Privacy Policy — 96phd Data Protection

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by 96phd through our website, mobile application, customer support channels, and any other services we provide. By creating a 96phd account or using our services, you consent to the collection, use, and processing of your personal information as described in this policy.

96phd operates in full compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and all implementing rules and regulations issued by the National Privacy Commission (NPC) of the Philippines. We are also subject to PAGCOR's data protection requirements for licensed online gaming operators.

This Privacy Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy. If you have questions about how we handle your personal data, please contact our Data Protection Officer at [email protected].

2. Information We Collect

2.1 Information You Provide Directly

When you register an account with 96phd, we collect personal information that you provide voluntarily, including:

• Identity Information: Full legal name, date of birth, nationality, government-issued identification numbers (as required for verification)
• Contact Information: Email address, mobile phone number, residential address, postal code
• Account Credentials: Username, password (stored in encrypted form), security questions and answers
• Financial Information: Payment method details (GCash mobile number, bank account information, e-wallet details), transaction history, deposit and withdrawal records
• Verification Documents: Copies of government-issued IDs (passport, driver's license, UMID, postal ID), proof of address documents, selfie photos for identity verification
• Communication Records: Customer support chat transcripts, emails, phone call recordings (where permitted by law)

2.2 Information Collected Automatically

When you use 96phd services, we automatically collect certain technical and usage information:

• Device Information: IP address, device type, operating system, browser type and version, mobile device identifiers
• Usage Data: Pages visited, games played, bet amounts, win/loss records, session duration, click patterns, timestamps
• Location Data: General geographic location derived from IP address to verify Philippine residency and comply with jurisdictional restrictions
• Cookies and Tracking Technologies: Session cookies, preference cookies, analytics cookies, and similar technologies (see Section 8 for details)
• Geolocation Data: If you grant permission through our mobile app, we may collect precise location data to verify that you are accessing our services from within the Philippines

2.3 Information from Third Parties

In certain circumstances, 96phd receives information from third-party sources:

• Payment Processors: Transaction confirmation, payment method verification from GCash, Maya, banks, and other financial service providers
• Identity Verification Services: Age verification, identity authentication, and fraud prevention data from third-party verification providers
• Affiliate Partners: Referral information if you signed up through an affiliate link
• Social Media Platforms: If you choose to register using social media login, we receive basic profile information as permitted by the platform

3. How We Use Your Information

96phd processes your personal data for the following lawful purposes:

3.1 Account Management and Service Provision

• Creating and maintaining your player account
• Processing deposits, withdrawals, and financial transactions
• Providing access to games, sports betting, and other gaming services
• Recording and tracking your gaming activity, betting history, and account balance
• Delivering customer support and responding to inquiries

3.2 Legal and Regulatory Compliance

• Verifying your age (21+ requirement) and identity to comply with PAGCOR regulations
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by law
• Maintaining records for auditing and regulatory reporting purposes
• Responding to lawful requests from government authorities, courts, or law enforcement agencies
• Enforcing our Terms & Conditions and preventing terms violations

3.3 Fraud Prevention and Security

• Detecting and preventing fraudulent transactions, money laundering, and unauthorized account access
• Identifying suspicious betting patterns, collusion, or bonus abuse
• Protecting against cyber attacks, hacking attempts, and security threats
• Monitoring for underage gambling attempts and self-excluded users

3.4 Marketing and Communications (With Your Consent)

• Sending promotional offers, bonus notifications, and personalized gaming recommendations
• Delivering newsletters, updates about new games, and platform improvements
• Conducting market research and customer satisfaction surveys

Note: You may opt out of marketing communications at any time by adjusting your account preferences or clicking the unsubscribe link in our emails. Transactional and service-related communications cannot be opted out of.

