92ph Privacy Policy

1. Introduction & Scope

92ph is committed to protecting the privacy and personal data of all players who use the 92ph platform. This Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

This Policy applies to all personal data collected by 92ph through the 92ph.one website, any associated mobile-optimised interfaces, and all communications between you and 92ph, including email, live chat, and support ticket interactions. It does not apply to third-party websites or services that may be linked from the 92ph platform — those are governed by their own privacy policies.

92ph acts as the Personal Information Controller in respect of the personal data it collects from players. Where 92ph engages third-party service providers to process data on its behalf, those providers act as Personal Information Processors and are bound by data processing agreements consistent with this Policy and applicable Philippine law.

2. Personal Data We Collect

92ph collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Registration & Identity Data

This data is collected when you create a 92ph account and is required to verify your identity, confirm your eligibility (including the 21+ age requirement), and maintain your account.

2.2 Identity Verification (KYC) Data

Know Your Customer (KYC) verification is required before processing withdrawals above certain thresholds and in compliance with anti-money laundering (AML) obligations. Acceptable Philippine government IDs include PhilSys ID, passport, driver's licence, SSS ID, GSIS ID, PRC ID, and Voter's ID.

2.3 Financial & Transaction Data

Financial data is collected to process deposits and withdrawals, comply with AML regulations, and maintain accurate financial records as required by PAGCOR and Philippine law. 92ph does not store complete payment instrument credentials on its servers.

2.4 Gaming Activity Data

• Game history, bet amounts, win/loss records, and session durations.
• Bonus and promotion participation records.
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status).

2.5 Technical & Device Data

• IP address, device type, operating system, and browser type.
• Geolocation data (country/region level) to verify jurisdictional eligibility.
• Cookie identifiers and session tokens (see Section 6).
• Platform access logs and timestamps.

2.6 Communications Data

• Records of your communications with 92ph support, including live chat transcripts, email correspondence, and support ticket content.
• Survey responses and feedback submitted through the 92ph platform.

3. How 92ph Uses Your Personal Data

92ph uses the personal data it collects for the following purposes:

92ph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by applicable law.

4. Legal Basis for Processing

92ph processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform the contract between you and 92ph — specifically, to provide you with access to the 92ph gaming platform, process your transactions, and manage your account.
• Legal Obligation: Processing is necessary to comply with legal obligations applicable to 92ph, including PAGCOR regulatory requirements, anti-money laundering laws, and tax reporting obligations under Philippine law.
• Legitimate Interests: Processing is necessary for the legitimate interests of 92ph, including fraud prevention, platform security, responsible gaming monitoring, and improving the quality of 92ph services, provided that such interests are not overridden by your rights and interests.
• Consent: Where 92ph relies on your consent as the legal basis for processing — for example, for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

92ph does not sell your personal data to third parties. 92ph 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 Service Providers: GCash, PayMaya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive the financial data necessary to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and identity verification service providers who assist 92ph in verifying player identities and complying with AML obligations.
• Game Software Providers: Game providers whose titles are available on the 92ph platform may receive anonymised or pseudonymised gameplay data for technical and audit purposes.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies may receive data as required by law or regulatory mandate.
• Law Enforcement: 92ph may disclose personal data to law enforcement agencies where required by a valid legal order, warrant, or subpoena issued by a competent Philippine authority.
• IT & Infrastructure Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on behalf of 92ph under binding data processing agreements.
• Professional Advisers: Legal, accounting, and auditing firms engaged by 92ph, subject to professional confidentiality obligations.

6. Cookies & Tracking Technologies

92ph uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse usage patterns. A cookie is a small text file placed on your device when you visit the 92ph website. Cookies do not contain executable code and cannot access other data on your device.

