a9piso Privacy Policy

1. Introduction

a9piso ("we," "us," or "our") is committed to protecting the privacy and personal data of all players who use the a9piso online gaming platform (the "Platform"). This Privacy Policy describes how a9piso collects, uses, stores, shares, and protects personal data in connection with the operation of the Platform.

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines. It is also consistent with the data governance requirements imposed by the Philippine Amusement and Gaming Corporation (PAGCOR) on licensed online gaming operators.

By registering an account, depositing funds, or otherwise using the a9piso Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

2. Personal Data We Collect

a9piso collects the following categories of personal data from players:

a9piso does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive data is collected (such as a copy of a government-issued ID), it is handled with heightened security measures.

3. How We Collect Your Data

a9piso collects personal data through the following means:

• Direct Collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the Platform, including IP address, device identifiers, browser information, and session activity logs, through the use of cookies and similar tracking technologies.
• Third-Party Sources: Identity verification data from PAGCOR-approved KYC service providers; fraud detection signals from payment processors; and publicly available information used to verify the accuracy of data you have provided.

4. Purpose of Processing

a9piso processes your personal data for the following purposes:

1. Account Management: To create, maintain, and administer your a9piso player account, including authentication and account security.
2. Identity Verification (KYC): To verify your identity and age in compliance with PAGCOR licensing requirements and Philippine anti-money laundering regulations.
3. Transaction Processing: To process deposits, withdrawals, and other financial transactions, and to maintain accurate financial records.
4. Platform Operation: To deliver gaming services, personalize your experience, and improve Platform functionality based on usage patterns.
5. Regulatory Compliance: To fulfill obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws.
6. Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct.
7. Responsible Gaming: To monitor gaming behavior and identify players who may benefit from responsible gaming interventions, in accordance with PAGCOR responsible gaming standards.
8. Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications.
9. Customer Support: To respond to inquiries, resolve disputes, and improve the quality of support services.

5. Legal Basis for Processing

a9piso processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform the contract between you and a9piso — specifically, to operate your player account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests: Processing is carried out for a9piso's legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your data protection rights.
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

a9piso does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

1. PAGCOR and Regulatory Authorities: a9piso is required by its operating license to submit player data and transaction records to PAGCOR upon request. We may also disclose data to the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other government agencies when required by law or court order.
2. KYC and Identity Verification Providers: We share identity documents and personal data with PAGCOR-accredited KYC service providers for the purpose of verifying your identity and age.
3. Payment Processors: Financial data is shared with payment service providers such as GCash, PayMaya, BPI, BDO, and Metrobank solely for the purpose of processing deposits and withdrawals.
4. Technology and Hosting Providers: We engage third-party service providers for cloud hosting, platform infrastructure, and cybersecurity services. These providers process data on our behalf under strict data processing agreements and are prohibited from using your data for their own purposes.
5. Fraud Prevention Services: We may share technical data with fraud detection and cybersecurity service providers to protect the integrity of the Platform.
6. Business Transfers: In the event of a merger, acquisition, or sale of all or part of a9piso's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party service providers engaged by a9piso are contractually required to implement appropriate technical and organizational measures to protect your personal data and to process it only in accordance with a9piso's instructions.

7. Data Retention

a9piso retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by AMLA regulations.
• Gaming Activity Logs: Retained for a minimum of two (2) years from the date of each gaming session.
• Customer Support Records: Retained for two (2) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with a9piso's data disposal procedures. Where data is anonymized, it may be retained indefinitely for statistical and analytical purposes.

8. Data Security

a9piso implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the a9piso Platform.
• Encryption at rest for all stored personal data and financial records.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Multi-factor authentication requirements for all administrative access to systems containing personal data.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While a9piso takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying a9piso immediately if you suspect unauthorized access to your account.

9. Cookies and Tracking Technologies

a9piso uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

Strictly necessary cookies are placed automatically as they are essential to Platform operation. All other cookies are placed only with your consent. You may manage or withdraw cookie consent at any time through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by a9piso:

1. Right to Be Informed: You have the right to be informed about how your personal data is collected and processed, as set out in this Privacy Policy.
2. Right of Access: You have the right to request a copy of the personal data a9piso holds about you, along with information about how it is being used.
3. Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held by a9piso.
4. Right to Erasure: 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, subject to a9piso's legal retention obligations.
5. Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
6. Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
7. Right to Lodge a Complaint: If you believe your data privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please contact the a9piso Data Protection Officer using the contact details provided in Section 13 of this Policy. a9piso will respond to all verified data subject requests within fifteen (15) business days of receipt.

11. Children's Privacy

The a9piso Platform is strictly intended for individuals who are at least twenty-one (21) years of age, as required under Philippine gaming regulations. a9piso does not knowingly collect personal data from individuals under the age of 21. If a9piso becomes aware that personal data has been collected from a minor, the account will be immediately suspended, all associated data will be deleted, and any funds held in the account will be returned to the depositing payment method following investigation.

If you believe that a minor has registered an account on the a9piso Platform, please contact our customer support team immediately so that appropriate action can be taken.

12. Updates to This Privacy Policy

a9piso reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, the updated Policy will be published on the Platform with a revised effective date. Where required by law, a9piso will notify affected players of material changes via email or in-platform notification prior to the changes taking effect.

Your continued use of the a9piso Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how your data is being protected.

13. Contact and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by a9piso, please contact our Data Protection Officer:

For complaints regarding data privacy violations, you may also contact the National Privacy Commission of the Philippines directly. a9piso cooperates fully with NPC investigations and is committed to resolving all data privacy concerns promptly and transparently.