3.5 Platform Improvement and Analytics

• Analyzing user behavior to improve website functionality and user experience
• Testing new features, games, and service enhancements
• Generating aggregated, anonymized statistical data for business intelligence purposes

3.6 Responsible Gaming

• Monitoring for signs of problem gambling behavior
• Implementing and enforcing deposit limits, session time limits, and self-exclusion requests
• Providing responsible gaming tools and support resources

4. Legal Basis for Processing

Under the Philippine Data Privacy Act, 96phd processes your personal data based on the following legal grounds:

Legal Basis	Processing Activities
Consent	Marketing communications, personalized offers, optional data collection (e.g., precise geolocation via mobile app)
Contractual Necessity	Account creation, game provision, payment processing, fulfilling our obligations under the Terms & Conditions
Legal Obligation	Age verification, KYC/AML compliance, PAGCOR regulatory reporting, responding to lawful government requests
Legitimate Interest	Fraud prevention, platform security, customer support, analytics for service improvement, responsible gaming monitoring

5. Data Sharing and Disclosure

96phd does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with the following categories of recipients under strict confidentiality obligations:

5.1 Service Providers and Business Partners

• Payment Processors: GCash, Maya, banks, and payment gateway providers to process deposits and withdrawals
• Game Providers: Evolution Gaming, Pragmatic Play, PG Soft, and other licensed game suppliers to deliver gaming content
• Identity Verification Services: Third-party KYC and age verification providers
• Cloud Hosting Providers: Secure data storage and server infrastructure providers
• Customer Support Platforms: Live chat and helpdesk software providers
• Marketing Service Providers: Email delivery services, SMS gateway providers (only if you opted in to marketing)

5.2 Regulatory and Legal Authorities

• PAGCOR: Regulatory reports, compliance audits, and licensing requirements
• Law Enforcement: When required by valid court order, subpoena, or legal process
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports as mandated by law
• National Privacy Commission: In response to data privacy complaints or investigations

5.3 Corporate Transactions

In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity. You will be notified of any such change in ownership or control of your personal information.

5.4 Data Transfer Outside the Philippines

Some of our service providers (e.g., cloud hosting, game providers) may process data on servers located outside the Philippines. In such cases, 96phd ensures that adequate safeguards are in place, including:

• Data processing agreements that comply with Philippine data protection standards
• Transfer to jurisdictions with adequate data protection laws as recognized by the NPC
• Implementation of technical and organizational security measures equivalent to Philippine standards

6. Data Security Measures

96phd implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

6.1 Technical Security

• Encryption: All data transmitted between your device and our servers is protected using TLS/SSL encryption
• Password Protection: Passwords are hashed using strong cryptographic algorithms and never stored in plain text
• Firewall Protection: Network firewalls and intrusion detection systems monitor and block unauthorized access attempts
• Secure Data Centers: Data is stored in secure, access-controlled data centers with 24/7 monitoring
• Regular Security Audits: Third-party penetration testing and vulnerability assessments are conducted regularly

6.2 Organizational Security

• Access Controls: Personal data is accessible only to authorized employees on a need-to-know basis
• Employee Training: All staff undergo data privacy and security awareness training
• Confidentiality Agreements: Employees and contractors are bound by strict confidentiality obligations
• Incident Response Plan: We maintain procedures for detecting, responding to, and reporting data breaches

6.3 Data Breach Notification

In the event of a data breach that is reasonably believed to have caused or will cause harm to you, 96phd will notify affected users and the National Privacy Commission within 72 hours of discovery, as required by the Data Privacy Act. Notifications will include the nature of the breach, types of data affected, and steps being taken to mitigate harm.

7. Data Retention

96phd retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and resolve disputes.

7.1 Active Account Data

While your account is active, we retain all account information, transaction records, and gaming history to provide ongoing services and maintain accurate records.

7.2 Closed Account Data

After voluntary account closure, 96phd retains your personal data for the following minimum periods as required by PAGCOR and Philippine law:

• Financial Records: 5 years (as required by Anti-Money Laundering regulations)
• Identity Verification Documents: 5 years (as required by PAGCOR licensing conditions)
• Gaming Transaction History: 5 years (for audit and dispute resolution purposes)
• Communication Records: 3 years (for customer service quality and dispute resolution)
• Marketing Preferences: Indefinitely, or until you request deletion (to honor opt-out requests)

7.3 Self-Excluded Users

If you self-exclude from 96phd for responsible gaming reasons, we retain your personal information indefinitely to prevent you from creating new accounts during the exclusion period, as required by responsible gaming regulations.

