96phd Privacy Policy

1. Data Controller Information

1.1 The personal data controller for the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations is 96phd, the operator of the online gaming platform accessible at 96phd.club ("96phd," "we," "us," or "our").

1.2 96phd operates in compliance with PAGCOR (Philippine Amusement and Gaming Corporation) regulations applicable to licensed online gaming operators in the Philippines.

1.3 This Privacy Policy applies to all personal data collected through the 96phd website, mobile web interface, related services, customer support channels, and any other touchpoints where 96phd collects data from or about you ("Data Subject" or "you").

2. Personal Data We Collect

2.1 Registration Data. When you create a 96phd account, we collect your chosen username, email address, registered mobile number (Philippine number), date of birth, and password (stored in hashed, non-recoverable form).

2.2 Identity Verification Data. To comply with PAGCOR KYC (Know Your Customer) and AMLA (Anti-Money Laundering Act) requirements, we may collect copies of government-issued identification documents such as: SSS ID, UMID, PhilHealth ID, Philippine Passport, and/or Driver's License. We also collect your full legal name and residential address as it appears on those documents.

2.3 Financial Data. We collect GCash account references, Maya account references, bank account details (for BPI, BDO, UnionBank, Metrobank transfers), and transaction records (deposits, withdrawals, bet amounts, game results) as necessary to process transactions and comply with AMLA obligations. We do not store full bank account numbers or card numbers on our servers — payment processing is handled by certified payment processors.

2.4 Gaming Activity Data. We collect records of your gaming sessions, including games played, bet amounts, win/loss results, bonus usage, and session duration. This data is used for account management, responsible gaming monitoring, and regulatory compliance.

2.5 Technical and Device Data. We automatically collect IP address, device type and operating system, browser type and version, mobile network carrier, session timestamps, and pages visited within the 96phd Platform. This data is used for security, fraud prevention, and platform optimisation.

2.6 Communications Data. If you contact 96phd via live chat or email, we retain records of those communications for quality assurance, dispute resolution, and regulatory audit purposes.

2.7 Responsible Gaming Data. If you use 96phd's responsible gaming tools — such as deposit limits, self-exclusion requests, or cooling-off periods — we record those preferences and decisions to honour them across all sessions and prevent circumvention.

3. How We Collect Your Data

3.1 Directly from You. The majority of personal data 96phd holds is provided by you directly: during registration, during identity verification, when you make deposits or withdrawals, and when you contact customer support.

3.2 Automatically. Certain technical and device data is collected automatically when you visit or use the 96phd Platform, through server logs, session tracking, and cookies (see Section 9 for cookie details).

3.3 From Third-Party Payment Processors. When you make a GCash or Maya deposit or withdrawal, our payment processor provides confirmation data to 96phd's systems for transaction matching and reconciliation. No raw financial credentials are passed to 96phd from these processors.

3.4 From Identity Verification Services. Where 96phd uses a third-party KYC service provider to assist with document verification, that provider processes your identity documents on our behalf under a data processing agreement, subject to the same data protection standards required by this Policy.

4. Purposes of Processing

4.1 96phd processes your personal data for the following specific purposes:

• Account management: creating, maintaining, and managing your 96phd account;
• Identity and age verification: confirming that you meet the 21+ age requirement and verifying your identity in compliance with PAGCOR KYC standards;
• Payment processing: processing GCash, Maya, and bank deposits and withdrawals, and maintaining transaction records;
• Regulatory compliance: fulfilling obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act;
• Fraud and security: detecting and preventing fraudulent activity, money laundering, account takeovers, and other security threats;
• Responsible gaming: monitoring gaming activity to support responsible gaming commitments, enforcing self-exclusion and deposit limits, and identifying potentially problematic gambling patterns;
• Customer support: responding to your enquiries, resolving disputes, and providing technical assistance;
• Platform improvement: analysing aggregated usage data to improve the 96phd Platform's performance, design, and game offerings;
• Marketing communications: sending promotional offers, bonus notifications, and news about new games or features — only where you have given consent and only via channels you have opted in to.

5. Legal Bases for Processing

5.1 96phd processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contract performance: processing necessary to fulfil our obligations to you under the 96phd Terms & Conditions, including account management and payment processing;
• Legal obligation: processing required by PAGCOR regulations, AMLA, and other applicable Philippine laws;
• Legitimate interests: processing for fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your privacy rights;
• Consent: processing for marketing communications, non-essential cookies, and any other purpose where consent is the appropriate legal basis under applicable law. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 No Sale of Personal Data. 96phd does not sell, rent, or trade your personal data to any third party for that party's own marketing, commercial, or other purposes.

6.2 Service Providers. 96phd shares personal data with trusted third-party service providers who process data on our behalf under written data processing agreements, including: payment processing partners (GCash, Maya, BPI, BDO, UnionBank, Metrobank), KYC/identity verification providers, live chat software providers, cloud infrastructure and hosting providers, and game suppliers (for the purpose of delivering games and confirming transaction outcomes).

