9aph Casino Privacy Policy

1. Introduction

1.1 9aph Casino is committed to protecting the privacy and personal data of every Filipino player who registers and plays on the Platform. We understand that trust is foundational to the relationship between 9aph and its members — and that trust depends on our handling your data with integrity, transparency, and care.

1.2 This Policy applies to all personal information collected through: the 9aph website at 9aph.club; account registration and verification processes; deposits, withdrawals, and transaction processing; gameplay activity and session data; customer support interactions; and marketing communications where consent has been provided.

1.3 9aph processes personal data of Filipino residents in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations as administered by the National Privacy Commission of the Philippines.

2. Data Controller

2.1 For the purposes of this Privacy Policy and applicable Philippine data protection law, the Data Controller responsible for your personal information is 9aph Casino, operating the online gaming platform at 9aph.club.

2.2 9aph has designated a Data Protection Officer ("DPO") responsible for overseeing this Policy and compliance with the Philippine Data Privacy Act. You may contact the DPO at any time regarding privacy matters at the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

3.1 Registration Data. When you create a 9aph account, we collect: your legal full name; Philippine mobile number; date of birth; username and encrypted password. This data is required to establish and maintain your account.

3.2 Identity Verification Data (KYC). To comply with anti-money laundering regulations and PAGCOR-aligned KYC requirements, 9aph may collect: a copy of a valid Philippine government-issued photo ID (e.g., PhilSys ID, UMID, driver's license, passport); proof of residential address; selfie or liveness verification photo; and proof of payment method ownership.

3.3 Financial Data. We collect information related to your deposits and withdrawals, including GCash account details, PayMaya account details, BPI/BDO/Metrobank account numbers (truncated), transaction amounts, and transaction history on the 9aph platform.

3.4 Gameplay and Activity Data. 9aph automatically records your gameplay activity, including games played, wager amounts, game session duration, bet history, wins and losses, bonus activations, and VIP tier progression. This data is used for account management, dispute resolution, and platform improvement.

3.5 Technical Data. When you access 9aph, we collect technical data including: IP address; device type, operating system, and browser version; approximate geographic location derived from IP; session timestamps; and platform usage patterns.

3.6 Communications Data. We retain records of your communications with 9aph support, including live chat transcripts, support ticket content, and emails exchanged with the 9aph team.

3.7 Marketing Preferences. Where you have provided consent, we retain records of your marketing opt-in status and communication preferences.

4. How We Use Your Personal Data

4.1 9aph uses the personal data described in Section 3 for the following purposes:

• Account management: creating, maintaining, and managing your 9aph player account
• Transaction processing: processing deposits and withdrawals via GCash, PayMaya, and Philippine bank channels
• Identity verification: KYC and age verification in compliance with PAGCOR-aligned requirements and Philippine AML law
• Fraud prevention and security: detecting and preventing unauthorized access, fraudulent transactions, money laundering, and account abuse
• Legal compliance: fulfilling obligations under Philippine law, including the Anti-Money Laundering Act (AMLA) and the Data Privacy Act
• Customer support: responding to your inquiries, resolving disputes, and improving support quality
• Platform improvement: analyzing usage patterns to enhance the 9aph platform experience
• Marketing communications: where you have provided explicit consent, sending promotional offers, bonus notifications, and 9aph updates
• Responsible gaming: monitoring for indicators of problem gambling and providing appropriate interventions

5. Legal Basis for Processing

5.1 Under the Philippine Data Privacy Act, 9aph processes your personal data on the following legal bases:

• Contract performance: processing necessary to provide the services described in the 9aph Terms & Conditions, including account operation and financial transactions
• Legal obligation: processing required to comply with Philippine law, including KYC, AML, and tax reporting obligations
• Legitimate interests: processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights
• Consent: processing for marketing communications and non-essential cookies, where your explicit consent has been obtained and can be withdrawn at any time

6. Data Sharing and Disclosure

6.1 9aph does not sell, rent, or trade your personal data to any third party for commercial purposes.

6.2 Service Providers. 9aph shares personal data with carefully selected third-party service providers who assist in operating the Platform, including: payment processors (GCash/Maya Philippines Inc., BancNet, InstaPay, PESONet); identity verification and KYC service providers; cloud infrastructure and hosting providers; fraud detection and security analytics providers; and customer support platform providers. All service providers are bound by data processing agreements requiring them to handle your data only as instructed by 9aph and in compliance with applicable law.

6.3 Regulatory Disclosure. 9aph will disclose personal data to Philippine government authorities, law enforcement agencies, or regulatory bodies (including the AMLC, NPC, and PAGCOR) where required by law, court order, or regulatory direction.

6.4 Business Transfers. In the event of a merger, acquisition, or sale of substantially all of 9aph's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

7. Data Retention

7.1 9aph retains personal data for as long as necessary to fulfill the purposes outlined in this Policy, and thereafter for as long as required by applicable Philippine law.

