9apeso Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") applies to all personal data collected by 9apeso ("9apeso", "we", "us", "our") through the 9apeso online gaming platform at https://9apeso.co, its subdomains, and any associated mobile interfaces ("the Platform"). It governs the collection, use, storage, disclosure, and protection of personal information belonging to registered users, visitors, and anyone who interacts with 9apeso services.

9apeso is committed to protecting the privacy and personal data of all Filipino players in full compliance with the Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission of the Philippines.

This Policy should be read in conjunction with the 9apeso Terms & Conditions. In the event of any conflict between this Policy and the Terms, this Policy shall govern with respect to personal data matters.

2 Data Controller

9apeso is the Data Controller responsible for the personal data processed under this Policy. As Data Controller, 9apeso determines the purposes and means by which your personal data is collected and processed. 9apeso operates under PAGCOR's online gaming regulatory framework and is subject to PAGCOR's data governance requirements in addition to those of the National Privacy Commission.

9apeso has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with the Data Privacy Act, handling data subject requests, and acting as the primary point of contact for the NPC. You may contact the 9apeso DPO at [email protected] with the subject line "DPO – Privacy Inquiry."

3 Personal Data We Collect

9apeso collects personal data in several categories, depending on your interaction with the Platform:

9apeso does not collect full credit or debit card numbers. All financial data transmitted through third-party payment processors (GCash, PayMaya, BPI, BDO, Metrobank) is governed by those processors' own privacy policies in addition to this Policy.

4 How We Use Your Personal Data

9apeso processes your personal data for the following purposes:

• Account management — to create, maintain, verify, and administer your 9apeso account;
• Identity verification (KYC) — to confirm your eligibility, verify that you are at least 21 years of age, and meet PAGCOR's Know Your Customer requirements;
• Payment processing — to process deposits, withdrawals, and refunds through supported Philippine payment channels;
• Gaming services — to provide access to games, record game outcomes, calculate winnings, and apply bonuses;
• Security and fraud prevention — to detect, investigate, and prevent fraudulent transactions, account takeover, and other prohibited conduct;
• Regulatory compliance — to fulfil reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission;
• Responsible gaming — to monitor gaming patterns, apply player-set limits, and intervene where signs of problem gambling are identified;
• Customer support — to respond to your queries, resolve disputes, and improve service quality;
• Marketing communications — to send promotional offers, bonus notifications, and platform updates to users who have provided marketing consent (opt-out available at any time);
• Platform improvement — to analyse aggregated usage patterns, conduct A/B testing, and improve the 9apeso user experience.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, 9apeso processes your personal data on the following legal grounds:

• Contractual necessity — processing required to fulfil the 9apeso Terms & Conditions you agreed to at registration (account management, payment processing, game delivery);
• Legal obligation — processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, and other Philippine legislation;
• Legitimate interests — fraud prevention, security monitoring, and platform improvement, where these interests do not override your fundamental rights;
• Consent — marketing communications, and any processing not covered by the above grounds, for which you have provided specific, informed, and freely given consent.

You may withdraw consent for consent-based processing at any time without affecting the lawfulness of processing that occurred before withdrawal. Withdrawal of consent for non-essential processing will not affect your ability to use the core 9apeso platform.

6 Sharing Your Personal Data

9apeso does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following circumstances:

• Service providers — third-party vendors who process data on our behalf under binding data processing agreements: KYC/identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), game software providers, cloud hosting services, and customer support platforms. These providers act as Data Processors and may only process your data as instructed by 9apeso;
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other Philippine government bodies when legally required;
• Law enforcement — Philippine law enforcement agencies when required by a valid court order, warrant, or legal process;
• Corporate transactions — in the event of a merger, acquisition, or sale of substantially all assets of 9apeso, personal data may be transferred to the acquiring entity, subject to equivalent privacy protections and advance notice to affected users.

All third-party service providers are contractually required to protect your personal data with security standards equivalent to those applied by 9apeso and to process it only for the purposes for which it was shared.

7 Data Retention

9apeso retains your personal data for the periods set out below, or longer if required by applicable Philippine law:

• Account and identity data — retained for the duration of your active account plus 5 years after account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act;
• Financial transaction data — retained for 5 years from the date of each transaction, in compliance with the AMLA and BIR requirements;
• Gaming records — retained for 3 years from each session date;
• Customer support communications — retained for 2 years from the date of the last interaction;
• Technical/log data — retained for 12 months from the date of collection.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual.

