p9ph Privacy Policy

p9ph operates the online gaming platform accessible at p9ph.club ("the Platform"), which offers live casino games, slots, bingo, Teen Patti, sports betting, and related services to players in the Philippines. In this Privacy Policy, references to "p9ph," "we," "us," or "our" refer to the operator of p9ph.club as the data controller responsible for your personal data.

p9ph is committed to protecting your privacy and processing your personal data responsibly, transparently, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). p9ph also operates within the framework of guidelines issued by the Philippine Amusement and Gaming Corporation (PAGCOR), which impose additional data handling obligations on licensed or regulated online gaming operators serving Filipino players.

This Privacy Policy applies to all personal data collected through p9ph.club, including during account registration, KYC verification, gameplay, payment processing, customer support interactions, promotional communications, and regular use of the platform. By creating a p9ph account or using any part of the platform, you acknowledge that you have read this Privacy Policy and consent to the collection and processing of your personal data as described herein.

p9ph collects personal data in several categories depending on how you interact with the platform. The table below summarises the types of data collected and their primary purpose:

p9ph does not collect sensitive personal information (as defined under RA 10173 — such as health data, political affiliations, or religious beliefs) unless explicitly required by law or PAGCOR regulations and with your prior written consent.

p9ph collects personal data through the following channels and mechanisms:

• Direct Collection: Information you provide when registering a p9ph account, completing KYC verification, making deposits or withdrawals, participating in promotions, contacting customer support, or responding to surveys.
• Automated Collection: Technical data collected automatically when you access p9ph.club, including your IP address, device identifiers, browser type, session logs, and page interaction data gathered through server logs and first-party analytics tools.
• Cookies and Similar Technologies: p9ph uses first-party cookies and similar tracking technologies to maintain session state, remember your preferences, and measure platform performance. See Section 9 for full details on cookie use.
• Third-Party Sources: p9ph may receive data about you from third-party identity verification providers engaged for KYC compliance, payment processors (such as GCash's parent entity Maya Philippines, BDO, BPI, etc.) in the course of processing transactions, and fraud detection services used to protect the platform and its players.
• Regulatory Bodies: In limited circumstances, p9ph may receive data from PAGCOR or other Philippine regulatory authorities as part of its compliance obligations.

p9ph uses your personal data only for specified, legitimate purposes. We do not process your data in a manner incompatible with the purposes for which it was originally collected. The primary purposes for which p9ph processes personal data are:

1. Account Management: Creating, maintaining, and managing your p9ph account, including verifying your identity and age (minimum 21 years old as required by PAGCOR), processing your login credentials, and communicating important account information.
2. Payment Processing: Facilitating deposits and withdrawals through your preferred Philippine payment method (GCash, PayMaya, BDO, BPI, Metrobank, UnionBank, 7-Eleven, Cebuana), verifying that payment accounts belong to you, and maintaining financial records.
3. Legal and Regulatory Compliance: Fulfilling p9ph's obligations under Philippine law and PAGCOR regulations, including Know Your Customer (KYC) procedures, Anti-Money Laundering Act (AMLA) reporting, age verification, and responding to lawful data requests from regulatory authorities.
4. Fraud Prevention and Platform Security: Detecting, investigating, and preventing fraudulent transactions, money laundering, account sharing, multi-accounting, bonus abuse, and other activities that violate p9ph's Terms & Conditions or Philippine law.
5. Responsible Gaming: Monitoring gaming activity to identify patterns consistent with problem gambling behaviour, enforcing deposit limits and self-exclusion requests, and ensuring compliance with p9ph's responsible gaming obligations under PAGCOR guidelines.
6. Customer Support: Responding to your enquiries, resolving disputes, processing complaints, and maintaining records of support interactions for quality assurance purposes.
7. Platform Improvement: Analysing aggregated, anonymised usage data to improve game selection, platform performance, and user experience for Filipino players.
8. Marketing and Promotions: Sending you information about p9ph bonuses, promotions, and new games via SMS or email — but only if you have opted in to receive such communications. You may opt out at any time.

