9sapp Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how 9sapp ("9sapp", "we", "us", "our") collects, uses, stores, discloses, and protects the personal data of players and visitors ("you", "your") who access or use the 9sapp online gaming platform available at https://9sapp.pro (the "Platform").

9sapp is committed to protecting your personal data and respecting your privacy in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, or "DPA"), its Implementing Rules and Regulations, and the regulations issued by the National Privacy Commission (NPC). We also comply with applicable PAGCOR guidelines regarding the handling of player information.

By registering an account, visiting the Platform, or using any of our services, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree with any part of this Policy, please discontinue your use of the Platform and, if applicable, close your account.

This Policy should be read together with the 9sapp Terms and Conditions, which are available at /terms-conditions. In the event of any conflict between this Policy and the Terms and Conditions, this Policy shall prevail with respect to all matters relating to personal data.

02 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, 9sapp is the personal information controller responsible for the personal data collected through the Platform. This means 9sapp determines the purposes and means of processing your personal data.

Our Data Protection Officer (DPO) oversees compliance with this Policy and with applicable Philippine data privacy regulations. If you have any questions or wish to exercise your data subject rights, you may contact the DPO by sending a written request to [email protected] with the subject line "Data Privacy Request".

03 Personal Data We Collect

9sapp collects the following categories of personal data from players and Platform visitors. The specific data collected depends on how you interact with the Platform and the services you use.

04 How We Collect Your Data

9sapp collects personal data through the following channels and mechanisms:

4.1 Directly From You

• When you complete the account registration form on the Platform, providing your name, date of birth, email address, and Philippine mobile number.
• When you submit KYC verification documents through our compliance portal or via email to our support team.
• When you make a deposit or request a withdrawal, providing payment method details.
• When you contact our customer support team via live chat, email, or any other support channel.
• When you participate in surveys, promotions, or competitions hosted on the Platform.
• When you update your account profile or modify your communication preferences.

4.2 Automatically When You Use the Platform

• Technical data — including your IP address, device type, browser, and session information — is collected automatically via server logs and device fingerprinting technologies when you access the Platform.
• Gaming activity data is recorded automatically each time you participate in a game session on 9sapp.
• Cookies and similar tracking technologies collect usage data as described in Section 8 of this Policy.

4.3 From Third Parties

• Payment processors (GCash, Maya, BPI, BDO, Metrobank, Coins.ph) may share transaction confirmation data with 9sapp to facilitate deposit and withdrawal processing.
• Identity verification service providers may share the results of document verification checks conducted on our behalf.
• Fraud prevention and anti-money laundering screening services may provide risk signals and watchlist screening results related to your account.
• Regulatory authorities, including PAGCOR, may share information relevant to licensing compliance and player protection obligations.

05 How We Use Your Personal Data

9sapp processes your personal data for the following specific, documented purposes:

• Account Creation and Management: To register your 9sapp account, verify your identity, maintain your account profile, and enable you to log in and access Platform services.
• Age Verification (21+): To confirm that you meet the minimum age requirement of 21 years for participation in online casino and sports betting activities in the Philippines, as required by PAGCOR.
• Payment Processing: To process deposits into your 9sapp account and to execute withdrawal requests to your registered payment method in Philippine Peso (PHP).
• KYC & AML Compliance: To verify your identity, screen your details against anti-money laundering (AML) watchlists, and fulfil our obligations under the Philippine Anti-Money Laundering Act (AMLA) and PAGCOR's compliance framework.
• Game Operation and Dispute Resolution: To operate games fairly, record game outcomes and transaction histories, and resolve disputes or complaints raised by players.
• Responsible Gaming: To monitor gaming behaviour for signs of problem gambling, apply responsible gaming tools (deposit limits, self-exclusion) you have requested, and send responsible gaming communications where indicated by your account activity.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, duplicate accounts, unauthorised access, cheating, and other prohibited conduct on the Platform.
• Customer Support: To respond to your queries, complaints, and support requests efficiently and maintain records of support interactions for quality assurance purposes.
• Marketing Communications (with consent): To send you promotional offers, bonus notifications, and Platform updates via email or SMS, where you have opted in to receive such communications. You may withdraw this consent at any time.
• Platform Improvement: To analyse anonymised and aggregated usage data to improve Platform performance, fix technical issues, and develop new features and game offerings relevant to Filipino players.
• Legal and Regulatory Compliance: To comply with applicable Philippine laws, respond to lawful requests from regulatory authorities (including PAGCOR, the NPC, and AMLC), and enforce our Terms and Conditions.

