Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how spinph9.club ("spinph9," "we," "our," or "us") collects, uses, discloses, stores, and protects the personal information of individuals ("you," "Player," or "User") who access or use the spinph9 online gaming platform at https://spinph9.club.

spinph9 is committed to maintaining the trust of Filipino players and to handling personal data responsibly, transparently, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations issued by the National Privacy Commission ("NPC").

By registering for a spinph9 account, accessing the Platform, or continuing to use the services offered by spinph9 after this Policy has been made available to you, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2 Data Controller

For the purposes of the DPA and applicable data protection law, spinph9 is the personal information controller responsible for the processing of your personal data in connection with your use of the Platform.

If you have any questions, concerns, or requests relating to this Policy or the processing of your personal data, please contact our Data Protection Officer ("DPO") at:

• Email: [email protected]
• Subject line: Data Privacy Request – spinph9

3 Personal Data We Collect

3.1 Registration and Account Data

When you register for a spinph9 account, we collect the following personal information:

• Full legal name;
• Date of birth (to verify the 21+ age requirement);
• Email address;
• Mobile phone number (Philippine mobile numbers, e.g., 09xx numbers);
• Username and hashed password;
• Residential address.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and Anti-Money Laundering Act (AMLA) obligations, spinph9 collects KYC documentation including:

• Government-issued photo identification (e.g., PhilSys National ID, passport, driver's licence, UMID, SSS/GSIS ID);
• Proof of address (e.g., utility bill, bank statement);
• Selfie or liveness verification image where required;
• Payment method verification documents.

3.3 Financial and Transaction Data

spinph9 records all financial transactions conducted on the Platform, including deposit amounts, withdrawal requests, payment method references (e.g., GCash registered name, BPI account last four digits), transaction timestamps, and game bet histories.

3.4 Technical and Usage Data

When you access the spinph9 Platform, we automatically collect technical information including:

• IP address and approximate geolocation;
• Device type, operating system, and browser version;
• Session duration, pages visited, and features accessed;
• Referring URL and exit pages.

3.5 Communications Data

We retain records of communications you have with spinph9, including live chat transcripts, support emails, and any feedback or complaints you submit.

4 How We Collect Your Data

spinph9 collects personal data through the following means:

• Directly from you — via account registration forms, KYC submission, deposit and withdrawal transactions, support communications, and any surveys or promotions you participate in;
• Automatically — through cookies, server logs, and similar technologies when you access and interact with the Platform;
• From third parties — including identity verification service providers, payment processors (e.g., GCash, Maya, InstaPay), fraud detection services, and game providers whose software runs on the Platform.

5 How We Use Your Personal Data

spinph9 uses personal data collected from Filipino players for the following purposes:

• To create and manage your spinph9 account;
• To verify your identity and age (21+) in compliance with PAGCOR and AMLA requirements;
• To process deposits, withdrawals, and betting transactions;
• To detect, investigate, and prevent fraud, money laundering, and prohibited conduct;
• To provide customer support and respond to enquiries;
• To administer bonuses, promotions, and the spinph9 VIP loyalty programme;
• To send service-related communications (e.g., transaction confirmations, security alerts, policy updates);
• To send marketing communications where you have provided explicit consent (opt-in only);
• To improve platform performance, game selection, and user experience through analytics;
• To comply with applicable Philippine law, including reporting obligations to PAGCOR and AMLC.

6 Legal Basis for Processing

Under the DPA, spinph9 processes your personal data based on the following legal grounds:

• Contractual necessity — processing required to register and maintain your account, process transactions, and deliver spinph9 services;
• Legal obligation — processing required to comply with PAGCOR licensing conditions, AMLA reporting requirements, and NPC directives;
• Legitimate interests — processing for fraud prevention, platform security, and analytics, where these interests do not override your privacy rights;
• Consent — processing for optional purposes such as marketing communications, where you have given explicit consent that can be withdrawn at any time.

7 Data Sharing and Disclosure

spinph9 does not sell or trade your personal data. We may share your information with the following categories of recipients where necessary:

• Payment processors — GCash, Maya, BPI, BDO, Metrobank, and other payment channels, solely to facilitate transactions;
• Identity verification providers — third-party KYC and AML screening services under confidentiality agreements;
• Game providers — game studios whose titles run on the spinph9 Platform, limited to the data necessary to operate the games;
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies where required by law;
• Service providers — cloud hosting providers, customer support platform operators, and analytics services, all subject to data processing agreements that prohibit independent use of your data.

All third parties with whom spinph9 shares personal data are contractually required to maintain appropriate technical and organisational measures to protect that data.

8 Data Retention

spinph9 retains personal data for as long as necessary to fulfil the purposes described in this Policy and to comply with applicable legal obligations. Specific retention periods include:

• Account data: retained for the life of the account plus five (5) years after account closure;
• KYC and identity documents: retained for a minimum of five (5) years after the end of the business relationship, as required by AMLA;
• Transaction records: retained for a minimum of five (5) years;
• Marketing consent records: retained until consent is withdrawn plus one (1) year;
• Support communications: retained for three (3) years.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised.

9 Cookies and Tracking Technologies

spinph9 uses the following categories of cookies on the Platform:

• Essential cookies — required for the Platform to function, including login session management and security tokens. These cannot be disabled.
• Analytics cookies — used to understand aggregate usage patterns (e.g., which games are most popular, which pages are visited). Data is collected in aggregate and does not identify individual players.
• Preference cookies — used to remember your display and language preferences across sessions.

spinph9 does not use third-party advertising or retargeting cookies. You may disable non-essential cookies through your browser settings; however, disabling essential cookies may impair your ability to use the Platform.

10 Data Security

spinph9 implements the following technical and organisational measures to protect your personal data:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the spinph9 Platform;
• Encryption at rest for all personally identifiable information stored in spinph9 databases;
• bcrypt hashing with unique salts for all account passwords;
• Role-based access controls restricting employee access to personal data on a need-to-know basis;
• Multi-factor authentication required for administrative system access;
• Regular third-party security audits and penetration testing;
• Real-time intrusion detection and anomaly monitoring.

Despite these measures, no internet transmission or electronic storage system is 100% secure. In the event of a personal data breach that affects your rights and freedoms, spinph9 will notify the NPC within 72 hours and affected players as soon as practicable, in accordance with NPC Circular No. 16-03.

11 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by spinph9:

• Right to be informed — the right to know how your data is being processed, as described in this Policy;
• Right of access — the right to request a copy of the personal data spinph9 holds about you;
• Right to rectification — the right to request correction of inaccurate or incomplete personal data;
• Right to erasure (right to be forgotten) — the right to request deletion of your personal data, subject to spinph9's legal retention obligations;
• Right to object — the right to object to processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to data portability — the right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint — the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Privacy Request." spinph9 will respond within fifteen (15) business days.

12 Children's Privacy

The spinph9 Platform is strictly prohibited for individuals under the age of 21. spinph9 does not knowingly collect personal data from anyone under 21 years of age. If we discover that personal data has been collected from an individual who is under 21, we will delete that data and close the associated account immediately. If you believe a minor has registered on spinph9, please notify us at [email protected].

13 International Data Transfers

The spinph9 Platform is operated primarily from servers located in the Philippines. Some of the third-party service providers used by spinph9 (e.g., cloud infrastructure providers, game studios) may process data in jurisdictions outside the Philippines. Where such transfers occur, spinph9 ensures that appropriate safeguards are in place — such as contractual clauses requiring the receiving party to maintain data protection standards equivalent to those under the DPA — before any transfer takes place.

14 Changes to This Privacy Policy

spinph9 reserves the right to update or revise this Privacy Policy at any time. Material changes will be communicated to registered players via email or by prominent notice on the Platform prior to the change taking effect. The "Last Updated" date at the top of this page reflects the most recent revision.

Your continued use of the spinph9 Platform after the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree with the revised Policy, you must stop using the Platform and may request account closure.

15 Contact Us

For any questions, concerns, or data subject requests relating to this Privacy Policy or spinph9's data processing practices, please contact:

• Email: [email protected]
• Subject line: Privacy Policy – spinph9
• Live Chat: Available 24/7 on spinph9.club

spinph9 targets a response time of fifteen (15) business days for all formal data privacy requests. Complaints may also be submitted to the National Privacy Commission of the Philippines at privacy.gov.ph (plain text — not a link).