Privacy Policy

1Introduction

This Privacy Policy ("Policy") describes how 96phj ("96phj," "we," "us," or "our") collects, uses, discloses, stores, and protects the personal information of individuals ("you," "Player," or "User") who access and use the online gaming platform operated at https://96phj.app ("Platform").

96phj operates as a Philippine-facing online casino and sports betting platform, and as such is subject to Philippine data protection law, specifically Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as administered by the National Privacy Commission ("NPC") of the Philippines.

This Policy should be read together with our Terms & Conditions, which govern the overall use of the 96phj Platform. Where this Policy and the Terms conflict with respect to data handling, this Policy shall prevail.

2Data Controller

For the purposes of the Data Privacy Act of 2012, 96phj acts as the personal information controller in respect of the personal data it collects directly from Players and through the operation of the Platform.

Where 96phj engages third-party service providers to process personal data on its behalf (for example, payment processors, KYC verification services, or cloud hosting providers), those parties act as personal information processors under written agreements that bind them to data protection obligations consistent with those imposed by the DPA and this Policy.

For all data-related inquiries, please contact our Data Protection Officer as described in Section 15 of this Policy.

3Personal Data We Collect

96phj collects the following categories of personal data, depending on your level of interaction with the Platform:

96phj does not knowingly collect sensitive personal information (as defined under Section 3(l) of the DPA) beyond what is strictly necessary for KYC and AML compliance purposes. Where sensitive information is collected — for example, government ID numbers — it is handled with enhanced security controls.

4How We Collect Personal Data

96phj collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions on the 96phj Platform.
• Automatically through the Platform: Technical data including IP addresses, device identifiers, and session data are logged automatically whenever you access 96phj.app, whether or not you are logged in to an account.
• From third-party service providers: 96phj may receive identity verification results from accredited KYC service providers, fraud risk scores from anti-fraud systems, and payment confirmation data from GCash, PayMaya, and Philippine banking partners.
• From publicly available sources: For AML and sanctions screening purposes, 96phj may verify your identity against publicly available government databases and official sanctions lists maintained by relevant Philippine authorities.

5Purposes of Processing

96phj processes your personal data for the following specific and legitimate purposes:

• Account creation and management: To establish, maintain, and administer your 96phj account, including authentication, password recovery, and account security.
• Identity verification (KYC): To comply with PAGCOR licensing requirements and Republic Act No. 9160 (Anti-Money Laundering Act), which mandate customer identification and verification before financial transactions can be processed.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other approved Philippine payment channels.
• Gaming operations: To operate games, calculate and settle wagers, apply bonuses and promotions, and maintain the integrity of the Platform's game outcomes.
• Responsible gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may require intervention under 96phj's responsible gaming framework.
• Legal and regulatory compliance: To fulfill 96phj's obligations under Philippine gaming regulations, the Anti-Money Laundering Act (as amended by RA 10365 and RA 11521), the Data Privacy Act, and any applicable tax reporting requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeovers, bonus abuse, and other forms of Platform misuse.
• Customer support: To respond to inquiries, resolve disputes, and maintain records of communications for quality assurance.
• Marketing communications: With your consent (which may be withdrawn at any time), to send you promotional offers, bonus notifications, and platform updates via email or SMS.
• Platform improvement: To analyze aggregated and anonymized usage data for the purpose of improving the 96phj Platform's features, performance, and user experience.

6Legal Basis for Processing

Under the Data Privacy Act of 2012, 96phj relies on the following legal bases for processing your personal data:

• Contract performance: Processing necessary to perform our contract with you (the Terms & Conditions), including account operation, payment processing, and game settlement.
• Legal obligation: Processing required to comply with Philippine law, including KYC/AML obligations under RA 9160, tax reporting obligations, and PAGCOR licensing requirements.
• Legitimate interests: Processing for fraud prevention, Platform security, and responsible gaming monitoring, where such processing does not override your fundamental rights.
• Consent: Processing for direct marketing communications, where you have provided explicit, informed, and freely given consent. You may withdraw marketing consent at any time by contacting [email protected].

7Data Sharing & Disclosure

96phj does not sell, rent, or trade your personal data. We share your personal data only in the following circumstances and with the following categories of recipients:

• Payment service providers: GCash (Mynt), PayMaya (Maya Bank), BPI, BDO, Metrobank, and other BSP-supervised payment processors require transaction data to process your deposits and withdrawals.
• KYC and identity verification providers: Accredited third-party identity verification services process your government ID images and biometric data solely for the purpose of confirming your identity and age in compliance with KYC requirements.
• Game content providers: Licensed game studios providing live dealer, slot, and other game content to the 96phj Platform may receive anonymized or pseudonymized session data as required for game integrity and certification purposes.
• Regulatory and law enforcement authorities: 96phj is required by Philippine law to report certain transactions and account information to the Anti-Money Laundering Council (AMLC), PAGCOR, the Bureau of Internal Revenue (BIR), and law enforcement agencies when compelled by lawful order or statutory obligation.
• Cloud and IT service providers: 96phj uses reputable cloud infrastructure providers for data hosting. These providers act as processors under written data processing agreements and are prohibited from using your data for their own purposes.
• Corporate transactions: In the event of a merger, acquisition, or sale of 96phj's business or assets, personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