7.4 Data Deletion

After the applicable retention period expires, your personal data will be securely deleted or anonymized such that it can no longer be associated with you. Anonymized data may be retained indefinitely for statistical and analytical purposes.

8. Cookies and Tracking Technologies

96phd uses cookies, web beacons, and similar tracking technologies to enhance your user experience, analyze platform usage, and deliver personalized content.

8.1 Types of Cookies We Use

• Essential Cookies: Required for basic website functionality, including login authentication, session management, and security features. These cookies cannot be disabled.
• Performance Cookies: Collect anonymous data about how visitors use our site, which pages are most popular, and error messages encountered. Used for analytics and platform improvement.
• Functionality Cookies: Remember your preferences (language, display settings) to provide a personalized experience on return visits.
• Marketing Cookies: Track your activity across websites to deliver targeted advertising and personalized offers. These cookies require your consent.

8.2 Managing Cookie Preferences

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or receive notifications when cookies are set. However, disabling essential cookies may limit your ability to use certain features of 96phd services.

To opt out of marketing cookies specifically, adjust your preferences in your 96phd account settings or use the cookie consent banner that appears on your first visit.

8.3 Third-Party Cookies

Some cookies on 96phd are set by third-party service providers, including analytics platforms (Google Analytics), payment processors, and game providers. These third parties have their own privacy policies governing their use of cookies.

9. Your Privacy Rights

Under the Philippine Data Privacy Act, you have the following rights regarding your personal data:

9.1 Right to Access

You have the right to request confirmation of whether we are processing your personal data and to obtain a copy of your data. You can access most of your account information directly by logging into your 96phd account.

9.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. You can update most information directly through your account settings. For information that cannot be self-edited, contact customer support.

9.3 Right to Erasure ("Right to Be Forgotten")

You may request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected. However, this right is subject to legal retention requirements (see Section 7). We may retain data required for compliance with PAGCOR regulations, AML laws, or to defend against legal claims.

9.4 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes at any time. You can opt out by adjusting your communication preferences in your account settings or clicking unsubscribe links in marketing emails.

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another service provider where technically feasible.

9.6 Right to Withdraw Consent

Where processing is based on your consent (e.g., marketing communications), you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

9.7 Right to File a Complaint

If you believe 96phd has violated your data privacy rights, you have the right to file a complaint with the National Privacy Commission of the Philippines. Contact details for the NPC are available at privacy.gov.ph.

9.8 Exercising Your Rights

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will respond to your request within 30 days as required by law. Verification of your identity may be required before we process your request.

10. Children's Privacy

96phd services are strictly intended for individuals aged 21 years and older. We do not knowingly collect personal information from anyone under the age of 21. If we become aware that we have inadvertently collected data from a person under 21, we will take immediate steps to delete that information and close the associated account.

Parents or guardians who believe their child has provided personal information to 96phd should contact us immediately at [email protected]. We will investigate and take appropriate action in accordance with Philippine law and PAGCOR regulations.

11. Changes to This Privacy Policy

96phd reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or for other operational, legal, or regulatory reasons. When we make material changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you via email or through a prominent notice on our website
• Request your consent where required by law

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Continued use of 96phd services after changes have been posted constitutes acceptance of the updated policy.

12. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

Data Protection Officer

Email: [email protected]

Subject Line: Data Privacy Inquiry

Customer Support

24/7 Live Chat available on 96phd.cam

Regulatory Authority

National Privacy Commission (NPC)
Website: privacy.gov.ph
For complaints regarding data privacy violations

We are committed to addressing your privacy concerns promptly and in accordance with Philippine law. Your privacy matters to us, and we strive to maintain the highest standards of data protection in the online gaming industry.