06 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 9sapp processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 9sapp — specifically, to provide the online gaming services you have signed up for, process your deposits and withdrawals, and operate your account.
• Legal Obligation: Processing is required to comply with Philippine law, including the Data Privacy Act, the Anti-Money Laundering Act, PAGCOR licensing conditions, and other applicable regulations. This covers KYC verification, AML screening, age verification, and record-keeping requirements.
• Legitimate Interests: 9sapp processes certain data (such as technical data for fraud prevention and security monitoring) on the basis of our legitimate interest in operating a secure and compliant gaming platform, provided that this interest is not overridden by your fundamental rights and freedoms.
• Consent: For marketing communications and non-essential cookies, 9sapp relies on your freely given, specific, and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Data Sharing & Disclosure

9sapp does not sell your personal data. We share your data only in the following circumstances and only to the extent necessary for each stated purpose:

7.1 Service Providers (Personal Information Processors)

9sapp engages trusted third-party service providers who process personal data on our behalf and under our documented instructions. These include payment processors (GCash, Maya, BPI, BDO, Metrobank, Coins.ph, 7-Eleven Cliqq), KYC and identity verification providers, fraud prevention and AML screening services, cloud hosting and data storage providers, and customer support platform providers. All processors are contractually bound to maintain the confidentiality and security of your data and to process it only for the purposes we specify.

7.2 Regulatory and Law Enforcement Authorities

9sapp may disclose personal data to the Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), or other competent Philippine authorities where we are legally required or compelled to do so by applicable law, court order, or regulatory directive. Such disclosures are made only to the extent strictly required.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 9sapp's business, personal data held by 9sapp may be transferred to the acquiring entity. You will be notified of any such transfer and of any changes to the privacy practices applicable to your data prior to the transfer taking effect.

7.4 With Your Consent

9sapp may share your personal data with other parties not listed above where you have given your explicit prior consent to such sharing. You may withdraw this consent at any time by contacting our support team.

08 Cookies & Tracking Technologies

9sapp uses cookies and similar tracking technologies (such as local storage objects and pixel tags) on the Platform. Cookies are small text files placed on your device that help the Platform function correctly and allow us to understand how players interact with the site.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable you to log in, maintain your session, and use core features such as the game lobby and cashier. These cookies cannot be disabled without breaking the Platform.
• Functional Cookies: These cookies remember your preferences — such as your preferred game lobby view and language setting — to provide a more personalised experience. Disabling these cookies may reduce convenience but will not prevent you from using the Platform.
• Security Cookies: Used for fraud detection, bot prevention, and device fingerprinting to protect your account and the Platform from unauthorised access and abuse.
• Analytics Cookies: Used to collect anonymised data about how players navigate and use the Platform, helping us identify performance issues and improve the user experience. Analytics data is aggregated and does not identify individual players.

8.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most browsers allow you to block or delete cookies, though doing so may affect the functionality of the Platform. For strictly necessary and security cookies, blocking is not recommended as it may prevent you from logging in or using the cashier.

09 Data Security

9sapp implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including KYC documents, financial records, and account credentials.
• Multi-factor authentication (MFA) for all administrative access to systems containing personal data.
• Role-based access controls ensuring that personal data is accessible only to authorised personnel who require it for their specific duties.
• Regular penetration testing and vulnerability assessments conducted by independent third-party security specialists.
• Automated intrusion detection and real-time security monitoring on all Platform infrastructure.
• Secure data centre facilities with physical access controls, CCTV surveillance, and environmental safeguards.
• Regular staff training on data privacy obligations and information security best practices.

Despite these measures, no system is completely immune to security breaches. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, 9sapp will notify you and the National Privacy Commission (NPC) within the timeframe required by Philippine law, and will take immediate steps to contain and remediate the breach.

10 Data Retention

9sapp retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable Philippine law. The following retention periods apply:

After the applicable retention period expires, personal data is securely deleted or anonymised so that it can no longer be linked to you as an individual. Where anonymised data is used for statistical analysis or Platform improvement, it is no longer considered personal data under the DPA.

