9apeso Privacy Policy

1. Introduction and Scope

9apeso ("we", "us", "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the online gaming platform accessible at 9apeso.cam and all associated services (collectively, the "Platform"). This Privacy Policy applies to all personal data collected from registered players ("Users", "you"), visitors to the Platform, and any other individuals whose data is processed by 9apeso in connection with the operation of the Platform.

This Privacy Policy is issued pursuant to the requirements of the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). It is also consistent with the anti-money laundering, know-your-customer, and data security obligations imposed on 9apeso by the Philippine Amusement and Gaming Corporation (PAGCOR) as our regulatory authority.

This Privacy Policy should be read in conjunction with our Terms and Conditions and Responsible Gaming Policy, both of which are incorporated by reference into the overall legal framework governing your relationship with 9apeso.

2. Identity of the Data Controller

For the purposes of the Data Privacy Act of 2012, 9apeso acts as the Personal Information Controller (PIC) with respect to all personal data collected and processed through the Platform. As the PIC, 9apeso determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is conducted lawfully, fairly, and securely.

For all data privacy enquiries, rights requests, and concerns, you may contact our Data Protection Officer (DPO) by sending a written enquiry to:

Email: [email protected]
Subject Line: Data Privacy – [Your Request Type]

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register an account, use our services, or interact with 9apeso in any capacity, we may collect the following categories of personal data that you provide to us directly:

• Identity Data: Full legal name, date of birth, nationality, gender
• Contact Data: Residential address, email address, Philippine mobile telephone number
• Identity Verification Data: Government-issued identification document numbers and copies (e.g., PhilSys ID, Passport, Driver's License, UMID), selfie photographs taken for KYC purposes
• Financial Data: GCash account details, PayMaya account details, bank account information (for withdrawal purposes), transaction history, deposit and withdrawal records
• Account Credentials: Username, encrypted password, security question responses
• Communications Data: Records of your communications with our customer support team via live chat, email, or any other channel
• Responsible Gaming Data: Self-imposed deposit limits, session time preferences, cooling-off requests, self-exclusion requests

3.2 Data Collected Automatically

When you access or use the Platform, certain technical data is collected automatically through your device and browser. This includes:

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, device identifiers
• Usage Data: Pages visited, games played, session duration, bet history, time and frequency of Platform access, search queries within the Platform
• Location Data: General geographic location derived from IP address (used to verify that you are accessing the Platform from within the Philippines, as required by PAGCOR regulations)
• Cookie Data: Information collected through cookies and similar tracking technologies, as described in Section 9 of this Privacy Policy

3.3 Data Received from Third Parties

In certain circumstances, 9apeso may receive personal data about you from third parties, including:

• Payment service providers (GCash, PayMaya, banks) for the purpose of verifying and processing transactions
• Identity verification and KYC service providers for the purpose of confirming your identity and age
• PAGCOR and other regulatory authorities, where we are legally required to receive or share data in connection with regulatory oversight
• Fraud prevention and anti-money laundering screening services

4. Purposes and Legal Bases for Processing

9apeso processes your personal data only for specified, legitimate purposes and on a lawful basis as required by the Data Privacy Act of 2012. The following table describes our primary processing purposes and the corresponding legal basis for each:

• Account Registration and Management: Processing your registration data to create and maintain your 9apeso account. Legal basis: performance of a contract between you and 9apeso.
• Identity Verification (KYC): Verifying your identity, age (21+), and eligibility to use the Platform. Legal basis: legal obligation under PAGCOR regulations and AML compliance requirements.
• Payment Processing: Processing deposits and withdrawals via GCash, PayMaya, and bank transfers. Legal basis: performance of a contract; compliance with financial regulatory obligations.
• Fraud Prevention and Security: Monitoring account activity for suspicious patterns, enforcing the one-account-per-player policy, and protecting the integrity of the Platform. Legal basis: legitimate interest of 9apeso and legal obligation.
• Regulatory Compliance and AML: Conducting anti-money laundering checks, maintaining records as required by PAGCOR and applicable Philippine law, responding to regulatory enquiries. Legal basis: legal obligation.
• Customer Support: Responding to your enquiries, complaints, and requests made through live chat or email. Legal basis: performance of a contract; legitimate interest.
• Responsible Gaming: Monitoring gaming patterns to identify players who may be at risk and implementing self-imposed responsible gaming tools. Legal basis: legal obligation under PAGCOR responsible gaming requirements; protection of vital interests.
• Platform Improvement and Analytics: Analysing usage data to improve the Platform's features, performance, and user experience. Legal basis: legitimate interest of 9apeso.
• Marketing and Promotions: Sending you information about 9apeso promotions, bonuses, and new features that we believe may be of interest to you. Legal basis: consent, which you may withdraw at any time.

