Privacy Policy for 9aplay

01Introduction

9aplay ("9aplay," "we," "us," "our") operates the online gaming platform accessible at https://9aplay.cam. We respect your right to privacy and are committed to protecting the personal information of every Filipino player who registers, visits, or engages with our platform. This Privacy Policy ("Policy") describes in detail what personal data 9aplay collects, why we collect it, how it is used and protected, with whom it may be shared, how long it is retained, and what rights you hold over your information under Philippine law.

This Policy applies to all personal data collected through the 9aplay website, any mobile-optimised version of the platform, customer support interactions, and any other channel through which you communicate with 9aplay. By registering a 9aplay account or by continuing to use our Services, you acknowledge that you have read and understood this Policy.

02Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, 9aplay is the personal information controller responsible for your data collected through the 9aplay platform.

Our designated Data Protection Officer (DPO) oversees all data protection activities and is the point of contact for privacy-related inquiries, data subject requests, and regulatory notifications. Contact details for the DPO are provided in Section 15 of this Policy.

03Personal Data We Collect

9aplay collects personal information in several categories depending on how you interact with the platform. The table below summarises the primary data categories and collection sources.

3.1 Sensitive Personal Information

9aplay may process certain categories of sensitive personal information as defined under the Philippine Data Privacy Act, specifically government-issued identification numbers required for KYC compliance. Such data is handled with enhanced security controls, accessed only by authorised personnel performing verification duties, and processed solely for the purposes stated in this Policy.

3.2 Data We Do Not Collect

9aplay does not knowingly collect biometric data, genetic data, religious beliefs, political opinions, or health information unless such data is incidentally present in an identification document submitted during KYC, in which case it is not separately processed or stored beyond the document itself.

04How We Use Your Personal Data

9aplay processes your personal data for the following purposes:

• Account Management: Creating, maintaining, verifying, and administering your 9aplay account, including processing your registration, authenticating your login sessions, and communicating account-related notices.
• Service Delivery: Enabling access to all 9aplay games and features, processing wagers and game outcomes, calculating and crediting winnings, and maintaining your account balance.
• Financial Transactions: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other accepted Philippine payment channels; reconciling transaction records; and maintaining financial audit trails.
• KYC and Identity Verification: Verifying player identity before processing withdrawals, confirming age eligibility (21+ requirement), and fulfilling obligations under Philippine anti-money laundering regulations.
• Legal and Regulatory Compliance: Meeting obligations under the Philippine Data Privacy Act (RA 10173), PAGCOR operational requirements, the Anti-Money Laundering Act (AMLA), and other applicable Philippine legislation.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, bonus abuse, collusion, and other prohibited conduct described in the 9aplay Terms & Conditions.
• Responsible Gaming: Monitoring gameplay patterns to identify potential problem gambling indicators and administering player-requested deposit limits, session controls, and self-exclusion arrangements.
• Customer Support: Responding to player inquiries, resolving complaints, and maintaining support interaction records for quality assurance and dispute resolution.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. Players may withdraw consent for marketing communications at any time via account settings.
• Platform Improvement: Analysing aggregated, anonymised usage data to identify technical issues, improve game performance, and enhance the overall player experience on the 9aplay platform.

05Legal Basis for Processing

Under the Philippine Data Privacy Act, 9aplay processes your personal data on the following legal bases:

1. Contractual Necessity: Processing required to perform our obligations under the 9aplay Terms & Conditions — including account management, game delivery, and payment processing.
2. Legal Obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR requirements, and the Data Privacy Act itself.
3. Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are balanced against and do not override your privacy rights.
4. Consent: Processing for marketing communications and optional platform features, where you have provided clear, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

06Data Sharing and Disclosure

9aplay does not sell, rent, or trade your personal information to any third party for their own marketing or commercial purposes. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

6.1 Service Providers and Processors

9aplay engages third-party service providers who process personal data on our behalf under strict data processing agreements. These include payment gateway operators (for GCash, PayMaya, and bank transfer processing), identity verification service providers (for KYC), cloud hosting infrastructure providers, and customer support platform vendors. All processors are contractually prohibited from using your data for any purpose beyond the specific service they provide to 9aplay.

6.2 Game Providers

Game software providers — including Pragmatic Play, PG Soft, and other studios whose games appear on the 9aplay platform — may receive technical data necessary to deliver game functionality, such as session tokens and anonymised player identifiers. Game providers do not receive your name, contact details, financial information, or government ID data.

6.3 Regulatory and Law Enforcement Authorities

9aplay will disclose personal data to the National Privacy Commission (NPC), PAGCOR, the Anti-Money Laundering Council (AMLC), Philippine law enforcement agencies, or any other competent authority when required to do so by applicable Philippine law, court order, or regulatory directive. We will inform you of any such disclosure where we are legally permitted to do so.

6.4 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of 9aplay's assets, your personal data may be transferred to the acquiring entity as part of that transaction, provided that the acquiring entity agrees to process your data in a manner consistent with this Privacy Policy and applicable Philippine law.

07Cookies and Tracking Technologies

9aplay uses cookies and similar tracking technologies on the platform to deliver and improve our Services. A cookie is a small text file stored on your device by your web browser when you visit the 9aplay website.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the platform to function. These maintain your authenticated session, preserve your cart and balance display, and ensure security features operate correctly. These cookies cannot be disabled without disrupting platform functionality.
• Performance and Analytics Cookies: Collect anonymised data about how players navigate the platform — pages visited, features used, and error events — to help us identify technical issues and improve performance.
• Functionality Cookies: Remember your platform preferences, such as your preferred language and display settings, to personalise your experience across sessions.
• Fraud Detection Cookies: Help identify and prevent fraudulent activity, including automated bot access, account takeover attempts, and suspicious session patterns.