7.2 Active Accounts. Personal data associated with active 9aph accounts is retained for the full duration of the account's existence.

7.3 Closed Accounts. Following account closure, 9aph retains KYC documents, transaction records, and gameplay history for a minimum of five (5) years in compliance with the Philippine Anti-Money Laundering Act (AMLA) record-keeping requirements.

7.4 Marketing Data. Where consent for marketing has been withdrawn, marketing communications will cease within 48 hours of opt-out. Marketing consent records are retained for five (5) years from the date of withdrawal to demonstrate compliance.

7.5 After applicable retention periods, personal data is securely deleted or anonymized so that it can no longer be associated with any individual.

8. Data Security

8.1 9aph implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 9aph servers
• AES-256 encryption for sensitive personal data stored in 9aph databases
• Multi-factor authentication requirements for 9aph administrative access
• Regular penetration testing and security audits by independent cybersecurity firms
• Access controls limiting personal data access to 9aph staff with a legitimate operational need
• Comprehensive staff data privacy training aligned with DPA requirements
• Incident response procedures including mandatory NPC breach notification within 72 hours where required

8.2 While 9aph employs industry-leading security practices, no online platform can guarantee absolute security. You are responsible for maintaining the security of your 9aph login credentials and notifying 9aph immediately of any suspected unauthorized account access.

9. Cookies and Tracking Technologies

9.1 9aph uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies: required for core Platform functionality, including maintaining your login session, processing transactions, and ensuring Platform security. These cannot be disabled.
• Performance and analytics cookies: used to understand how players interact with the 9aph Platform so we can improve its performance and user experience. Data collected is aggregated and anonymized.
• Functional cookies: used to remember your preferences, such as language settings and display options, to provide a more personalized experience.

9.2 9aph does not use third-party advertising cookies or permit third-party advertisers to place tracking technologies on the Platform.

9.3 You may control non-essential cookies through your browser settings. Note that disabling cookies may affect the functionality of certain Platform features. Session cookies are automatically deleted when you close your browser; persistent cookies are retained for defined periods specified in our cookie records.

10. Your Data Subject Rights

10.1 Under the Philippine Data Privacy Act of 2012, 9aph members have the following rights in relation to their personal data:

• Right to be informed: to know what personal data is being collected, how it is being used, and with whom it is being shared
• Right of access: to request a copy of the personal data 9aph holds about you
• Right to rectification: to request correction of inaccurate or incomplete personal data
• Right to erasure: to request deletion of your personal data, subject to applicable legal retention obligations
• Right to data portability: to receive a structured, machine-readable copy of personal data you have provided to 9aph
• Right to object: to object to processing based on legitimate interests, including direct marketing
• Right to lodge a complaint: to file a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph) if you believe your rights have been violated

10.2 To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Privacy Request". 9aph will acknowledge your request within 5 business days and provide a substantive response within 15 business days. Where requests are complex or numerous, this period may be extended to 30 business days with prior notification to you.

11. Children's Privacy

11.1 21+ 9aph does not knowingly collect personal data from individuals under 21 years of age. The Platform is strictly intended for adults who meet the minimum age requirement of 21 years as mandated by Philippine online gaming regulations.

11.2 If 9aph discovers that personal data has been collected from a person under 21 years of age, the associated account will be immediately closed, all balances forfeited, and the personal data deleted in accordance with this Policy and applicable law.

11.3 If you believe that a minor has registered on the 9aph Platform, please contact [email protected] immediately so that we may take appropriate action.

12. International Data Transfers

12.1 9aph primarily stores and processes personal data within the Philippines. In limited circumstances, personal data may be transferred to and processed in countries outside the Philippines, including where 9aph uses cloud service providers or technology partners with infrastructure in other jurisdictions.

12.2 Where personal data is transferred outside the Philippines, 9aph implements appropriate safeguards to ensure that such data receives a standard of protection consistent with the Philippine Data Privacy Act, including execution of standard contractual clauses and data processing agreements with relevant service providers.

13. Changes to This Privacy Policy

13.1 9aph may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or Platform functionality. When material changes are made, 9aph will provide notice via a notification within the Platform or by email to your registered address at least seven (7) days before the revised Policy takes effect.

13.2 The "Last updated" date at the top of this Policy reflects when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how 9aph protects your personal data.

13.3 Continued use of the 9aph Platform following the effective date of a revised Privacy Policy constitutes your acknowledgment of and agreement to the updated Policy.

14. Contact & Data Protection Officer

14.1 For any questions, concerns, or requests relating to this Privacy Policy or 9aph's handling of your personal data, please contact:

14.2 If you are not satisfied with 9aph's response to your privacy inquiry, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. Information on filing a complaint is available at the NPC website.