6.3 Regulatory Bodies. 96phd may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government authorities when required by law or regulation, or in response to a valid legal process.

6.4 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of 96phd's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

6.5 Cross-Border Transfers. Some of 96phd's service providers operate servers outside the Philippines. Where personal data is transferred internationally, 96phd ensures that appropriate safeguards are in place as required by the Data Privacy Act and NPC guidelines.

7. Data Retention

7.1 96phd retains personal data for as long as your account remains active and for such additional period as may be required by applicable law, regulation, or legitimate business need. Specifically:

• Account and registration data: retained for the duration of your account and for a minimum of five (5) years thereafter, as required by AMLA and PAGCOR record-keeping obligations;
• Transaction and gaming activity records: retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA;
• Identity verification documents: retained for as long as required by PAGCOR KYC standards and AMLA, typically five (5) years from the end of the customer relationship;
• Customer support communications: retained for three (3) years from the date of the communication, or longer where the communication is relevant to an ongoing dispute;
• Marketing consent records: retained for as long as necessary to demonstrate the basis for any marketing communications sent.

7.2 Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents recovery or identification.

8. Data Security

8.1 96phd implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data in transit between your device and 96phd servers;
• AES-256 encryption for sensitive data at rest, including identity verification documents and financial records;
• Access controls and role-based permissions limiting access to personal data to authorised personnel with a legitimate need;
• Regular security vulnerability assessments and penetration testing;
• Two-factor authentication requirements for all staff with access to production systems containing personal data;
• Audit logging of all access to systems containing personal data.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 96phd will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by the Data Privacy Act. Affected data subjects will be notified without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

9. Cookies and Tracking Technologies

9.1 The 96phd Platform uses cookies and similar technologies to operate core platform functionality, remember your preferences, maintain your login session, and analyse Platform usage. We use the following categories of cookies:

• Strictly necessary cookies: required for the Platform to function, including session management and security cookies. These cannot be disabled;
• Functional cookies: used to remember your preferences such as language settings and game favourites;
• Analytics cookies: used to collect anonymised data about how visitors use the Platform, to help us improve performance and user experience. Analytics data is not linked to your personal identity;
• Marketing cookies: used with your consent to deliver personalised promotional content within the 96phd Platform.

9.2 You can manage your cookie preferences through your browser settings. Disabling certain categories of cookies may affect your experience on the Platform.

10. Your Data Subject Rights

10.1 As a data subject under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by 96phd:

• Right to be informed: the right to know what personal data 96phd collects about you, the purposes of processing, and how it is used;
• Right to access: the right to request a copy of the personal data 96phd holds about you;
• Right to correction: the right to have inaccurate or incomplete personal data corrected or updated;
• Right to erasure or blocking: the right to request deletion or blocking of personal data where it is no longer necessary for the purposes for which it was collected, subject to 96phd's legal retention obligations;
• Right to data portability: the right to receive your personal data in a structured, commonly used format and to transmit it to another controller, where technically feasible;
• Right to object: the right to object to processing based on legitimate interests, in particular where such processing is used for direct marketing;
• Right to withdraw consent: where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

10.2 To exercise any of the above rights, please contact 96phd's Data Protection Officer (see Section 13). Requests will be processed within fifteen (15) business days of receipt. Where a request is complex or numerous, 96phd may extend this period by a further thirty (30) days, with prior notification.

10.3 If you believe that 96phd has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Children's Privacy and Underage Users

11.1 The 96phd Platform is strictly restricted to persons who are 21 years of age or older. 96phd does not knowingly collect personal data from persons under the age of 21.

11.2 If 96phd discovers or has reason to believe that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, the personal data will be isolated and deleted to the extent not required for regulatory reporting, and the matter may be referred to PAGCOR as required.

11.3 If you are a parent or guardian and believe that a minor has registered on 96phd, please contact our Data Protection Officer immediately at the details set out in Section 13.

12. Updates to This Privacy Policy

12.1 96phd reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes will be notified to registered players via the email address on file and/or via a prominent notice on the Platform at least seven (7) days before taking effect.

12.2 The "Last updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how 96phd handles your personal data.

12.3 Your continued use of the 96phd Platform following the effective date of any update to this Policy constitutes your acknowledgement of the updated Policy.

13. Contact and Data Protection Officer

13.1 If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or need to report a suspected data privacy concern, please contact 96phd's designated Data Protection Officer through the following channels:

13.2 Contact details above are provided as plain text only and are not clickable links. Please copy the email address and use your own email client to send a message.

13.3 For complaints that cannot be resolved with 96phd directly, you may contact the National Privacy Commission of the Philippines at privacy.gov.ph (please access this address independently via your browser).