96phn Privacy Policy

1 Introduction and Scope

96phn ("96phn", "we", "us", "our") is committed to protecting the privacy and personal data of every player who registers and uses the 96phn platform at https://96phn.cam (the "Platform"). This Privacy Policy has been prepared in accordance with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act 10173, "DPA") and its Implementing Rules and Regulations, as enforced by the National Privacy Commission ("NPC").

This Privacy Policy applies to all personal data collected through the Platform, including data submitted at the point of registration, during identity verification, in the course of financial transactions, through game activity, and via any communication you have with the 96phn support team. It applies to all registered players, prospective players who visit the Platform without registering, and any individual whose data is processed by 96phn in connection with the Platform's operation.

This Privacy Policy should be read alongside the 96phn Terms & Conditions, which govern your overall use of the Platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on a data privacy matter, this Privacy Policy shall prevail.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, 96phn acts as the Personal Information Controller ("PIC") in respect of the personal data it collects and processes in connection with the Platform. As PIC, 96phn determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the DPA and all applicable regulations issued by the NPC.

96phn has appointed a Data Privacy Officer ("DPO") responsible for overseeing data protection compliance and serving as the primary point of contact for data subjects wishing to exercise their rights under RA 10173. The DPO's contact details are provided in Section 15 of this Policy.

3 Personal Data We Collect

96phn collects personal data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed. The categories of personal data collected include the following:

96phn does not intentionally collect sensitive personal information as defined under Section 3(l) of RA 10173 (such as health, racial or ethnic origin, religious beliefs, or political opinions) unless it is directly necessary for legal compliance. Where such data is incidentally disclosed, it will be treated with the heightened protections required by the DPA.

4 Legal Basis for Processing

96phn processes your personal data on one or more of the following lawful bases as provided under Section 12 of RA 10173:

• Consent: Where you have given clear, informed, and freely given consent to processing for a specific purpose — such as receiving promotional communications from 96phn.
• Contractual Necessity: Where processing is necessary to perform the contract between you and 96phn — i.e., to operate your player account, process deposits and withdrawals, and deliver gaming services.
• Legal Obligation: Where processing is required to comply with a legal obligation binding on 96phn, including obligations under the Anti-Money Laundering Act (RA 9160), the Data Privacy Act (RA 10173), and PAGCOR gaming regulations.
• Legitimate Interests: Where processing is necessary for the legitimate interests of 96phn, provided those interests are not overridden by your rights and freedoms — for example, fraud prevention, platform security monitoring, and product improvement analytics.

5 How We Use Your Personal Data

96phn uses the personal data it collects for the following specific purposes:

• Account Management: Creating, maintaining, verifying, and administering your 96phn player account, including processing your 96phn login credentials and keeping your account details accurate and current.
• Transaction Processing: Processing PHP deposits via GCash, Maya, BPI, BDO, Metrobank, and other approved payment methods; processing withdrawal requests to your nominated payment method; maintaining complete and accurate financial records as required by law.
• Identity Verification (KYC): Verifying your identity and age in compliance with PAGCOR guidelines, RA 10173, and the Anti-Money Laundering Act of 2001 (RA 9160, as amended).
• Platform Security: Detecting and preventing fraud, money laundering, bonus abuse, multi-accounting, and other prohibited activities; protecting the security and integrity of the 96phn platform and its infrastructure.
• Customer Support: Responding to queries, complaints, and disputes submitted through live chat, email, or other support channels; maintaining support interaction records for quality assurance and dispute resolution.
• Responsible Gaming: Monitoring gameplay patterns to identify potential signs of problem gambling; administering deposit limits, self-exclusion requests, and cool-off periods as requested by players or as required under responsible gaming obligations.
• Legal and Regulatory Compliance: Meeting 96phn's obligations under all applicable Philippine laws, regulations, and directions from the NPC, PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent authorities.
• Marketing Communications (with consent): Sending promotional offers, bonus notifications, and platform news to players who have consented to receive such communications. You may withdraw marketing consent at any time by contacting support or adjusting your notification preferences in account settings.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the 96phn platform, game lobby, payment flows, and overall player experience.

96phn will not use your personal data for any purpose that is incompatible with the purposes listed above without obtaining your separate consent or unless otherwise permitted by law.