11 Your Data Subject Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 9sapp:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, stored, and disclosed. This Privacy Policy fulfils that obligation.
• Right to Access: You have the right to request a copy of the personal data 9sapp holds about you, including information about how it is being processed. We will provide this within 15 business days of a verified request.
• Right to Rectification: You have the right to request correction of any inaccurate, incomplete, or outdated personal data we hold about you. For basic profile corrections (name spelling, email address), you may update these directly in your account settings.
• Right to Erasure (Right to be Forgotten): You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where the data has been unlawfully processed. Note that this right is subject to overriding legal retention obligations (e.g., AMLA requires 5-year retention of financial records).
• Right to Object: You have the right to object to the processing of your personal data where 9sapp relies on legitimate interests as the legal basis, or where your data is being processed for direct marketing purposes. Objection to marketing can be exercised at any time via the unsubscribe link in any promotional email or by contacting support.
• Right to Data Portability: You have the right to receive the personal data you have provided to 9sapp in a structured, commonly used, and machine-readable format (such as CSV), and to request that it be transmitted to another personal information controller where technically feasible.
• Right to Lodge a Complaint: If you believe that your data privacy rights have been violated, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint is available on the NPC's official website.

How to Exercise Your Rights

To exercise any of the rights listed above, please send a written request to our Data Protection Officer at [email protected] with the subject line "Data Privacy Request". Your request must include:

• Your full registered name and 9sapp account username.
• A clear description of the right you wish to exercise and the specific data concerned.
• A copy of a valid government-issued ID to verify your identity (this is required to prevent unauthorised access to your data by third parties).

9sapp will acknowledge your request within five (5) business days and provide a substantive response within fifteen (15) business days. In complex cases requiring additional time, we will notify you of the extended timeline and the reasons for it.

12 Minors and Age Restriction

9sapp's gaming services are strictly restricted to individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing online gambling in the Philippines. We do not knowingly collect personal data from individuals under the age of 21.

As part of our account registration process, all applicants are required to declare their date of birth and submit government-issued identification documents for age verification. Any account found to have been created by a person under 21 years of age will be immediately suspended, all associated funds will be frozen pending investigation, and any winnings generated during the period of underage access will be forfeited in accordance with our Terms and Conditions.

If you have reason to believe that a person under the age of 21 has registered an account on 9sapp, please report this immediately to [email protected] so that we can take prompt action.

13 Cross-Border Data Transfers

In the course of providing services through the Platform, some of your personal data may be processed by service providers located outside of the Philippines — for example, cloud infrastructure providers or international fraud prevention services.

Where personal data is transferred outside the Philippines, 9sapp takes all reasonable steps to ensure that such transfers comply with the requirements of the Philippine Data Privacy Act and the rules of the National Privacy Commission. This includes ensuring that recipient entities are bound by contractual data processing agreements that require them to apply data protection standards equivalent to those required under Philippine law.

9sapp will not transfer your personal data to a third country or international organisation that does not provide an adequate level of protection for personal data, unless appropriate safeguards are in place and you have been duly informed.

14 Changes to This Privacy Policy

9sapp may update this Privacy Policy from time to time to reflect changes in our data practices, changes in applicable Philippine law or PAGCOR regulations, or improvements to our Platform and services. The "Last Updated" date at the top of this page indicates when the most recent revision was made.

For material changes — meaning changes that significantly affect how we use your personal data or that affect your rights as a data subject — 9sapp will provide you with advance notice by email to your registered address at least fourteen (14) days before the revised Policy takes effect. Your continued use of the Platform after the effective date of a revised Policy constitutes your acceptance of the updated terms.

For minor changes (such as corrections of typographical errors, clarification of existing practices, or updates to contact details), we will update the "Last Updated" date without advance notification. We encourage you to review this Policy periodically to stay informed about how 9sapp protects your personal data.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way 9sapp handles your personal data, please do not hesitate to contact us through any of the following channels:

• Data Privacy Requests & DPO Contact: Send an email to [email protected] with the subject line "Data Privacy Request".
• General Support: Contact our support team via live chat on the Platform, available 24/7, or via email at [email protected].
• Support Hours: Live chat is available 24 hours a day, 7 days a week. Email responses are provided within 24 hours on business days (Monday to Friday, 8 AM – 10 PM PHT, 7 days a week).

For responsible gaming support requests — including activation of deposit limits, cool-off periods, or self-exclusion — please contact us directly via email or live chat and our team will process your request promptly.