Privacy Policy

1. Who We Are

rich9 ("we," "us," "our," or the "Company") operates the online gaming platform accessible at rich9.app. We are the Personal Information Controller (PIC) as defined under the Data Privacy Act of 2012. We are responsible for the lawful, fair, and transparent processing of your personal data in connection with your use of our gaming services.

If you have any questions or concerns about how we handle your personal data, you may contact our Data Protection Officer (DPO) at [email protected]. We aim to respond to all privacy-related inquiries within five (5) business days.

2. Personal Data We Collect

rich9 collects personal data that is necessary to provide you with a safe, legal, and enjoyable gaming experience. We collect data in the following categories:

2.1 Data You Provide Directly

• Identity Data: Full legal name, date of birth, gender, and nationality.
• Contact Data: Email address, mobile phone number, and residential address (including city, province, and postal code).
• Account Data: Username, password (stored in encrypted form), and security questions.
• Verification Data: Government-issued ID (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's license, UMID), selfie photos, and proof of address documents submitted during Know Your Customer (KYC) verification.
• Financial Data: Bank account details (BPI, BDO, Metrobank, and other Philippine banks), GCash account number, PayMaya account number, and transaction history.
• Communications Data: Records of your communications with our customer support team, including live chat transcripts and email correspondence.

2.2 Data We Collect Automatically

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, session duration, click patterns, search queries within the Platform, and features used.
• Location Data: General geographic location derived from your IP address. We do not collect precise GPS location data.
• Cookie Data: Information collected through cookies and similar tracking technologies. See Section 9 (Cookies) for details.

2.3 Data We Receive from Third Parties

• Payment Processors: Transaction confirmation data from GCash, PayMaya, and banking partners to verify deposits and withdrawals.
• Identity Verification Services: Results from third-party KYC and anti-money laundering (AML) screening services.
• Fraud Prevention Services: Risk scores and fraud indicators from third-party fraud detection providers.

3. How We Use Your Personal Data

We process your personal data only for specific, legitimate purposes. The table below outlines the primary purposes for which we use your data and the legal basis for each:

4. Disclosure of Your Personal Data

rich9 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

4.1 Service Providers

We engage trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, banking partners), KYC and identity verification providers, fraud detection services, cloud hosting providers, and customer support software vendors. These providers are contractually bound to process your data only on our instructions and in compliance with applicable data protection laws.

4.2 Regulatory and Law Enforcement Authorities

We may disclose your personal data to government agencies, regulatory bodies, law enforcement authorities, or courts when required to do so by law, court order, or regulatory directive. This includes compliance with anti-money laundering (AML) reporting obligations and cooperation with investigations by the Philippine National Police (PNP), National Bureau of Investigation (NBI), or other competent authorities.

4.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and ensure that your data continues to be protected in accordance with this Privacy Policy.

4.4 With Your Consent

We may share your data with other third parties where you have given us your explicit consent to do so.

5. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Account Data: Retained for the duration of your account and for five (5) years after account closure, in compliance with AML regulations.
• Transaction Records: Retained for seven (7) years to comply with Philippine tax and financial record-keeping requirements.
• KYC and Verification Documents: Retained for five (5) years after account closure as required by AML regulations.
• Communications Data: Retained for three (3) years for customer support quality assurance and dispute resolution purposes.
• Marketing Data: Retained until you withdraw consent or request deletion, whichever comes first.

After the applicable retention period expires, we securely delete or anonymize your personal data so that it can no longer be associated with you.

6. Your Rights Under Philippine Law

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data. You may exercise these rights by contacting our Data Protection Officer at [email protected].

7. Data Security

rich9 employs industry-standard technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.3 or higher. Passwords are hashed using bcrypt with salt.
• Access Controls: Access to personal data is restricted to authorized personnel only, on a need-to-know basis. All employees and contractors sign confidentiality agreements.
• Secure Infrastructure: Our servers are hosted in secure data centers with 24/7 monitoring, firewalls, intrusion detection systems, and regular security audits.
• Regular Testing: We conduct regular penetration testing and vulnerability assessments to identify and remediate security weaknesses.
• Incident Response: We maintain an incident response plan to detect, contain, and respond to data breaches. In the event of a breach affecting your personal data, we will notify you and the National Privacy Commission (NPC) within seventy-two (72) hours as required by law.

While we take all reasonable precautions to protect your data, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

8. International Data Transfers

Your personal data is primarily stored and processed within the Philippines. In some cases, we may transfer data to service providers located outside the Philippines (e.g., cloud hosting providers with servers in Singapore or other jurisdictions). When we do so, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or other legally recognized transfer mechanisms, to ensure your data receives an adequate level of protection.

9. Cookies and Tracking Technologies

rich9 uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how you use the Platform.

9.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly. These enable core features like account login, session management, and security.
• Performance Cookies: Collect anonymous data about how you use the Platform, such as which pages you visit and how long you stay. This helps us improve performance and user experience.
• Functional Cookies: Remember your preferences (e.g., language, currency) so you don't have to re-enter them each time you visit.
• Marketing Cookies: Track your activity across websites to deliver personalized ads and measure the effectiveness of our marketing campaigns. These are only set with your consent.

9.2 Managing Cookies

You can control and delete cookies through your browser settings. Most browsers allow you to block or delete cookies, though doing so may affect the functionality of the Platform. To learn more about managing cookies, visit your browser's help section.

10. Third-Party Links

The rich9 Platform may contain links to third-party websites, such as payment processors or social media platforms. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

11. Children's Privacy

rich9 is strictly for users aged 21 years and older. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected data from a minor, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on our Platform, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify you by posting the updated policy on this page and updating the effective date at the top. In some cases, we may also notify you by email or through an in-platform notification. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or how we handle your personal data, please contact our Data Protection Officer:

Data Protection Officer
rich9
Email: [email protected]

We will respond to all privacy-related inquiries within five (5) business days. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.