Section 01
1. Introduction
This Privacy Policy ("Policy") describes how 9winph ("9winph," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of users ("you," "Player," or "User") who access or use the 9winph online casino platform, including the website at 9winph.app and the 9winph mobile application (collectively, the "Platform").
9winph is committed to protecting the privacy and personal data of all Filipino players in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.
Scope: This Policy applies to all personal data collected through the Platform, including data provided during registration, KYC verification, financial transactions, customer support interactions, and general use of the Platform. By using 9winph, you consent to the practices described in this Policy.
This Policy should be read together with our Terms & Conditions, which govern your use of the 9winph Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.
Section 02
2. Data Controller
For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, 9winph is the personal information controller responsible for your personal data collected through the Platform. Our designated Data Protection Officer (DPO) can be contacted at the details provided in Section 15 of this Policy.
9winph operates within the regulatory framework established by the Philippine Amusement and Gaming Corporation (PAGCOR). Certain data processing activities are carried out in compliance with PAGCOR's regulatory requirements, which may impose mandatory data collection and retention obligations on
us as a licensed operator.
Section 03
3. Data We Collect
9winph collects the following categories of personal data from players:
- Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., Philippine passport number, SSS/GSIS number, PhilSys ID number, driver's license number).
- Contact Data: Email address, mobile phone number, and residential address (including city, province, and postal code within the Philippines).
- Account Data: Username, encrypted password, account preferences, notification settings, and responsible gaming limit configurations.
- Financial Data: GCash account details, Maya account details, Philippine bank account numbers (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), debit card details, transaction history, deposit and withdrawal records, and account balance information. We do not store full payment card numbers; card data is tokenized by our payment processor.
- Gaming Data: Game history, bet amounts, win/loss records, session durations, game preferences, and bonus usage history.
- Technical Data: IP address, device type and model, operating system, browser type and version, time zone, and unique device identifiers.
- Usage Data: Pages visited, features used, click-through data, session timestamps, and navigation paths within the Platform.
- Communications Data: Records of your interactions with our customer support team, including live chat transcripts, email correspondence, and support ticket history.
- KYC Documentation: Copies of government-issued identification documents and proof of address submitted during the verification process.
Sensitive Personal Information: Certain data we collect — such as government ID numbers — may qualify as sensitive personal information under the Data Privacy Act of 2012. We apply heightened security measures to such data and process it only to the extent required by law or with your explicit consent.
Section 04
4. How We Collect Your Data
9winph collects personal data through the following means:
- Direct Submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
- Automated Technologies: Data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. See Section 10 for more information on our use of cookies.
- Third-Party Sources: Data received from payment processors (e.g., GCash, Maya, Philippine banks) to verify transactions; identity verification service providers used for KYC purposes; and fraud prevention and anti-money laundering screening services.
- PAGCOR and Regulatory Bodies: In certain circumstances, we may receive data from PAGCOR or other Philippine regulatory authorities in connection with our licensing obligations.
Section 05
5. How We Use Your Data
9winph uses your personal data for the following purposes:
- Account Management: To register and maintain your 9winph player account, verify your identity, and manage your account settings and preferences.
- Service Delivery: To provide access to games, process deposits and withdrawals, award bonuses, and deliver the core features of the 9winph Platform.
- KYC and Compliance: To verify your identity and age (21+), comply with PAGCOR licensing requirements, and fulfill our obligations under Philippine anti-money laundering (AML) and counter-terrorism financing (CTF) laws.
- Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the Platform and its users.
- Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
- Responsible Gaming: To monitor gaming behavior for signs of problem gambling, enforce self-imposed limits, and administer self-exclusion requests in accordance with our Responsible Gaming policy.
- Marketing and Promotions: To send you promotional offers, bonus notifications, and platform updates, subject to your marketing preferences. You may opt out at any time.
- Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the 9winph Platform.
- Legal Obligations: To comply with applicable Philippine laws, respond to lawful requests from government authorities, and enforce our Terms & Conditions.
Section 06
6. Legal Basis for Processing
Under the Data Privacy Act of 2012, 9winph processes your personal data on the following legal bases:
- Contractual Necessity: Processing required to perform our contract with you — i.e., to operate your account, process transactions, and deliver gaming services.
