a9ph Privacy Policy

1. Data Controller Information

a9ph operates as the data controller for all personal information collected through the a9ph platform. As data controller, a9ph determines the purposes and means by which your personal data is processed. a9ph is committed to processing your personal data in a lawful, fair, and transparent manner, in full compliance with the Republic Act No. 10173 (Data Privacy Act of 2012) of the Philippines and the regulations issued by the National Privacy Commission (NPC).

If you have any questions, concerns, or requests relating to the processing of your personal data by a9ph, you may contact our Data Protection Officer via email at [email protected] or through the live chat function available inside your a9ph account dashboard.

2. Data We Collect

a9ph collects the following categories of personal data from registered players and platform visitors:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (used for age verification – players must be 21 years or older)
• Residential address, including barangay, city or municipality, province, and postal code
• Email address used for account registration and communications
• Mobile phone number registered to your a9ph account
• Government-issued identification document details (e.g., Philippine passport, driver's license, SSS/UMID card) submitted during KYC verification

2.2 Financial Data

• Payment method details used for deposits and withdrawals (e.g., GCash mobile number, PayMaya account reference, bank account name and number for BPI, BDO, or Metrobank)
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references
• Account balance history and bonus credit records

2.3 Gaming and Activity Data

• Game session history, including games played, wager amounts, outcomes, and session duration
• Bonus and promotion usage history
• Responsible gaming tool settings, including deposit limits, loss limits, and self-exclusion records
• Customer support interaction records, including chat transcripts and email correspondence

2.4 Technical and Device Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser type and version
• Session timestamps and login history
• Cookie identifiers and similar tracking data (see Section 7 for full details)

3. How We Collect Your Data

a9ph collects your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or updating your account profile.
• Automated collection: Technical and device data collected automatically when you access the a9ph platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers, fraud prevention data from security partners, and payment verification data from payment processors such as GCash and PayMaya.

4. How We Use Your Data

a9ph uses the personal data it collects for the following purposes:

Purpose	Data Used
Account registration and management	Identity data, contact data
Age and identity verification (KYC)	Identity data, government ID details
Processing deposits and withdrawals	Financial data, identity data
Delivering and improving gaming services	Gaming data, technical data
Fraud prevention and security monitoring	All categories of data
Responsible gaming monitoring and tools	Gaming data, financial data
Customer support and dispute resolution	Identity data, gaming data, support records
Regulatory compliance and reporting	Identity data, financial data, gaming data
Platform analytics and performance improvement	Technical data, gaming data (aggregated)
Sending account-related communications	Contact data

a9ph does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have provided explicit consent.

5. Legal Basis for Processing

a9ph processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its implementing rules and regulations:

• Contractual necessity: Processing required to fulfill the contract between you and a9ph, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) requirements, gaming regulations, and tax reporting obligations.
• Legitimate interests: Processing carried out for a9ph's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for the receipt of promotional communications. You may withdraw consent at any time by contacting a9ph support.

6. Data Sharing and Disclosure

6.1 Third-Party Service Providers

a9ph may share your personal data with carefully selected third-party service providers who assist in operating the a9ph platform. These include KYC and identity verification providers, payment processors (including GCash, PayMaya, and banking partners), fraud detection and security service providers, cloud hosting and infrastructure providers, and customer support platform providers. All third-party service providers are contractually required to process your data only on a9ph's instructions and to maintain appropriate security measures.

6.2 Regulatory and Legal Disclosure

a9ph may disclose your personal data to regulatory authorities, law enforcement agencies, or other government bodies where required to do so by applicable Philippine law, court order, or regulatory directive. This includes disclosures required under the Anti-Money Laundering Act (AMLA) and its amendments, gaming regulatory requirements, and any other applicable legal obligation.

6.3 No Sale of Personal Data

a9ph does not sell, rent, lease, or otherwise transfer your personal data to third parties for their own commercial or marketing purposes. Any sharing of data is limited to what is strictly necessary for the purposes described in this Privacy Policy.

7. Cookies and Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device when you visit the a9ph platform. They allow the platform to recognize your device, remember your preferences, and provide a more personalized and functional experience. a9ph also uses similar technologies such as web beacons and local storage for related purposes.

7.2 Types of Cookies Used by a9ph

• Strictly necessary cookies: Required for the platform to function. These include session cookies that keep you logged in and security cookies that protect against fraudulent activity. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, game lobby filters, and responsible gaming tool configurations.
• Analytics cookies: Collect aggregated, anonymized data about how players use the a9ph platform, helping us identify areas for improvement. No personally identifiable information is included in analytics reports.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and other security threats to your account and the platform.

7.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the a9ph platform, including your ability to stay logged in or access certain game features. Strictly necessary cookies cannot be disabled as they are essential to the operation of the platform.

8. Data Retention

a9ph retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering regulations and gaming regulatory requirements.
• Financial transaction data: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine financial regulations.
• Gaming activity data: Retained for a minimum of three (3) years from the date of each session, for regulatory compliance and dispute resolution purposes.
• Customer support records: Retained for a minimum of two (2) years from the date of each interaction.
• Technical and device data: Retained for up to twelve (12) months from collection, unless required for longer retention for security or fraud investigation purposes.

Upon expiry of the applicable retention period, a9ph will securely delete or anonymize your personal data in accordance with its data disposal procedures.

9. Data Security

a9ph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the a9ph platform.
• Encryption of sensitive data at rest, including identity documents and financial records.
• Role-based access controls limiting access to personal data to authorized a9ph personnel on a need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of the a9ph platform and infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and responding to personal data breaches in accordance with NPC notification requirements.

While a9ph takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your a9ph account login credentials and for notifying a9ph immediately if you suspect any unauthorized access to your account.

10. Your Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by a9ph:

• Right to be informed: The right to be notified of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data that a9ph holds about you.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held by a9ph.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to a9ph's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used format 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 that a9ph has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact the a9ph Data Protection Officer via email at [email protected] or through the live chat function in your account dashboard. a9ph will respond to all data rights requests within thirty (30) days of receipt, in accordance with NPC guidelines.

11. Children and Minors

The a9ph platform is strictly restricted to individuals who are 21 years of age or older, in accordance with applicable Philippine gaming regulations. a9ph does not knowingly collect personal data from individuals under the age of 21. If a9ph becomes aware that personal data has been collected from a minor, the relevant account will be immediately suspended, all data will be deleted, and any deposits will be returned in accordance with a9ph's minor account procedures. If you believe that a minor has registered an account on a9ph, please contact the support team immediately at [email protected].

12. Changes to This Policy

a9ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or the way a9ph processes personal data. Where changes are material, a9ph will notify registered players via email or a prominent notice on the platform prior to the changes taking effect. The effective date at the top of this Privacy Policy will be updated to reflect the date of the most recent revision. Your continued use of the a9ph platform following the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by a9ph, please contact us through the following channels:

• Live Chat: Available 24/7 inside your a9ph account dashboard — the fastest way to reach our support team.
• Email: [email protected] — for data rights requests, privacy concerns, and formal complaints.

For complaints that cannot be resolved directly with a9ph, you may contact the National Privacy Commission of the Philippines through their official channels. a9ph is committed to working cooperatively with the NPC to resolve any privacy concerns raised by our players.