6 Sharing and Disclosure of Personal Data

96phn does not sell, rent, or trade your personal data to any third party for commercial purposes. 96phn may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements or legal obligations:

• Game Providers: Certified game providers (including but not limited to PG Soft, Pragmatic Play, Jili Games, and Habanero) receive session identifiers and account references necessary to deliver game content and record game outcomes. Game providers do not receive your full identity or financial data.
• Payment Processors: Licensed Philippine payment service providers (GCash, Maya/PayMaya, InstaPay network participants, PESONet banks) receive the minimum financial data necessary to process your deposits and withdrawals in PHP.
• Identity Verification Partners: Regulated KYC and AML compliance service providers may process copies of your government-issued identification documents for the purpose of verifying your identity, age, and source of funds where required.
• IT and Infrastructure Partners: Trusted technology service providers that host, maintain, or support the 96phn platform infrastructure — acting as Personal Information Processors ("PIP") under data processing agreements that require them to handle data only on 96phn's instructions and in accordance with the DPA.
• Legal and Regulatory Authorities: The National Privacy Commission, PAGCOR, the Anti-Money Laundering Council, the Bureau of Internal Revenue, law enforcement agencies, and courts of competent jurisdiction, where disclosure is required by law, court order, or regulatory direction.
• Professional Advisers: Lawyers, auditors, and other professional advisers retained by 96phn, subject to binding confidentiality obligations, where disclosure is necessary in connection with legal proceedings, regulatory investigations, or corporate transactions.

7 Cookies and Tracking Technologies

The 96phn Platform uses cookies and similar tracking technologies to ensure the proper functioning of the site, to maintain your logged-in session, to detect fraud, and to collect anonymised analytics data that helps us improve platform performance. The following types of cookies may be placed on your device when you access 96phn:

• Strictly Necessary Cookies: Required for core platform functionality — including session management, 96phn login state persistence, and security token validation. These cookies cannot be disabled without preventing access to the Platform.
• Functional Cookies: Remember your language preference, display settings, and game lobby filters to personalise your Platform experience across sessions.
• Analytics Cookies: Collect aggregated, anonymised data about page visits, session durations, game loading performance, and navigation paths to help 96phn identify and fix usability issues. No individual player is identifiable from this data.
• Security Cookies: Assist in fraud detection, bot identification, and suspicious activity monitoring to protect your account and the broader Platform from abuse.

Non-essential cookies (functional and analytics) may be declined through your browser settings. Instructions for managing cookies in Chrome, Safari, Firefox, and Edge are available in each browser's respective help documentation. Please note that disabling functional cookies may affect your 96phn experience — for example, resetting your session preferences on each visit.

96phn does not use third-party advertising cookies or cross-site tracking technologies for behavioural advertising purposes.

8 Data Security Measures

96phn implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure, in compliance with Section 20 of RA 10173 and the NPC's security guidelines. These measures include:

• Encryption in Transit: All data transmitted between your device and the 96phn Platform is encrypted using TLS 1.2/1.3 and 256-bit SSL certificates. This includes 96phn login credentials, payment information, and account communications.
• Encryption at Rest: Sensitive personal data stored in 96phn's databases — including identity documents, financial data, and authentication credentials — is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data within 96phn's systems is restricted on a role-based, need-to-know basis. Internal access is logged and regularly audited. Staff with access to personal data are subject to confidentiality obligations.
• Two-Factor Authentication: Player accounts are protected by optional SMS-based two-factor authentication via registered Philippine mobile numbers. 96phn strongly recommends that all players enable 2FA through account settings.
• Security Monitoring: Continuous monitoring of Platform systems for anomalous activity, intrusion attempts, and suspected data breaches, with incident response procedures aligned to NPC notification requirements.
• Regular Security Audits: Periodic third-party security assessments and penetration testing of Platform infrastructure to identify and remediate vulnerabilities.

While 96phn employs robust security measures, no online system can guarantee absolute security. Players are responsible for keeping their own 96phn login credentials confidential and for immediately notifying 96phn support if they suspect unauthorised access to their account.