5. Disclosure of Personal Data

5.1 Internal Disclosure

Personal data collected by 9apeso is accessible internally only to employees, contractors, and agents who require access to perform their specific job functions — such as customer support, compliance, payments processing, and fraud prevention. All such personnel are subject to binding confidentiality obligations.

5.2 Third-Party Service Providers

9apeso engages third-party service providers who process personal data on our behalf as Personal Information Processors (PIPs) under the Data Privacy Act of 2012. These include:

• Payment processing providers (GCash / Maya / banking partners)
• Identity verification and KYC technology providers
• Cloud hosting and data storage service providers
• Customer support platform providers
• Fraud detection and anti-money laundering screening services
• Analytics and Platform performance monitoring tools

All third-party PIPs engaged by 9apeso are subject to written data processing agreements that require them to process personal data only on documented instructions from 9apeso, implement appropriate technical and organisational security measures, and comply with applicable Philippine data protection law.

5.3 Regulatory and Legal Disclosure

9apeso may be required to disclose your personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), law enforcement authorities, or other competent government bodies in the Philippines where such disclosure is required by applicable law, court order, or legitimate regulatory demand. In all such cases, 9apeso will disclose only the minimum amount of personal data required to satisfy the applicable legal obligation.

5.4 No Sale of Personal Data

9apeso does not sell, rent, or otherwise commercially transfer your personal data to any third party for their own independent marketing or commercial purposes. Your data is not a product at 9apeso.

6. Data Retention

9apeso retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by applicable law and regulation:

• Account and KYC Data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR and AMLC regulations.
• Transaction and Financial Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with Philippine AML record-keeping requirements.
• Customer Support Communications: Retained for two (2) years from the date of the last communication.
• Marketing Preferences and Consent Records: Retained until consent is withdrawn, plus one (1) year for audit purposes.
• Technical and Usage Logs: Retained for up to twelve (12) months unless a longer retention period is required for an active investigation or legal proceeding.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents re-identification.

7. Your Data Subject Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by 9apeso:

• Right to be Informed: The right to know what personal data about you is being collected, how it will be used, and with whom it may be shared — as provided in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data we hold about you and information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure (Right to be Forgotten): 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 overriding legal retention obligations.
• Right to Object: The right to object to processing of your personal data for direct marketing purposes or where processing is based on our legitimate interest.
• Right to Data Portability: The right to receive a copy of personal data you have provided to us in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the contact information provided in Section 2 of this Privacy Policy. We will respond to all verified rights requests within fifteen (15) business days of receipt.

8. Data Security

9apeso implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Encryption of personal data in transit using TLS/SSL technology
• Encryption of sensitive personal data at rest, including financial information and identity document copies
• Access controls limiting personal data access to authorised personnel on a need-to-know basis
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure
• Multi-factor authentication requirements for administrative access to systems holding personal data
• Employee data protection training and confidentiality obligations
• Incident response procedures for prompt detection, containment, and reporting of personal data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 9apeso will notify the National Privacy Commission within 72 hours of becoming aware of the breach and will notify affected Users without undue delay in accordance with NPC Circular No. 16-03.

9. Cookies and Tracking Technologies

9apeso uses cookies and similar tracking technologies (collectively, "Cookies") to operate and improve the Platform, personalise your experience, and gather analytics data. The following categories of Cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session management cookies that keep you logged in and maintain your game state. These cannot be disabled.
• Performance and Analytics Cookies: Collect anonymous information about how Users navigate the Platform, which pages are most visited, and how Users interact with games. Used to improve Platform performance.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations to provide a more personalised experience.
• Security Cookies: Used to detect and prevent fraudulent activity, enforce session limits, and protect account security.

You may control the use of non-essential Cookies through your browser settings or through the Cookie preferences panel available on the Platform. Please note that disabling certain Cookies may affect the functionality of the Platform.

10. Children's Privacy

The 9apeso Platform is strictly prohibited to individuals under the age of 21 years, in accordance with PAGCOR regulations governing casino-style online gaming in the Philippines. 9apeso does not knowingly collect or process personal data from individuals under 21 years of age.

If 9apeso becomes aware that personal data has been collected from a person under the age of 21, that Account will be immediately suspended and all personal data collected from such individual will be securely deleted without delay, subject to any overriding legal obligations to retain records for regulatory or investigative purposes.

11. Changes to This Privacy Policy

9apeso reserves the right to update or modify this Privacy Policy at any time. The "Last Updated" date at the top of this document will reflect the date of the most recent revision. For material changes to this Privacy Policy that affect your rights or the way we use your personal data, we will notify registered Users via email or via a prominent notice on the Platform prior to the change taking effect.

Your continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any changes, you may close your account and request erasure of your personal data, subject to applicable retention obligations.

12. Contact and Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 9apeso, please contact our Data Protection Officer:

Email: [email protected]
Subject Line: Data Privacy Enquiry

If you are not satisfied with our response to your data privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official government website.