8 Cookies & Tracking Technologies

9apeso uses cookies and similar tracking technologies to operate the platform, maintain session state, prevent fraud, and analyse usage patterns. The categories of cookies used are:

• Strictly necessary cookies — essential for platform operation (login session, security tokens, game state). These cannot be disabled without breaking core functionality;
• Functional cookies — remember your preferences such as language settings, responsible gaming tool configurations, and display options;
• Analytical cookies — collect aggregated, anonymised data about platform usage to help 9apeso improve the experience. No personally identifiable data is sent to analytics providers;
• Marketing cookies — used only if you have given explicit consent to receive personalised promotional content from 9apeso.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to 9apeso and using the platform.

9 Security Measures

9apeso implements a layered security architecture to protect your personal data, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and the 9apeso platform;
• Encryption of sensitive data fields at rest within 9apeso databases;
• Role-based access controls ensuring that only authorised 9apeso personnel can access personal data, and only to the extent necessary for their job function;
• Multi-factor authentication for all internal administrative access to production systems;
• Regular third-party penetration testing and security audits;
• Automated anomaly detection systems that flag unusual login patterns or access attempts for immediate review.

In the event of a personal data breach that is likely to result in risk to the rights and freedoms of affected individuals, 9apeso will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with the Data Privacy Act and NPC Circular 16-03.

10 Your Rights as a Data Subject

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 9apeso:

• Right to be informed — to know that your data is being collected, the purposes, and your rights, as set out in this Policy;
• Right of access — to request a copy of the personal data 9apeso holds about you;
• Right to rectification — to request correction of any inaccurate or incomplete personal data;
• Right to erasure — to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to object — to object to processing based on legitimate interests or for direct marketing purposes;
• Right to data portability — to receive your personal data in a structured, machine-readable format and have it transferred to another controller where technically feasible;
• Right to file a complaint — to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph) if you believe your rights under RA 10173 have been violated.

11 Children's Privacy & Age Restriction

The 9apeso platform is strictly intended for adults aged 21 years and above, in compliance with PAGCOR regulations governing online gaming in the Philippines. 9apeso does not knowingly collect, process, or retain personal data from individuals under the age of 21.

If 9apeso becomes aware that personal data has been collected from a person under 21 years of age, the account will be suspended immediately and all personal data associated with that account will be securely deleted without retention. Any funds deposited to such an account will be handled in accordance with PAGCOR's guidelines on underage account closure.

If you believe a minor has registered a 9apeso account, please contact [email protected] immediately so the account can be reviewed and actioned.

12 Cross-Border Data Transfers

Some of 9apeso's service providers — including game software providers and cloud infrastructure vendors — may process personal data in jurisdictions outside the Philippines. Where such transfers occur, 9apeso ensures that they are conducted in accordance with Section 21 of the Data Privacy Act, which requires that the receiving country or organisation provides an adequate level of protection equivalent to the Data Privacy Act.

Mechanisms used to safeguard cross-border transfers include standard contractual clauses in data processing agreements, binding corporate rules where applicable, and transfer impact assessments. If you have questions about specific cross-border transfers, contact the 9apeso DPO.

13 Amendments to This Policy

9apeso reserves the right to update this Privacy Policy at any time to reflect changes in Philippine law, NPC regulations, PAGCOR requirements, platform features, or business practices. When material changes are made, 9apeso will notify registered users via the email address or mobile number on record at least 7 days before the changes take effect.

The current version of this Policy is always available at https://9apeso.co/privacy-policy. The "Last Updated" date at the top of this page reflects the most recent revision. Continued use of the 9apeso platform after the effective date of any revision constitutes acceptance of the updated Policy.

14 Contact & NPC Information

For privacy-related questions, data subject requests, or concerns about how 9apeso handles your personal data, please contact the 9apeso Data Protection Officer:

If you are not satisfied with 9apeso's response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines:

This Privacy Policy was last updated in June 2026. 9apeso operates under PAGCOR oversight and is committed to the responsible, transparent, and lawful handling of personal data belonging to Filipino players aged 21 and above.