96phj Privacy Policy

This Privacy Policy ("Policy") is issued by 96phj ("96phj," "we," "us," "our") and applies to all personal data collected in connection with your registration and use of the 96phj online gaming platform at 96phj.club ("the Platform"). This Policy is incorporated by reference into the 96phj Terms & Conditions.

By registering an account on the 96phj platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

1. Introduction

1.1 96phj is committed to protecting the privacy and personal data of all players registered on the Platform. This Policy sets out in plain language what data 96phj collects, why it is collected, how it is used, with whom it may be shared, how long it is retained, and what rights you have over your personal data.

1.2 96phj operates under PAGCOR regulation and is subject to PAGCOR's data governance requirements in addition to the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations ("IRR").

1.3 This Policy applies to all personal data collected through the Platform, including data collected during registration, account verification (KYC), gameplay, payment transactions, customer support interactions, and marketing communications.

2. Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, 96phj is the personal information controller of all data collected through the Platform. Our designated Data Protection Officer (DPO) can be contacted at the address provided in Section 14 of this Policy.

2.2 96phj is registered with the National Privacy Commission (NPC) of the Philippines as required under the DPA and its IRR.

3. Personal Data We Collect

96phj collects the following categories of personal data:

3.1 Identity and Registration Data

• Full legal name as appearing on government-issued ID
• Date of birth
• Philippine residential address
• Nationality and citizenship
• Government-issued identification document type and number (UMID, SSS, PhilHealth, Voter's ID, Driver's License, or Passport)
• Selfie or live photo for identity verification

3.2 Contact Data

• Philippine mobile number (Globe or Smart)
• Email address

3.3 Financial and Transaction Data

• GCash or Maya account number linked to your 96phj wallet
• Bank account details for bank transfer withdrawals (BPI, BDO, Metrobank, etc.)
• Deposit and withdrawal history
• Cryptocurrency wallet addresses (USDT TRC20 transactions only)
• Transaction amounts and timestamps

3.4 Gaming and Behavioral Data

• Game session history, wagering records, and outcomes
• Bonus usage and wagering progress data
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion status)
• Game preferences and platform navigation patterns

3.5 Technical and Device Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Device fingerprint for fraud detection and security
• Session timestamps and login history
• Cookies and similar tracking technology data (see Section 8)

3.6 Communications Data

• Customer support chat transcripts and email correspondence
• Feedback and survey responses
• Marketing communication engagement data (email opens, notification interactions)

96phj does not collect sensitive personal information as defined under Section 3(l) of RA 10173 (including racial or ethnic origin, political opinion, religious belief, health data, or biometric data) except where expressly required for identity verification under PAGCOR KYC regulations, in which case such data is processed under explicit consent.

4. How We Collect Your Data

4.1 Directly from you: Registration form, KYC document upload, deposit and withdrawal transactions, customer support interactions, and feedback submissions.

4.2 Automatically: When you access and use the Platform, technical data including IP address, device information, and session data are collected automatically via cookies, server logs, and analytics tools.

4.3 From payment providers: When you link GCash, Maya, or a bank account to your 96phj wallet, the relevant payment provider confirms account ownership details to enable transaction processing and fraud prevention.

4.4 From identity verification services: 96phj uses PAGCOR-approved third-party KYC verification services to cross-reference identity documents provided during registration.

5. How We Use Your Personal Data

96phj uses the personal data it collects for the following purposes:

Purpose	Data Used	Legal Basis
Account registration and management	Identity, contact data	Contract performance
KYC identity verification	Identity, ID documents	Legal obligation (PAGCOR)
Processing deposits and withdrawals	Financial, transaction data	Contract performance
Fraud prevention and security monitoring	Technical, transaction data	Legitimate interest
Anti-money laundering compliance	Identity, financial data	Legal obligation
Responsible gaming compliance	Gaming, behavioral data	Legal obligation (PAGCOR)
Customer support	Contact, communications data	Contract performance
Marketing communications (opt-in)	Contact, engagement data	Consent
Platform analytics and improvement	Technical, behavioral data	Legitimate interest

6. Legal Basis for Data Processing

6.1 Performance of a contract: Most data processing on the 96phj platform is necessary for the performance of the contract between you and 96phj — i.e., providing the gaming services you have registered to use.

6.2 Legal obligation: 96phj processes certain data because it is legally required to do so under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.

6.3 Legitimate interests: 96phj processes technical and behavioral data for fraud prevention, security monitoring, and platform improvement — these represent legitimate interests that do not override your fundamental privacy rights.

6.4 Consent: Marketing communications and non-essential cookies are processed only on the basis of your explicit consent, which you may withdraw at any time.

7. Data Sharing and Disclosure

7.1 96phj does not sell, rent, or trade your personal data to third parties for their own commercial or marketing purposes.

