9abon Privacy Policy

1.1 9abon is committed to protecting the privacy and personal data of all users of the Platform. This Policy applies to all personal information collected by 9abon through the Platform, including information provided during registration, account use, customer support interactions, and through automated tracking technologies.

1.2 This Policy applies to all data subjects who interact with the Platform, whether as registered players, visitors browsing without an account, or individuals who contact 9abon's support channels.

1.3 This Policy should be read together with 9abon's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

1.4 9abon processes personal data in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines (the "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

2.1 For the purposes of the Data Privacy Act of 2012, the data controller responsible for your personal information is 9abon, operating the Platform at https://9abon.org.

2.2 9abon has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection law. The DPO may be contacted at [email protected] with the subject line "Data Protection Officer – Privacy Enquiry."

3.1 9abon collects the following categories of personal data from or about you:

3.2 9abon does not collect special categories of personal data (such as health data, religious beliefs, or biometric data for identification purposes) except where strictly required for responsible gaming assessments, in which case explicit consent will be sought.

4.1 9abon collects personal data through the following channels:

• Direct interactions: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, participating in promotions, or contacting our support team;
• Automated technologies: Data collected automatically as you use the Platform, including cookies, web beacons, server logs, and similar tracking technologies;
• Third-party sources: Identity verification agencies, payment processors (including GCash, Maya, BPI, BDO, and Metrobank), fraud prevention services, and credit reference agencies;
• Publicly available sources: Information available through public registries or databases where relevant to anti-money laundering compliance or responsible gaming obligations.

5.1 9abon processes your personal data for the following purposes:

• Account management: To create, maintain, and manage your 9abon account, including authentication, account security, and profile updates;
• KYC and age verification: To verify your identity and confirm that you meet the 21+ age requirement before processing withdrawals or granting access to age-restricted features;
• Transaction processing: To process deposits, withdrawals, and to maintain accurate financial records for your account;
• Game delivery: To provide, personalise, and improve the games and services available on the Platform;
• Customer support: To respond to your queries, complaints, and requests, and to resolve disputes;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeovers, money laundering, and other illegal activities;
• Regulatory compliance: To comply with our obligations under Philippine gaming regulations, anti-money laundering laws, tax laws, and any other applicable legislation;
• Responsible gaming: To monitor gaming behaviour for indicators of problem gambling and to administer responsible gaming tools including self-exclusion, deposit limits, and session timers;
• Marketing communications: To send you promotional offers, updates, and information about 9abon games and services, where you have consented to receive such communications;
• Analytics and improvement: To analyse Platform usage, improve features, and enhance user experience through aggregated and anonymised insights.

6.1 9abon processes your personal data on the following legal grounds as provided under the Data Privacy Act of 2012:

• Consent: For marketing communications and optional features, we rely on your freely given, specific, informed, and unambiguous consent, which you may withdraw at any time;
• Contractual necessity: Processing required to perform the contract between you and 9abon — including account creation, game delivery, payment processing, and support services;
• Legal obligation: Processing necessary to comply with our legal and regulatory obligations under Philippine law, including AML, KYC, and tax requirements;
• Legitimate interests: Processing necessary for 9abon's legitimate business interests, including fraud prevention, security monitoring, and Platform improvement, where these are not overridden by your fundamental rights and freedoms.

7.1 9abon does not sell, rent, or trade your personal data to third parties for marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, and other payment service providers solely for the purpose of processing your financial transactions;
• Identity verification services: Third-party KYC and age verification providers engaged to fulfil our regulatory obligations;
• Fraud prevention agencies: Services used to detect and prevent fraudulent activity, account takeovers, and money laundering;
• Game providers: Third-party game studios and live casino providers (such as JILI, PG Soft, Pragmatic Play, and Evolution Gaming) who may process certain technical data to deliver their games;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies, where required by applicable law or court order;
• Professional advisors: Lawyers, accountants, and auditors engaged in the provision of professional services to 9abon, subject to binding confidentiality obligations;
• IT and hosting providers: Technology service providers who host, maintain, and support the Platform infrastructure, under strict data processing agreements.

7.2 All third parties with whom 9abon shares personal data are required to implement appropriate technical and organisational security measures and to use your data only for the specified purpose for which it was shared.

8.1 Some of 9abon's service providers and game partners operate from jurisdictions outside the Philippines. Where personal data is transferred internationally, 9abon ensures that appropriate safeguards are in place in accordance with the Data Privacy Act of 2012 and NPC regulations.

8.2 Such safeguards include contractual clauses that impose data protection obligations on the recipient equivalent to those applicable in the Philippines, and verification that recipient jurisdictions provide an adequate level of data protection.

