9phl Privacy Policy

This Privacy Policy ("Policy") describes how 9phl ("the Company," "we," "us," "our"), the operator of the online gaming platform accessible at https://9phl.club (the "Platform"), collects, processes, stores, shares, and protects the personal data of users ("Players," "you," "your") in connection with your use of our services.

This Policy applies to all personal data collected through the 9phl Platform, including data provided directly by you during registration and gameplay, data collected automatically through your use of the Platform, and data obtained from third parties as part of our regulatory compliance obligations.

This Policy is designed to comply with the requirements of Republic Act No. 10173, the Data Privacy Act of 2012 (the "DPA"), its Implementing Rules and Regulations, the issuances of the National Privacy Commission of the Philippines, and the data handling obligations imposed on 9phl under its PAGCOR operating license.

9phl is the personal information controller in respect of the personal data it processes about its players. The Company has designated a Data Protection Officer (DPO) responsible for ensuring compliance with the Data Privacy Act and for responding to data subject requests and inquiries.

For all privacy-related matters, including the exercise of your rights as a data subject, you may contact the 9phl Data Protection Officer using the contact information provided in Section 16 of this Policy. The DPO is accessible during Philippine business hours and will respond to formal written data subject requests within the timeframe specified in the DPA's implementing rules.

9phl collects and processes the following categories of personal data from players registered on the Platform:

A. Identity and Account Data

• Full legal name as it appears on your government-issued Philippine ID.
• Date of birth (used to verify the PAGCOR-mandated 21+ age requirement).
• Username chosen during account registration.
• Hashed password (your actual password is never stored in readable form).
• Government-issued photo ID type and reference number (e.g., Passport number, UMID number, Driver's License number).
• A photograph of your government-issued ID and a selfie image, submitted for KYC verification.

B. Contact Data

• Philippine mobile number used as the primary account identifier and OTP delivery channel.
• Email address, where provided.
• Residential address in the Philippines, where required for KYC or AMLA compliance purposes.

C. Financial Data

• E-wallet account identifiers (GCash mobile number, Maya account reference) used for deposits and withdrawals.
• Bank account details (BPI, BDO, Metrobank, or other Philippine bank) where bank transfer is used for deposits or withdrawals.
• Deposit and withdrawal transaction histories, including amounts, timestamps, and payment method references.
• Account balance history.
• Source-of-funds information provided in compliance with AMLA reporting requirements where applicable.

D. Gaming and Behavioral Data

• Full gaming session history including games played, bets placed, amounts wagered, winnings, and session duration.
• Betting patterns and game preferences observed during platform use.
• Bonus and promotion uptake and wagering requirement progression.
• Responsible gaming settings activated by you or applied by 9phl, including deposit limits, loss limits, and self-exclusion history.

E. Technical and Device Data

• IP address and approximate geolocation data (used to verify Philippine jurisdiction compliance).
• Device type, operating system, browser type, and screen resolution.
• Session logs including login timestamps, session durations, and navigation within the Platform.
• Cookie identifiers and similar tracking technology data as described in Section 8.

9phl collects personal data through the following means:

• Direct collection: Information you actively provide during account registration, KYC submission, payment processing, customer support interactions, and any surveys or feedback mechanisms on the Platform.
• Automated collection: Technical and behavioral data collected automatically through your interaction with the Platform, including server logs, game analytics systems, and cookie-based tracking as described in Section 8.
• Third-party collection: Identity verification data received from accredited KYC service providers engaged by 9phl; fraud signals and risk scores from payment fraud prevention partners; and geolocation verification data from network infrastructure services used to confirm Philippine jurisdiction compliance.
• Regulatory-mandated collection: Information collected as required by PAGCOR's licensing terms, the Anti-Money Laundering Act (AMLA), or direct regulatory instruction from PAGCOR or other competent Philippine authority.

9phl processes personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Performance of Contract: Processing of identity, contact, financial, and gaming data is necessary for the performance of the agreement between 9phl and each registered player, including account management, game provision, payment processing, and customer support.
• Legal Obligation: Processing necessary for compliance with 9phl's obligations under the Data Privacy Act, PAGCOR licensing requirements, the Anti-Money Laundering Act (Republic Act No. 9160 as amended), and other applicable Philippine statutes and regulatory directives.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and Platform improvement, where such interests are balanced against the rights and interests of data subjects and are not outweighed by those rights.
• Consent: Processing for direct marketing communications and optional preference personalization, where you have provided express consent that may be withdrawn at any time without affecting the lawfulness of prior processing.

Personal data collected by 9phl is used for the following specific purposes:

• Creating, maintaining, and administering your 9phl account, including authentication, account security, and session management.
• Processing deposits, withdrawals, and all financial transactions on the Platform using your verified Philippine payment methods (GCash, Maya, BPI, BDO, Metrobank, and others).
• Performing Know Your Customer (KYC) identity verification as required by PAGCOR's licensing conditions and the Anti-Money Laundering Act.
• Verifying your age to enforce the PAGCOR-mandated 21+ age restriction.
• Verifying your location to ensure Platform access is limited to players physically within the Philippines as required under 9phl's PAGCOR license.
• Detecting, investigating, and preventing fraud, money laundering, collusion, and other prohibited conduct.
• Operating and delivering all gaming products, live dealer services, and sportsbook features available on the Platform.
• Administering responsible gaming tools including deposit limits, loss limits, self-exclusion, and session time controls, and monitoring for indicators of problem gambling behavior.
• Providing customer support services in English and Tagalog through live chat and email.
• Sending transactional communications including deposit confirmations, withdrawal notifications, OTP messages, and account security alerts.
• Sending promotional and marketing communications about 9phl offers, bonuses, and new features, where you have provided consent or where legitimate interests apply.
• Generating aggregated and anonymized analytics to improve Platform performance, game selection, and user experience.
• Complying with reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and any other competent Philippine regulatory or law enforcement authority.

9phl does not sell, rent, or commercially transfer your personal data to third parties. Personal data is shared only in the following circumstances and with the following categories of recipients:

• Game Providers: Game session data (session identifiers, bet amounts, RNG seeds, game outcomes) is shared with licensed game providers (such as Pragmatic Play, PG Soft, Jili Games, and CQ9) solely to the extent necessary to deliver the game functionality and resolve disputes. These providers are contractually bound to data protection standards consistent with this Policy.
• Payment Processors: Payment and identity data necessary to process deposits and withdrawals is shared with authorized Philippine payment providers including GCash, Maya, BPI, BDO, Metrobank, and other licensed Philippine financial institutions. All payment partners are subject to Bangko Sentral ng Pilipinas (BSP) oversight and maintain independent data protection obligations.
• KYC and Verification Partners: Identity documents and biometric selfie data submitted for KYC are processed by accredited identity verification service providers engaged by 9phl under data processing agreements that require compliance with the DPA.
• Fraud Prevention Services: Device and transaction data may be shared with fraud detection and cybersecurity service providers to protect the Platform and its players from fraudulent activity.
• Regulatory and Law Enforcement Authorities: 9phl will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), and law enforcement bodies where required by applicable Philippine law, court order, or direct regulatory instruction. Such disclosures will be limited to the minimum necessary to fulfill the legal obligation.
• Professional Advisers: Personal data may be disclosed to legal, audit, or financial advisers engaged by 9phl in connection with the provision of their professional services, subject to confidentiality obligations.

9phl uses cookies and similar tracking technologies on the Platform to operate core functionality, improve performance, and understand how players use the site. A cookie is a small text file stored on your device when you visit a website. The following categories of cookies are used on the 9phl Platform:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your 9phl account, security cookies that support fraud detection, and cookies that maintain your language and regional preference settings. These cookies cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Enable enhanced features and personalization such as remembering your preferred game categories, display settings, and responsible gaming configurations. Disabling these cookies may reduce Platform functionality.
• Analytics Cookies: Used by 9phl's internal analytics system to collect aggregated, anonymized data about how users navigate the Platform — including page visit frequencies, feature usage patterns, and game category popularity. This data is used solely to improve the Platform and is not linked to individual player identities in any reports.
• Security and Fraud Detection Cookies: Enable 9phl to identify and block fraudulent login attempts, bot activity, and other Platform abuse. These work by comparing device fingerprint data across sessions.

Most web browsers permit you to control cookie settings through the browser's privacy preferences. Note that blocking strictly necessary cookies will impair your ability to log in to and use the 9phl Platform. You can manage your cookie preferences at any time through your browser settings.

9phl implements a multi-layered security program to protect personal data against unauthorized access, disclosure, alteration, and destruction. The following technical and organizational security measures are in place:

• 256-bit SSL/TLS encryption for all data in transit between your device and 9phl's servers.
• Encryption at rest for stored personal data, financial records, and KYC documents using industry-standard encryption algorithms.
• Passwords are stored exclusively as salted cryptographic hashes using a recognized secure hashing algorithm. Plain-text passwords are never stored or logged.
• Two-factor authentication (2FA) available for all accounts and strongly recommended for all players.
• Role-based access controls limiting internal staff access to personal data to the minimum necessary for each staff member's function.
• Regular security vulnerability assessments and penetration testing of Platform infrastructure by qualified cybersecurity professionals.
• Logging and monitoring of all access to systems containing personal data, with automated alerting for anomalous access patterns.
• Physical security controls at data processing facilities including access logging and surveillance.
• Data processor contracts with all third-party service providers handling personal data on behalf of 9phl, requiring maintenance of security standards consistent with this Policy.

9phl retains personal data only for as long as necessary to fulfill the purposes described in this Policy or as required by applicable Philippine law and PAGCOR licensing conditions. The following retention periods apply:

• Active Account Data: Retained for the duration of your account relationship with 9phl plus a minimum of five (5) years following account closure, as required under PAGCOR's record-keeping obligations and AMLA compliance requirements.
• KYC and Identity Documents: Retained for a minimum of five (5) years following account closure in compliance with Anti-Money Laundering Council (AMLC) record retention requirements applicable to covered persons under the AMLA.
• Financial Transaction Records: Retained for a minimum of five (5) years following the date of each transaction, consistent with AMLA record-keeping requirements and BIR record retention standards.
• Gaming Session Logs: Retained for a minimum of three (3) years to support dispute resolution, regulatory audits, and responsible gaming monitoring obligations.
• Technical and Security Logs: Retained for a period of twelve (12) months, except where specific logs are required to support an ongoing fraud investigation or legal proceeding, in which case they will be retained for the duration of that matter.
• Marketing Consent Records: Retained for three (3) years following the withdrawal of consent or last marketing interaction, as evidence of the legal basis for prior marketing communications.

Following the expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymized using processes that prevent re-identification.

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights in relation to the personal data 9phl holds about you. These rights apply to all Filipino players and residents of the Philippines. You may exercise any of these rights by contacting the 9phl Data Protection Officer using the contact details in Section 16.

9phl will respond to all valid data subject requests within thirty (30) days of receipt. Where a request is complex or involves a large volume of data, 9phl may extend this period by a further thirty (30) days, notifying you of the extension and the reasons for it within the initial period.

9phl's services are directed exclusively at adults aged 21 and above, consistent with PAGCOR's mandatory age restriction for all licensed Philippine online gaming platforms. 9phl does not knowingly collect personal data from any individual under the age of 21.

If 9phl becomes aware that it has inadvertently collected personal data from an individual who is under 21 years of age, it will take immediate steps to delete that data from its systems, close the account, and refund any deposits made net of any applicable processing fees.

If you believe that a minor has registered for or accessed a 9phl account, please contact 9phl's customer support immediately via live chat or at [email protected] so the matter can be investigated and resolved promptly.

9phl may send you marketing communications about new games, promotions, bonuses, and 9phl features where you have consented to receive such communications during account registration or at a later point. You may withdraw your consent to receive marketing communications at any time by:

• Clicking the unsubscribe link in any marketing email you receive from 9phl.
• Updating your communication preferences in your 9phl account settings.
• Contacting 9phl customer support with a request to opt out of marketing communications.

Withdrawal of consent to marketing communications does not affect the lawfulness of processing conducted prior to withdrawal, and does not affect your receipt of transactional communications that are necessary for your account operation (such as deposit confirmations, withdrawal notifications, OTP messages, and security alerts).

Please note that where you have activated self-exclusion or cooling-off period responsible gaming tools, 9phl will automatically suppress all marketing communications for the duration of the restriction, regardless of your general marketing consent status.

The 9phl Platform may contain references to or integrations with third-party services, including game provider platforms and payment processing interfaces. These third parties operate under their own privacy policies and data protection frameworks, separate and distinct from this Policy.

9phl is not responsible for the privacy practices of any third-party service providers whose interfaces appear on or are accessible through the 9phl Platform. We recommend that you review the privacy policies of any third-party service you use in connection with your 9phl experience. Our use of third-party game providers and payment processors is governed by data processing agreements that require those parties to maintain privacy standards consistent with the requirements of the Data Privacy Act.

9phl may update this Privacy Policy from time to time to reflect changes in applicable Philippine law, PAGCOR regulatory requirements, 9phl's data processing activities, or best practices in data protection. When material changes are made to this Policy, 9phl will provide notice to active account holders via email notification or a prominent notice on the Platform at least 7 days before the revised Policy takes effect, except where changes are required immediately by law or regulatory instruction.

The date of the most recent revision is always displayed at the top of this document. Continued use of the 9phl Platform following the effective date of a revised Policy constitutes your acknowledgment of the updated terms, to the extent permitted by the Data Privacy Act. If any change to this Policy materially affects your rights, 9phl will seek fresh consent where required by law.

For all questions, concerns, or requests relating to this Privacy Policy or your personal data rights, you may contact 9phl's Data Protection Officer using the following details:

• Email (Privacy Matters): [email protected] — please include "Data Privacy Request" or "DPO" in the subject line of your email to ensure prompt routing to the Data Protection Officer.
• Live Chat: Available 24/7 on the 9phl Platform for general privacy inquiries. For formal data subject rights requests, written email contact to the DPO is preferred to ensure proper documentation.
• Platform: https://9phl.club