Under the Philippine Data Privacy Act and its Implementing Rules, p9ph processes your personal data on the following lawful bases:

• Contractual Necessity: Processing required to perform the contract with you — i.e., to operate your p9ph account, process your transactions, and provide gaming services as agreed in the Terms & Conditions.
• Legal Obligation: Processing necessary to comply with PAGCOR regulations, the Anti-Money Laundering Act, the Philippine Data Privacy Act, National Privacy Commission issuances, and other applicable Philippine laws.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improving the p9ph platform — where such interests are not overridden by your data protection rights.
• Consent: Processing for optional purposes such as marketing communications and certain analytics activities — where we rely on your freely given, specific, informed consent, which you may withdraw at any time without affecting the lawfulness of processing prior to withdrawal.

p9ph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Ever. We share your personal data only in the following circumstances and only to the extent strictly necessary:

• Payment Processors: We share financial data (transaction amounts, account identifiers) with your chosen payment provider — GCash, PayMaya, BDO, BPI, Metrobank, UnionBank, 7-Eleven, or Cebuana Lhuillier — solely to process deposits and withdrawals. These providers are bound by their own data protection obligations under Philippine law.
• KYC and Identity Verification Providers: We engage accredited third-party identity verification services to assist with PAGCOR-mandated KYC processes. These providers receive only the data necessary for identity verification and are bound by strict data processing agreements.
• Game Software Providers: Providers of casino games, slots, and live dealer content hosted on the p9ph platform may receive anonymised or pseudonymised gameplay data for the purpose of game functionality and technical support.
• Regulatory Authorities: p9ph is required by law to provide certain player data and transaction records to PAGCOR and, where applicable, to the Anti-Money Laundering Council (AMLC) and the National Privacy Commission upon lawful request.
• Fraud Prevention Services: We use regulated third-party fraud detection and risk management services that may process technical and transaction data to identify suspicious activity. These services do not use your data for any purpose other than fraud prevention on behalf of p9ph.
• Legal Proceedings: We may disclose your data to courts, law enforcement agencies, or legal advisers where required by a lawful court order, warrant, or legal obligation under Philippine law.

All third parties with whom p9ph shares personal data are contractually required to process it lawfully, securely, and only for the purposes for which it was shared.

p9ph retains your personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required by law or PAGCOR regulations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your p9ph account's active status.
• Account Closure: Following account closure, p9ph retains identity and transaction data for a minimum of five (5) years to comply with AMLA record-keeping obligations and PAGCOR requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with the Anti-Money Laundering Act and its implementing regulations.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship with the player, or longer if required by a regulatory authority.
• Customer Support Records: Retained for three (3) years from the date of the interaction, unless a longer period is required for an ongoing dispute or legal proceeding.
• Marketing Data: Retained until you opt out of marketing communications or request deletion, after which it is removed from active marketing lists within 30 days.

When data is no longer required and no legal retention obligation applies, p9ph securely deletes or anonymises it so that it can no longer be linked to you as an individual.

p9ph takes the security of your personal data seriously and implements appropriate technical and organisational measures to protect it against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your browser/app and p9ph servers is encrypted using 256-bit TLS/SSL protocols — the same standard used by major Philippine banks.
• Encryption at Rest: Sensitive personal data (including identity documents and financial records) is encrypted at rest in p9ph's data storage systems.
• Access Controls: Access to personal data within p9ph is restricted on a strict need-to-know basis. Staff with access to personal data are bound by confidentiality obligations and receive regular data privacy training.
• Password Security: p9ph stores all user passwords using industry-standard one-way hashing algorithms. Your actual password is never stored in recoverable form.
• Two-Factor Authentication: SMS OTP verification is applied to login attempts from unrecognised devices and to sensitive account actions such as password changes and withdrawal requests.
• Regular Security Audits: p9ph conducts regular security reviews and vulnerability assessments of its platform and data systems.

In the event of a personal data breach that poses a real risk to your rights and freedoms, p9ph will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay in accordance with the requirements of the Philippine Data Privacy Act.

p9ph uses cookies and similar technologies on p9ph.club to ensure the platform functions correctly, to remember your preferences, and to understand how Filipino players use the site so we can improve it. A cookie is a small text file stored in your browser when you visit a website. p9ph uses the following categories of cookies:

• Strictly Necessary Cookies: These are essential for the platform to function. They maintain your login session, keep your wallet secure between pages, and remember your language and region settings. These cookies cannot be disabled without preventing the platform from working correctly.
• Functional Cookies: These remember your preferences (such as your preferred game category or deposit method) to provide a personalised experience on return visits. They are not required but enhance your experience.
• Performance and Analytics Cookies: First-party analytics cookies collect anonymised data on how pages are used — such as which games are most popular and where players spend time — to help p9ph improve the platform. This data cannot be linked back to you personally.
• Session Security Cookies: Short-lived cookies used to detect suspicious login activity and verify that each request comes from an authentic p9ph session.

p9ph does not use third-party advertising cookies or permit third-party advertisers to place cookies on p9ph.club. You can manage or delete cookies through your browser settings. Disabling strictly necessary cookies will impair the functionality of the platform and may prevent you from accessing your account.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by p9ph. To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Privacy Request" and include your registered mobile number or username for account identification. p9ph will respond to all verified data rights requests within thirty (30) calendar days.