7.2 Managing Cookies

You may configure your browser to refuse some or all cookies, or to alert you when cookies are being set. Please note that disabling strictly necessary cookies will impair your ability to use the 9aplay platform, including logging in and accessing your account balance. Disabling performance or functionality cookies will not prevent you from using the platform but may affect your experience.

08Data Retention

9aplay retains your personal data for as long as necessary to fulfil the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Specific retention periods applicable to the main data categories are as follows:

• Account and Identity Data: Retained for the duration of your account plus a minimum of five (5) years following account closure, as required by Philippine anti-money laundering regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with AMLC record-keeping requirements.
• KYC Documents: Retained for the duration of your account plus five (5) years following closure.
• Customer Support Communications: Retained for three (3) years from the date of each interaction, for dispute resolution purposes.
• Technical and Usage Logs: Retained for twelve (12) months in active logs; archived for a further two (2) years for security investigation purposes.
• Marketing Preferences: Retained until you withdraw consent or request deletion, subject to any overriding legal retention obligation.

When retention periods expire, personal data is securely deleted or anonymised so that it can no longer be associated with any individual. Where anonymisation is not technically feasible, data is securely destroyed in accordance with industry-standard data disposal practices.

09Data Security

9aplay implements a multi-layered security framework to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Our technical and organisational security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 9aplay platform;
• Encryption at rest for sensitive data stored on 9aplay servers, including KYC documents and financial records;
• Role-based access controls ensuring that 9aplay employees can access personal data only to the extent required by their specific job function;
• Two-Factor Authentication (2FA) available for all player accounts to prevent unauthorised access;
• Automated intrusion detection and brute-force prevention systems on all login interfaces;
• Regular security assessments and penetration testing of platform infrastructure;
• Staff training on data protection obligations and secure data handling practices;
• Contractual security requirements imposed on all third-party service providers who process 9aplay player data.

While 9aplay applies rigorous security standards, no online platform can guarantee absolute security against all possible threats. We encourage players to use strong, unique passwords for their 9aplay accounts, enable Two-Factor Authentication, and report any suspected unauthorized access to our support team immediately.

10Your Data Rights

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), you hold the following rights with respect to your personal data held by 9aplay. These rights may be exercised by contacting our Data Protection Officer using the details provided in Section 15.

• Right to Be Informed: The right to be notified about how your personal data is collected and processed — fulfilled by this Privacy Policy.
• Right of Access: The right to request a copy of the personal data 9aplay holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by 9aplay. You may also update most account information directly through your account profile settings.
• 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 9aplay's legal retention obligations. Regulatory record-keeping requirements may prevent deletion of certain data categories.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format, where technically feasible.
• Right to Object: The right to object to processing of your personal data for marketing purposes. You may withdraw marketing consent at any time via your account settings without affecting any other aspect of the service.
• Right to Lodge a Complaint: If you believe your data rights have been violated, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC).

9aplay will respond to all data rights requests within 15 calendar days of receipt. Complex requests may require an extension of up to 30 days, in which case we will notify you of the reason and expected timeline.

11Children's Privacy

The 9aplay platform is strictly restricted to individuals who are 21 years of age or older in accordance with Philippine gaming law. 9aplay does not knowingly collect personal information from persons under the age of 21. If we become aware that personal data has been collected from an individual below the minimum age, we will promptly suspend the associated account, delete the personal data collected, and, where applicable, notify the relevant regulatory authority.

If you have reason to believe that a minor has registered an account on the 9aplay platform using false age information, please contact our support team immediately at the contact details provided in Section 15.

12Cross-Border Data Transfers

9aplay's primary operations and data storage infrastructure are based in and oriented toward the Philippine market. In certain circumstances, personal data may be processed by or transferred to service providers and game technology vendors operating outside the Philippines — for example, game server infrastructure or cloud hosting services.

Where such transfers occur, 9aplay ensures appropriate safeguards are in place as required by the Philippine Data Privacy Act, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under Philippine law. We will not transfer personal data to jurisdictions that do not provide adequate data protection guarantees without implementing appropriate safeguards and obtaining consent where required.

13Third-Party Links

The 9aplay platform does not include links to external third-party websites as part of its standard operation. However, in the event that any third-party link appears incidentally in player communications or platform materials, please note that clicking any such link will take you to a website outside of 9aplay's control. This Privacy Policy does not apply to third-party websites, and 9aplay accepts no responsibility for the privacy practices of any external site. We encourage you to review the privacy policy of any website you visit before providing personal information.

14Amendments to This Policy

9aplay reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or regulatory requirements. We will notify registered players of material changes via email to the registered address and/or via a prominent notice on the 9aplay platform at least seven (7) calendar days prior to the effective date of any change, where practicable.

The revised Policy will be published on this page with an updated "Last Updated" date. Your continued use of the 9aplay platform following the effective date of a revised Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you must cease using 9aplay Services and contact us to arrange account closure.

15Contact and Data Protection Officer

For all privacy-related inquiries, requests to exercise your data rights, or to contact our Data Protection Officer, please use the following channels:

• Live Chat: Available 24/7 directly on the 9aplay Platform. Our Filipino support agents are available in both English and Tagalog and can escalate privacy requests to the DPO.
• Email (DPO): [email protected] — mark your subject line with "Privacy Request" or "DPO Inquiry" for expedited handling.

We aim to acknowledge all privacy requests within 3 business days and to resolve them within 15 calendar days. Complex matters involving multiple data categories or regulatory coordination may require up to 30 days, in which case we will communicate the reason and expected timeline.

If you are not satisfied with how 9aplay has handled your privacy inquiry, you have the right to escalate your complaint to the Philippine National Privacy Commission (NPC) at privacy.gov.ph.