9 Data Retention

96phn retains personal data only for as long as is necessary for the purposes for which it was collected, or for as long as required by applicable Philippine law — whichever period is longer. The following general retention periods apply:

• Active Account Data: Retained for the duration of the account's active status plus such additional period as required by law.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with the Anti-Money Laundering Act (RA 9160) and BIR record-keeping requirements.
• Identity Verification Documents: Retained for a minimum of five (5) years from the date of verification or from account closure, whichever is later, as required under AML regulations.
• Customer Support Records: Retained for a minimum of three (3) years from the date of the interaction for dispute resolution and quality assurance purposes.
• Technical and Usage Logs: Retained for up to twelve (12) months for security monitoring and fraud prevention purposes, after which they are deleted or anonymised.
• Marketing Consent Records: Retained for as long as the associated account remains active, or until consent is withdrawn, whichever is earlier, plus a reasonable period thereafter for compliance documentation.

Upon expiry of the applicable retention period, personal data will be securely deleted, destroyed, or anonymised so that it can no longer be associated with an identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical analysis purposes.

10 Your Rights Under RA 10173

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 96phn. To exercise any of these rights, please contact the 96phn Data Privacy Officer as described in Section 15:

96phn will respond to all data subject rights requests within thirty (30) days of receipt. Where a request is particularly complex or numerous, this period may be extended by a further sixty (60) days, in which case you will be notified within the initial thirty-day period and given an explanation for the extension.

11 Children and Minors

The 96phn Platform is strictly intended for individuals who are 21 years of age or older, in compliance with PAGCOR guidelines governing minimum age for participation in casino-style gaming activities in the Philippines. 96phn does not knowingly collect personal data from individuals under the age of 21.

If 96phn becomes aware that personal data has been collected from a person under 21 years of age without appropriate parental or guardian consent, it will immediately take steps to delete that data and close the associated account. If you believe that a minor under 21 has submitted personal data to 96phn, please contact the DPO at the details in Section 15 immediately so that appropriate action can be taken.

Parents and guardians of minors are encouraged to use internet filtering and parental control software on shared family devices to prevent minors from accessing online gambling platforms, including 96phn.

12 Cross-Border Data Transfers

Some of 96phn's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to countries that may not provide the same level of data protection as Philippine law, 96phn will ensure that appropriate safeguards are in place — including contractual clauses that impose obligations equivalent to those required under RA 10173, or reliance on the recipient country's whitelisted data protection framework as recognised by the NPC.

Game providers who receive session data to deliver game content may operate servers located in various jurisdictions. In all such cases, data sharing is limited to the minimum information necessary for game delivery, and game providers are contractually required to protect that data in accordance with standards at least equivalent to RA 10173.

13 Third-Party Links and Services

The 96phn Platform may contain references or links to third-party services — such as game providers' terms pages or payment processor help documentation. This Privacy Policy applies solely to personal data collected and processed by 96phn directly. It does not apply to data practices of any third-party service, platform, or website that you access independently of 96phn.

96phn is not responsible for the privacy practices of third-party game providers, payment processors, or any other external entities. Players are encouraged to review the privacy policies of any third-party service they interact with, particularly payment service providers such as GCash and Maya, whose data practices are governed by their own respective privacy policies and Philippine BSP regulations.

14 Updates to This Privacy Policy

96phn reserves the right to update this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidance, Platform functionality, or 96phn's data processing practices. Material changes — meaning changes that significantly affect your rights or the way we process your personal data — will be communicated to registered players via their registered email address or through a prominent notice on the Platform, with at least seven (7) days' prior notice where practicable.

The current version of the Privacy Policy, including its effective date and version number, is always accessible at https://96phn.cam/privacy-policy. Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acknowledgment and acceptance of the updated terms.

If you object to any changes to this Privacy Policy, you must discontinue your use of the Platform and may request voluntary account closure in accordance with the Terms & Conditions. Any data processing carried out under the prior version of the Policy before the effective date of the update remains lawful under that prior version.

15 Contact Information and Data Privacy Officer

If you have questions about this Privacy Policy, wish to exercise your data subject rights under RA 10173, or want to report a suspected data privacy concern, please contact the 96phn Data Privacy Officer using the details below. All privacy-related correspondence must be submitted in English.

If you are not satisfied with 96phn's response to a data privacy request or complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory authority responsible for administering and enforcing RA 10173. For more information, visit the NPC's official website at privacy.gov.ph (do not navigate there via this page — search for it directly in your browser).