9.1 9abon retains personal data only for as long as necessary to fulfil the purposes described in this Policy, including any legal, accounting, or reporting requirements.

9.2 The following general retention periods apply:

• Account and identity data: Retained for the lifetime of your account and for a minimum of five (5) years after account closure, in compliance with AML record-keeping obligations;
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable tax and financial regulations;
• Gaming activity records: Retained for a minimum of three (3) years from the date of the activity;
• Marketing consent records: Retained until consent is withdrawn, plus a reasonable period thereafter as evidence of consent;
• Support communications: Retained for two (2) years from the date of the final interaction.

9.3 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data.

10.1 As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 9abon:

10.2 To exercise any of the above rights, please contact 9abon's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." 9abon will respond within the timeframe prescribed by the NPC, generally within thirty (30) calendar days.

10.3 We may need to verify your identity before processing a rights request to protect the confidentiality of your personal data. This is a security measure and does not affect your right to make a request.

11.1 9abon uses cookies and similar tracking technologies to operate the Platform effectively, enhance user experience, and gather analytics about Platform usage.

11.2 The following types of cookies are used on the 9abon Platform:

• Strictly necessary cookies: Essential for the Platform to function. These enable authentication, session management, and security features. They cannot be disabled without breaking Platform functionality;
• Performance and analytics cookies: Used to collect aggregated, anonymised information about how users interact with the Platform, enabling us to improve functionality and user experience;
• Functional cookies: Used to remember your preferences and settings, such as language selection and display preferences;
• Targeting and marketing cookies: Used to deliver relevant promotional content. These are only placed with your prior consent.

11.3 You may control cookie settings through your browser's privacy settings. Please note that disabling certain cookies may affect the functionality of the Platform.

12.1 With your consent, 9abon may send you promotional emails, SMS messages, or in-platform notifications about bonuses, new games, and special offers available on the Platform.

12.2 You may withdraw your consent to receive marketing communications at any time by:

• Clicking the "Unsubscribe" link in any marketing email from 9abon;
• Updating your communication preferences in your 9abon Account Settings;
• Contacting 9abon support at [email protected].

12.3 Withdrawing consent for marketing communications does not affect the lawfulness of processing carried out before withdrawal, nor does it affect 9abon's ability to send you transactional communications necessary for account management (e.g., deposit confirmations, withdrawal notifications, security alerts).

13.1 The 9abon Platform is strictly intended for individuals who are 21 years of age or older. 9abon does not knowingly collect personal data from persons under 21 years of age.

13.2 If 9abon becomes aware that it has inadvertently collected personal data from an individual under 21 years of age, it will immediately close the relevant account, forfeit any associated balance, and securely delete all personal data associated with that account.

13.3 Age verification is a mandatory step in the KYC process. If you become aware that a minor has accessed the Platform using false age information, please contact 9abon support immediately.

14.1 9abon implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 9abon Platform;
• Hashed password storage — your account password is never stored in a readable format;
• Two-factor authentication (2FA) available for all account holders;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing of Platform infrastructure;
• Automated monitoring for suspicious login attempts and unusual account activity.

14.2 While 9abon takes all reasonable precautions, no system is completely impenetrable. You are responsible for maintaining the confidentiality of your login credentials. 9abon will never ask you for your password via email or live chat.

15.1 In the event of a personal data breach that is reasonably believed to give rise to a real risk of serious harm to affected data subjects, 9abon will:

• Notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in compliance with NPC Circular 16-03;
• Notify affected data subjects without undue delay, providing clear information about the nature of the breach, the data affected, the likely consequences, and the measures being taken;
• Maintain a record of all personal data breaches, including those that do not meet the notification threshold, as required by law.

16.1 9abon reserves the right to update or revise this Privacy Policy at any time to reflect changes in applicable law, our data practices, or the services we offer. The revised Policy will be published at https://9abon.org/privacy-policy with the updated effective date clearly indicated.

16.2 Material changes to this Policy will be communicated to registered users via the email address on their 9abon account. Continued use of the Platform after the revised Policy becomes effective constitutes acceptance of the updated terms.

16.3 We encourage you to review this Policy periodically to remain informed about how 9abon protects your personal data.

17.1 For any questions, concerns, or requests relating to this Privacy Policy or 9abon's data practices, please contact:

• Data Protection Officer — 9abon
• Email: [email protected] (Subject: "Privacy Policy Enquiry")
• Live Chat: Available 24/7 via the Platform

17.2 If you believe that 9abon has not adequately addressed your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for administering and enforcing the Data Privacy Act of 2012.

17.3 9abon takes all privacy complaints seriously and will investigate and respond to all submissions within the timeframe required by applicable law.