8Cookies & Tracking Technologies

96phj uses cookies and similar tracking technologies on 96phj.app to enhance Platform functionality, maintain login sessions, and analyze usage patterns. The following types of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens that keep you logged in to your 96phj account. These cookies cannot be disabled without affecting Platform functionality.
• Performance and analytics cookies: Used to understand how Players navigate 96phj, which game categories are most visited, and where users encounter friction — enabling us to improve the Platform. Data collected is aggregated and anonymized.
• Functional cookies: Remember your preferences such as language settings and game lobby filters to provide a more personalized experience on return visits.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your 96phj account. 96phj does not use third-party advertising cookies or cross-site tracking technologies.

9Data Retention

96phj retains your personal data for as long as your account is active and for a period thereafter as required by applicable law. Specific retention periods include:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, in compliance with the Anti-Money Laundering Act's record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years following the transaction date, or longer if required by BIR audit or regulatory investigation.
• Customer support records: Retained for three (3) years following the resolution of the relevant inquiry or complaint.
• Marketing consent records: Retained for as long as your consent remains in effect and for one (1) year following withdrawal of consent.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with 96phj's data destruction procedures.

10Data Security

96phj implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your browser and 96phj.app.
• Encryption at rest for sensitive data fields, including government ID numbers and financial account details.
• Role-based access controls limiting employee access to personal data to only those with a documented operational need.
• Multi-factor authentication requirements for 96phj systems that access personal data.
• Regular security audits and penetration testing of the Platform and supporting infrastructure.
• Data breach detection and response procedures, including notification to the National Privacy Commission and affected individuals within the timeframes required by the DPA in the event of a qualifying personal data breach.

While 96phj takes all reasonable precautions to protect your data, no online system can guarantee absolute security. You are responsible for maintaining the confidentiality of your 96phj account credentials and for reporting any suspected unauthorized access immediately to [email protected].

11Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 96phj:

• Right to be informed: The right to be notified of the personal data we collect and how it is processed — satisfied by this Privacy Policy.
• Right of access: The right to request a copy of the personal data 96phj holds about you, and information about how it is being processed.
• Right to correction: The right to request correction of inaccurate or incomplete personal data in your 96phj account.
• Right to erasure ("right to be forgotten"): 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 96phj's legal retention obligations under the AMLA and other applicable laws.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes. Withdrawal of marketing consent does not affect the lawfulness of processing carried out before withdrawal.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines (www.privacy.gov.ph) if you believe your data privacy rights have been violated.

To exercise any of these rights, submit a written request to 96phj's Data Protection Officer at the contact details provided in Section 15. 96phj will respond within fifteen (15) working days of receiving a verifiable request.

12Children's Privacy and Minors

The 96phj Platform is strictly intended for adults aged 21 years or older, in compliance with PAGCOR regulations governing casino-style gaming in the Philippines. 96phj does not knowingly collect personal data from individuals under 21 years of age.

If 96phj discovers or has reasonable grounds to believe that a user is under 21 years of age, the account will be immediately suspended, all associated personal data will be reviewed, and the account will be permanently closed in compliance with applicable Philippine gaming regulations. Any balance in the account will be handled in accordance with PAGCOR's underage gambling protocols.

If you believe that a minor has registered on the 96phj Platform, please notify us immediately at [email protected].

13International Data Transfers

96phj primarily processes and stores personal data within data centers located in or serving the Philippines. In limited circumstances — for example, where a game content provider or cloud infrastructure partner operates servers in another jurisdiction — personal data may be transferred internationally.

Any international transfer of personal data by 96phj is conducted only to countries or entities that provide a level of data protection that is at minimum equivalent to the standards required by the Philippine Data Privacy Act of 2012, through the use of:

• Contractual clauses approved by the National Privacy Commission, or
• Standard data protection agreements with the receiving entity, or
• Transfers to jurisdictions with data protection laws recognized as adequate by the NPC.

14Updates to This Privacy Policy

96phj reserves the right to update or modify this Privacy Policy at any time. When material changes are made, 96phj will post the revised Policy on this page with an updated "Last Updated" date and, where required by the DPA, notify registered account holders via email or in-platform notification.

Your continued use of the 96phj Platform following the posting of a revised Privacy Policy constitutes your acknowledgment and, where applicable, your consent to the changes. We encourage you to review this Policy periodically.

15Contact Us & Data Protection Officer

For all data privacy inquiries, rights requests, complaints, or questions about this Privacy Policy, please contact the 96phj Data Protection Officer: