25ph9 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 25ph9 ("25ph9," "we," "us," or "our") collects, uses, stores, and discloses personal data in connection with your use of the 25ph9 online gaming platform, accessible at https://25ph9.app (the "Platform").

This Policy applies to all users of the 25ph9 Platform, including registered account holders, visitors who browse the Platform without registering, and any individual whose personal data is processed by 25ph9 in connection with the Platform's operation.

By accessing or using the 25ph9 Platform, you acknowledge that you have read, understood, and agree to the collection and use of your personal data as described in this Policy. If you do not agree, please discontinue use of the Platform immediately.

This Policy should be read together with the 25ph9 Terms & Conditions, which govern your use of the Platform generally.

2. Data Controller Information

25ph9 acts as the data controller for personal data collected through the Platform. As data controller, 25ph9 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

For all data privacy inquiries, requests, and complaints, you may contact our designated Data Privacy Officer (DPO) at: [email protected]

3. Personal Data We Collect

25ph9 collects the following categories of personal data from users of the Platform:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification numbers (e.g., Philippine passport number, SSS number, PhilSys reference number, driver's license number).
• Contact Data: Email address, mobile phone number, and residential address (including city, province, and postal code).
• Account Data: Username, encrypted password, account registration date, account status, and account preferences.
• Financial Data: Payment method details (e.g., GCash mobile number, bank account details for BPI, BDO, Metrobank, or UnionBank), deposit and withdrawal transaction history, and account balance information.
• Gaming Activity Data: Wager history, game session logs, win/loss records, bonus usage, and responsible gaming tool settings.
• Technical Data: IP address, device type, browser type and version, operating system, session timestamps, and cookies.
• Verification Data: Copies of identity documents submitted for Know Your Customer (KYC) verification purposes.
• Communications Data: Records of your communications with 25ph9 customer support, including chat logs and email correspondence.

25ph9 does not collect sensitive personal information (as defined under the DPA 2012) unless strictly required for identity verification or legal compliance purposes, and only with your explicit consent where required.

4. How We Collect Your Data

25ph9 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, server logs, and similar technologies.
• Third-party sources: Identity verification data from licensed KYC service providers; payment transaction data from payment processors such as GCash, PayMaya, and partner banks; and fraud prevention data from third-party risk management services.

5. Purposes and Legal Basis for Processing

25ph9 processes your personal data for the following purposes, each supported by a lawful basis under the DPA 2012:

• Account registration and management — necessary for the performance of the contract between you and 25ph9.
• Identity verification (KYC) — necessary for compliance with anti-money laundering (AML) regulations and PAGCOR licensing requirements.
• Processing deposits and withdrawals — necessary for the performance of the contract and for compliance with financial regulations.
• Providing gaming services — necessary for the performance of the contract.
• Fraud prevention and security monitoring — necessary for the legitimate interests of 25ph9 in protecting the Platform and its users.
• Responsible gaming compliance — necessary for compliance with legal obligations and for the protection of users' vital interests.
• Customer support — necessary for the performance of the contract and for the legitimate interests of 25ph9.
• Marketing communications — based on your consent, where you have opted in to receive promotional communications from 25ph9. You may withdraw consent at any time.
• Legal and regulatory compliance — necessary for compliance with applicable Philippine laws and regulations, including reporting obligations to PAGCOR and other authorities.

6. Sharing of Personal Data

25ph9 does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Licensed third-party services used to verify your identity and comply with AML obligations.
• Fraud prevention and risk management services: Third-party providers that assist 25ph9 in detecting and preventing fraudulent activity on the Platform.
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulatory obligation.
• Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by 25ph9, subject to professional confidentiality obligations.
• IT and platform service providers: Cloud hosting, data storage, and platform infrastructure providers who process data on behalf of 25ph9 under data processing agreements.

All third parties with whom 25ph9 shares personal data are required to process such data in accordance with applicable data protection laws and the terms of their agreements with 25ph9.

7. Cookies and Tracking Technologies

25ph9 uses cookies and similar technologies on the Platform for the following purposes:

• Essential cookies: Required for the Platform to function correctly, including session management, authentication, and security features. These cannot be disabled without affecting Platform functionality.
• Performance cookies: Used to collect anonymized data about how users interact with the Platform, helping 25ph9 identify and fix technical issues and improve user experience.
• Preference cookies: Used to remember your Platform settings and preferences, such as language and display options.

25ph9 does not use third-party advertising cookies or cross-site tracking technologies. You may manage cookie preferences through your browser settings; however, disabling essential cookies may impair your ability to use the Platform.

8. Data Retention

25ph9 retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Specific retention periods include:

• Account data and gaming records: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and PAGCOR record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• KYC verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer support communications: Retained for two (2) years from the date of the communication, unless a longer period is required for ongoing dispute resolution.
• Technical and log data: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 25ph9's data disposal procedures.

9. Data Security

25ph9 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the 25ph9 Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls limiting access to personal data to authorized personnel only.
• Regular security assessments and penetration testing of the Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While 25ph9 takes data security seriously, no system is completely immune to security risks. In the event of a personal data breach that is likely to result in harm to affected individuals, 25ph9 will notify the NPC and affected users in accordance with the requirements of the DPA 2012.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 25ph9:

• Right to be informed: The right to be informed of how your personal data is collected, used, and processed — which this Policy fulfills.
• Right of access: The right to request a copy of the personal data 25ph9 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to 25ph9's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact 25ph9's Data Privacy Officer at [email protected]. 25ph9 will respond to verified data subject requests within fifteen (15) business days, as required by the DPA 2012.

11. Children's Privacy

The 25ph9 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 25ph9 does not knowingly collect personal data from individuals under the age of 21.

If 25ph9 becomes aware that personal data has been collected from an individual under 21 years of age, such data will be deleted immediately and the associated account will be closed. If you believe a minor has registered on the Platform, please notify us immediately at [email protected].

12. Changes to This Privacy Policy

25ph9 reserves the right to update or amend this Privacy Policy at any time. The revised Policy will be published on this page with an updated "Last Updated" date. Where changes are material, 25ph9 will endeavor to notify registered users via email or in-platform notification prior to the changes taking effect.

Your continued use of the 25ph9 Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how 25ph9 protects your personal data.

13. Contact and Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 25ph9, please contact our Data Privacy Officer:

Data Privacy Officer — 25ph9
Email: [email protected]

For complaints that remain unresolved after contacting 25ph9, you may escalate your concern to the National Privacy Commission (NPC) of the Philippines. The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012.

25ph9 is committed to working cooperatively with the NPC and to resolving any data privacy complaints in a fair and timely manner.