross-Border Data Transfers

In the course of operating the 9ph28 Platform, your personal data may be transferred to and processed in countries outside the Philippines — for example, where our game studio partners or technology service providers are based. Where such transfers occur, 9ph28 ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law.
• Transfers only to countries or organizations that have been assessed as providing an adequate level of data protection.
• Binding corporate rules or equivalent mechanisms where transfers occur within a corporate group.

By using the 9ph28 Platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

13. Third-Party Services & Links

The 9ph28 Platform may reference or integrate with third-party services, including licensed game studios, payment gateways, and identity verification providers. These third parties operate under their own privacy policies, and 9ph28 is not responsible for the data practices of any third party.

9ph28 does not include links to external websites on the Platform. All game content is delivered within the 9ph28 Platform environment. Where third-party services process your personal data on 9ph28's behalf, they do so as Personal Information Processors under contractual obligations consistent with this Policy and the Data Privacy Act.

14. Policy Updates

9ph28 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will update the effective date at the top of this page and, where appropriate, notify registered players via email or an in-platform notification.

Your continued use of the 9ph28 Platform following the posting of any changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically. The most current version will always be available at https://9ph28.net/privacy-policy.

15. Contact & Data Protection Officer

9ph28 has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of the Philippines. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated. The NPC can be reached through its official website at privacy.gov.ph.