The following categories of cookies are used on the 92ph platform:

• Strictly Necessary Cookies: These cookies are essential for the 92ph platform to function. They enable core features such as session management, login authentication, and security. These cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: These cookies remember your preferences — such as language settings and responsible gaming tool configurations — to provide a more personalised experience on 92ph.
• Analytics Cookies: These cookies collect anonymised information about how players use the 92ph platform, including pages visited, time spent, and navigation paths. This data helps 92ph improve platform performance and user experience.
• Security Cookies: These cookies assist in detecting and preventing fraudulent activity, bot access, and other security threats to the 92ph platform and its players.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 92ph platform. Strictly necessary and security cookies cannot be disabled as they are integral to platform operation and player protection.

7. Data Retention

92ph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements applicable to 92ph under Philippine law.

• Active Account Data: Personal data associated with an active 92ph account is retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and AML obligations.
• KYC & Identity Documents: Identity verification documents are retained for a minimum of five (5) years from the date of verification or account closure, whichever is later, as required by the Anti-Money Laundering Act of 2001 (as amended).
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Support Communications: Customer support records are retained for three (3) years from the date of the interaction, unless a longer retention period is required in connection with a dispute or legal proceeding.
• Marketing Data: Where you have consented to receive marketing communications from 92ph, your contact details and preferences are retained until you withdraw your consent or request erasure.

Upon expiry of the applicable retention period, 92ph will securely delete or anonymise your personal data in accordance with its data disposal procedures.

8. Data Security

92ph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data transmitted between your device and the 92ph platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including passwords and financial identifiers, is stored using strong cryptographic hashing and encryption.
• Access Controls: Access to personal data within 92ph is restricted to authorised personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular data protection training.
• Infrastructure Security: The 92ph platform is hosted on secure, regularly audited infrastructure with firewalls, intrusion detection systems, and continuous security monitoring.
• Vulnerability Management: 92ph conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in the platform.
• Incident Response: 92ph maintains a data breach response plan. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 92ph will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

9. Your Privacy Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by 92ph:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed by 92ph. This Privacy Policy fulfils that obligation.
• Right of Access: You have the right to request a copy of the personal data that 92ph holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data that 92ph holds about you. You may update certain account details directly through your 92ph account settings.
• Right to Erasure: You have 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 92ph's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to 92ph's overriding legitimate grounds.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 92ph has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact the 92ph Data Privacy Officer at the contact details provided in Section 13 of this Policy. 92ph will respond to all verified privacy rights requests within thirty (30) days of receipt, in accordance with NPC guidelines.

10. Children's Privacy & Age Restriction

The 92ph platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law and PAGCOR regulations governing online gaming. 92ph does not knowingly collect personal data from individuals under the age of 21.

During registration, all players are required to confirm that they are at least 21 years of age. 92ph conducts age verification as part of its KYC process and will suspend or close any account where it determines that the account holder is under 21 years of age. Any personal data collected from an underage individual will be deleted promptly upon discovery.

If you are a parent or guardian and believe that your child has registered on the 92ph platform, please contact 92ph support immediately so that the account can be closed and the data deleted.

11. Third-Party Links & Services

The 92ph platform may contain references to third-party payment providers and game software suppliers. While 92ph takes care to work only with reputable partners, 92ph is not responsible for the privacy practices of third-party services. Each third-party service operates under its own privacy policy, and 92ph encourages you to review those policies before providing any personal data directly to a third party.

92ph does not control and is not responsible for the content, privacy policies, or practices of any third-party websites or services that are not operated by 92ph.

12. Changes to This Privacy Policy

92ph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, 92ph will update the "Last Updated" date at the top of this page and, where practicable, notify registered players via email or an in-platform notification.

Your continued use of the 92ph platform after any changes to this Policy have been posted constitutes your acceptance of the revised Policy. If you do not agree with the changes, you must cease using the 92ph platform and may request account closure by contacting 92ph support.

92ph recommends that you review this Privacy Policy periodically to stay informed about how your personal data is being protected.

13. Contact & Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by 92ph, please contact the 92ph Data Privacy Officer:

Please include your registered username, a clear description of your request or concern, and any relevant details to help us respond efficiently. 92ph aims to acknowledge all privacy-related enquiries within five (5) business days and to resolve them within thirty (30) days, consistent with NPC guidelines.

You also have the right to file a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through its official government channels.