96phd Privacy Policy

1. Introduction

1.1 96phd is committed to protecting the privacy and personal data of all players and visitors who interact with the Platform. We understand that trust is the foundation of any relationship between a gaming platform and its players, and we take our data protection obligations seriously.

1.2 This Policy applies to all personal data collected by 96phd through the Platform, including data collected during registration, account use, customer support interactions, and marketing communications. It applies to all players located in the Philippines and to any other person whose personal data is processed by 96phd in connection with the Platform.

1.3 This Policy should be read together with our Terms & Conditions, which govern your use of the Platform. In the event of any conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.

2. Data Controller

2.1 For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, 96phd is the personal information controller in respect of the personal data collected through the Platform.

2.2 96phd operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Our data processing activities are conducted in compliance with both PAGCOR requirements and the Data Privacy Act.

2.3 If you have any questions about how 96phd processes your personal data, or if you wish to exercise any of your rights under the Data Privacy Act, please contact our Data Protection Officer using the details set out in Section 15 of this Policy.

3. Personal Data We Collect

3.1 Registration Data. When you create a 96phd account, we collect the following information: full legal name, date of birth, nationality, residential address, email address, mobile phone number, and username.

3.2 Identity Verification Data. To comply with PAGCOR requirements and Philippine anti-money laundering regulations, we may collect copies of government-issued identification documents (such as a Philippine passport, driver's licence, or national ID), proof of address documents, and selfie photographs for identity verification purposes.

3.3 Financial Data. We collect information about your deposits and withdrawals, including payment method details (such as GCash account references, Maya account references, or bank account details), transaction amounts, and transaction history. We do not store full payment card numbers on our servers.

3.4 Gaming Activity Data. We collect records of your gaming activity on the Platform, including games played, wagers placed, outcomes, session durations, and bonus usage. This data is used for regulatory compliance, responsible gaming monitoring, and platform improvement.

3.5 Technical Data. We automatically collect certain technical information when you access the Platform, including your IP address, device type, operating system, browser type and version, and session timestamps.

3.6 Communications Data. We retain records of communications between you and 96phd, including customer support chat logs, emails, and any feedback or complaints you submit.

3.7 Marketing Preferences. If you opt in to marketing communications, we record your preferences and the communications we send to you.

4. How We Collect Your Data

4.1 Directly from you — when you register for an account, complete identity verification, make a deposit or withdrawal, contact customer support, or respond to a survey or promotion.

4.2 Automatically — through cookies, web beacons, and similar tracking technologies when you access and use the Platform. See Section 8 for more information about our use of cookies.

4.3 From third parties — including identity verification service providers, payment processors, and fraud prevention services, where necessary to verify your identity or process your transactions.

4.4 From regulatory authorities — including PAGCOR and the Anti-Money Laundering Council (AMLC), where required by law.

5. How We Use Your Personal Data

5.1 96phd uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your 96phd account;
• Identity verification: To verify your identity and age (21+) as required by PAGCOR regulations;
• Transaction processing: To process deposits, withdrawals, and bonus payments in Philippine Peso;
• Regulatory compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act, and other applicable Philippine laws;
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to enforce self-exclusion and deposit limit requests;
• Fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct;
• Customer support: To respond to your enquiries, complaints, and support requests;
• Platform improvement: To analyse usage patterns and improve the features, performance, and security of the Platform;
• Marketing: To send you promotional offers and updates about 96phd, where you have consented to receive such communications.

6. Legal Basis for Processing

6.1 96phd processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: Processing necessary to perform our contract with you (i.e., to operate your 96phd account and provide gaming services);
• Legal obligation: Processing necessary to comply with our obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act;
• Legitimate interests: Processing necessary for our legitimate interests in preventing fraud, ensuring platform security, and improving our services, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent, particularly in relation to marketing communications.

7. Sharing Your Personal Data

7.1 96phd does not sell, rent, or trade your personal data to third-party marketers under any circumstances.

7.2 We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law;
• Payment processors: GCash, Maya, and Philippine banking partners, to process your deposits and withdrawals;
• Identity verification providers: Third-party KYC (Know Your Customer) service providers engaged to verify your identity documents;
• Fraud prevention services: Third-party providers engaged to detect and prevent fraudulent activity on the Platform;
• Technology providers: Cloud hosting, platform infrastructure, and security service providers who process data on our behalf under strict data processing agreements;
• Game providers: Third-party game studios whose games are available on the Platform, to the extent necessary to deliver those games to you.

7.3 All third parties with whom 96phd shares personal data are required to process that data in accordance with the Philippine Data Privacy Act and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

8. Cookies and Tracking Technologies

8.1 96phd uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how the Platform is used.

8.2 We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled without affecting core functionality, such as maintaining your login session;
• Performance cookies: Used to collect anonymised data about how players use the Platform, helping us identify and fix performance issues;
• Functional cookies: Used to remember your preferences, such as language settings and display options;
• Analytics cookies: Used to understand aggregate usage patterns and improve the Platform experience.

8.3 You can control cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Your continued use of the Platform following our cookie notice constitutes your consent to our use of cookies as described in this Policy.

9. Data Security

9.1 96phd implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Access controls limiting personal data access to authorised personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Staff training on data protection and information security obligations.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 96phd will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act.

9.3 While 96phd takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for keeping your 96phd login credentials confidential and for notifying us immediately of any suspected unauthorised access to your account.

10. Data Retention

10.1 96phd retains your personal data for as long as your account remains active and for such additional period as is necessary to comply with our legal and regulatory obligations.

10.2 Specifically, we retain:

• Account and identity data: For the duration of your account and for a minimum of five (5) years after account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Transaction records: For a minimum of five (5) years from the date of the transaction, in accordance with Philippine anti-money laundering requirements;
• Customer support records: For three (3) years from the date of the interaction;
• Marketing preference records: Until you withdraw your consent or for three (3) years from your last interaction with 96phd, whichever is earlier.

10.3 When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, 96phd will securely delete or anonymise that data.

11. Your Rights as a Data Subject

11.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 96phd:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy;
• Right of access: The right to request a copy of the personal data 96phd holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to our legal and regulatory retention obligations;
• Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation, or to object to processing for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

11.2 To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. We will respond to your request within thirty (30) days. In complex cases, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.

11.3 Please note that some rights are subject to limitations. For example, we may be unable to delete personal data that we are required to retain by law or that is necessary to defend a legal claim.

12. Children's Privacy and Age Restriction

12.1 The 96phd Platform is strictly for persons aged twenty-one (21) years and above. 96phd does not knowingly collect personal data from persons under 21 years of age.

12.2 If we become aware that we have inadvertently collected personal data from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a person under 21 has registered on the Platform, please contact us immediately at the details in Section 15.

13. Third-Party Links

13.1 The Platform may contain links to third-party websites or services. This Privacy Policy applies only to the 96phd Platform. 96phd is not responsible for the privacy practices of any third-party websites, and we encourage you to review the privacy policies of any third-party sites you visit.

14. Amendments to This Policy

14.1 96phd reserves the right to amend this Privacy Policy at any time. We will notify registered players of material changes via email or through a prominent notice on the Platform prior to the changes taking effect.

14.2 The date of the most recent revision is displayed at the top of this Policy. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

14.3 If you do not agree to any amended Policy, you must cease using the Platform and may close your account in accordance with our Terms & Conditions.

15. Contact and Data Protection Officer

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 96phd, please contact our Data Protection Officer:

15.2 Email: [email protected]

15.3 General support: [email protected]

15.4 You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 96phd has not handled your personal data in accordance with the Data Privacy Act.