7.2 96phj may share your personal data with the following categories of recipients, solely to the extent necessary for the stated purpose:

• PAGCOR: As 96phj's licensing regulator, PAGCOR has the right to inspect and access player data in connection with regulatory oversight, investigation, or audit.
• Payment service providers: GCash, Maya, BPI, BDO, Metrobank, and other payment partners receive only the data necessary to process your specific transaction.
• KYC verification providers: PAGCOR-approved identity verification services receive identity documents for the sole purpose of completing KYC verification.
• Anti-fraud and AML services: Third-party fraud detection and anti-money laundering screening services receive transaction and identity data solely for compliance purposes.
• Law enforcement and government authorities: 96phj will disclose personal data to Philippine government agencies, law enforcement bodies, or courts where required by law, court order, or regulatory directive.
• Technology and hosting providers: 96phj's cloud infrastructure and software providers process technical data under strict data processing agreements that prohibit unauthorized use.

7.3 All third-party data processors engaged by 96phj are bound by data processing agreements that require them to process your data only on 96phj's documented instructions, implement appropriate security measures, and comply with the DPA.

8. Cookies and Tracking Technologies

8.1 96phj uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device that help the Platform function correctly and enable analytics.

8.2 The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function — including session authentication, security tokens, and load balancing. These cannot be disabled without disabling core platform functionality.
• Functional cookies: Remember your preferences, language settings, and game display options to improve your experience.
• Analytics cookies: Collect anonymized data about how players navigate the Platform to enable performance improvements. These are activated only with your consent.
• Marketing cookies: Used to deliver relevant promotions and measure campaign effectiveness. Activated only with your explicit consent.

8.3 You may manage your cookie preferences via the cookie settings panel on the Platform. Withdrawing consent for non-essential cookies will not affect your ability to use core Platform functionality.

9. Data Retention

9.1 96phj retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to applicable legal and regulatory minimum retention requirements.

9.2 Financial transaction records, KYC documentation, and account history are retained for a minimum of five (5) years following account closure in compliance with PAGCOR regulations and the Anti-Money Laundering Act (AMLA).

9.3 Customer support communications are retained for two (2) years following resolution of the relevant matter.

9.4 Marketing engagement data is retained until you withdraw consent for marketing communications or for a maximum of three (3) years from your last interaction, whichever is earlier.

9.5 Following the applicable retention period, personal data is securely deleted or irreversibly anonymized.

10. Data Security

10.1 96phj implements technical and organizational security measures appropriate to the risk associated with processing your personal data, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and 96phj servers
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial data
• Access controls limiting data access to authorized personnel with a legitimate need
• Multi-factor authentication for administrative access to systems containing player data
• Regular penetration testing and security audits conducted by independent third parties
• Intrusion detection and monitoring systems operating 24/7

10.2 Personal Data Breaches. In the event of a personal data breach likely to adversely affect your privacy rights or freedoms, 96phj will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required under the DPA. Affected players will be notified without undue delay where the breach is likely to result in high risk to their rights.

11. Your Data Privacy Rights

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

To exercise any of these rights, contact the 96phj Data Protection Officer using the details in Section 14. 96phj will respond to all data rights requests within thirty (30) calendar days. Where a request cannot be fulfilled in full due to legal or regulatory obligations, 96phj will explain the reason in writing.

12. Children's and Minors' Privacy

12.1 The 96phj platform is strictly for adults aged 21 years and above. 96phj does not knowingly collect personal data from individuals under 21 years of age.

12.2 If 96phj becomes aware that personal data has been collected from a person under 21, the account will be immediately suspended, the data will be securely deleted, and any deposits made will be returned to the originating payment method in accordance with PAGCOR regulations.

12.3 If you believe a minor has accessed or registered on the 96phj platform, please contact our support team or Data Protection Officer immediately.

13. Updates to This Privacy Policy

13.1 96phj may update this Privacy Policy periodically to reflect changes in data processing practices, legal requirements, or Platform features. Material changes will be communicated to registered players via email or in-platform notification prior to the effective date.

13.2 The date of the most recent revision is displayed at the top of this Policy. Continued use of the Platform following notification of a material change constitutes acceptance of the updated Policy.

13.3 We recommend reviewing this Policy periodically to stay informed about how 96phj protects your personal data.

14. Contact Information & Data Protection Officer

For privacy-related inquiries, requests to exercise your data rights, or concerns about how 96phj processes your personal data, please contact:

• Data Protection Officer, 96phj
• Email: [email protected] (plain text — not a clickable link)
• Live Support: 24/7 live chat available on the 96phj platform
• Response Time: Data rights requests are acknowledged within 5 business days and responded to within 30 calendar days

If you believe that 96phj has not adequately addressed your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through the NPC's official complaint channels.