- Legal Obligation: Processing required to comply with PAGCOR regulations, AML/CTF laws, tax obligations, and other applicable Philippine legal requirements.
- Legitimate Interests: Processing carried out for our legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights.
- Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.
Section 07
7. Data Sharing and Disclosure
9winph does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:
- Payment Processors: GCash, Maya, and Philippine banking partners, to process deposits and withdrawals on your behalf.
- Identity Verification Providers: Third-party KYC and age verification service providers engaged to assist with regulatory compliance.
- Fraud and AML Screening Services: Service providers that assist 9winph in detecting and preventing fraudulent activity and money laundering.
- Game Software Providers: Licensed game developers and content providers whose games are available on the 9winph Platform may receive limited technical data necessary to deliver their games.
- IT and Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers engaged to support the operation of the Platform.
- Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or a valid legal order.
- Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by 9winph, subject to confidentiality obligations.
Third-Party Contracts: All third-party service providers engaged by 9winph are required to process your personal data only on our instructions and in accordance with applicable data protection law. We do not permit them to use your data for their own purposes.
Section 08
8. Data Retention
9winph retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. Specifically:
- Active Account Data: Retained for the duration of your account's active status on the Platform.
- Transaction and Gaming Records: Retained for a minimum of five (5) years following the relevant transaction or gaming session, in compliance with PAGCOR record-keeping requirements and Philippine AML regulations.
- KYC Documentation: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, as required by law.
- Customer Support Records: Retained for three (3) years following the resolution of the relevant support interaction.
- Marketing Data: Retained until you withdraw your consent to marketing communications or request deletion, subject to legal retention obligations.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.
Section 09
9. Data Security
9winph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:
- SSL/TLS encryption for all data transmitted between your device and our servers.
- AES-256 encryption for sensitive data stored in our databases, including financial information and KYC documentation.
- Two-factor authentication (2FA) available for all player accounts.
- Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
- Regular security audits, penetration testing, and vulnerability assessments conducted by independent security professionals.
- Intrusion detection and prevention systems monitoring the Platform for suspicious activity in real time.
- Secure data centers with physical access controls and environmental safeguards.
Security Incident Response: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 9winph will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012.
While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for keeping your 9winph login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.
Section 10
10. Cookies and Tracking Technologies
9winph uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver relevant content. The following types of cookies are used:
- Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that maintain your login state and security cookies that protect against cross-site request forgery (CSRF). These cookies cannot be disabled.
- Performance and Analytics Cookies: Used to collect anonymized data about how players use the Platform, including pages visited and features used. This data helps us improve the Platform's performance and user experience.
- Functional Cookies: Used to remember your preferences, such as language settings, game preferences, and responsible gaming limit configurations.
- Marketing Cookies: Used to deliver relevant promotional content and track the effectiveness of our marketing campaigns. These cookies are only placed with your consent.
You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies in popular browsers, refer to your browser's help documentation.
Section 11
11. Your Data Protection Rights
Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights with respect to your personal data held by 9winph:
- Right to Be Informed: The right to be informed about how your personal data is collected and processed — which this Policy fulfills.
- Right of Access: The right to request a copy of the personal data 9winph holds about you, along with information about how it is processed.
- Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your account settings.
- Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations and PAGCOR regulatory requirements.
- Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
- Right to Data Portability: 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 Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.
To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.
Section 12
12. Minors and Age Restriction
The 9winph Platform is strictly intended for individuals aged 21 years and above, in accordance with PAGCOR regulations governing online casino gambling in the Philippines. 9winph does not knowingly collect personal data from individuals under the age of 21.
Underage Access: If we become aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately at the details provided in Section 15.
Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gambling platforms. 9winph supports PAGCOR's responsible gaming initiatives and takes its obligations regarding underage gambling prevention seriously.
Section 13
13. International Data Transfers
9winph primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to, or processed by, service providers located outside the Philippines — for example, cloud infrastructure providers or game software developers operating internationally.
Where such transfers occur, 9winph ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to process your data in accordance with standards equivalent to those required by the Data Privacy Act of 2012. We will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining your consent.
Section 14
14. Policy Updates
9winph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. When we make material changes to this Policy, we will notify registered players via email or an in-platform notification prior to the changes taking effect. The "Last Updated" date at the top of this page will be revised accordingly.
Your continued use of the 9winph Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.