Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how m9apiso ("m9apiso," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "Player," or "User") who access or use the m9apiso online gaming platform at m9apiso.net and all associated services (collectively, the "Platform").

m9apiso is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. We operate in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

By registering an account, accessing the Platform, or otherwise providing your personal information to m9apiso, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, m9apiso acts as the personal information controller ("PIC") in respect of the personal data it collects from players and users of the Platform.

As the personal information controller, m9apiso determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently in accordance with applicable Philippine law.

m9apiso has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 14 of this Policy.

3. Personal Data We Collect

m9apiso collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include:

3.1 Identity & Contact Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth
• Gender
• Philippine mobile number
• Email address
• Residential address (city, province, region)
• Nationality

3.2 Verification & KYC Data

• Government-issued photo ID (Passport, Driver's License, UMID, SSS ID, PhilHealth ID, Voter's ID, or Postal ID)
• Proof of address documents
• Selfie photographs submitted for identity verification
• Source of funds declarations where required by PAGCOR regulations

3.3 Financial & Transaction Data

• GCash or Maya account details (mobile number associated with the account)
• Bank account details (bank name, account number) for bank transfer transactions
• Debit card details (card number masked, expiry date, cardholder name)
• Deposit and withdrawal history
• Transaction amounts and timestamps

3.4 Gaming Activity Data

• Game history, bet amounts, and outcomes
• Session duration and frequency of play
• Bonus and promotion usage
• Responsible gaming tool settings (deposit limits, self-exclusion status)

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Unique device identifiers
• Login timestamps and session logs
• Platform interaction logs and error reports

3.6 Communications Data

• Records of communications with m9apiso customer support (live chat transcripts, email correspondence)
• Feedback and survey responses
• Complaint records

4. How We Collect Your Data

m9apiso collects personal data through the following means:

• Direct submission: 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, web beacons, and server logs. See Section 10 for details on our cookie practices.
• Third-party sources: Identity verification data from KYC service providers; payment confirmation data from GCash, Maya, and banking partners; fraud detection signals from security service providers. All third-party data sources are contractually bound to comply with applicable Philippine data protection law.
• Regulatory sources: Information shared with m9apiso by PAGCOR or other regulatory bodies in the exercise of their regulatory functions.

5. How We Use Your Personal Data

m9apiso uses your personal data for the following purposes:

m9apiso will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, m9apiso processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — including account management, game provision, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for m9apiso's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

m9apiso does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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, Maya, and banking partners receive the minimum data necessary to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party verification services that assist m9apiso in confirming player identities in compliance with PAGCOR requirements.
• Fraud prevention and security providers: Service providers that help m9apiso detect and prevent fraudulent activity, cheating, and unauthorized access.
• IT and platform infrastructure providers: Cloud hosting, database, and technical service providers that support the operation of the m9apiso Platform, all bound by data processing agreements.
• Customer support tools: Live chat and ticketing platform providers used to deliver customer support services.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies where disclosure is required by law or regulation.
• Law enforcement: Philippine law enforcement agencies where m9apiso is legally compelled to disclose data, or where disclosure is necessary to prevent or investigate a crime.

8. Data Retention

m9apiso retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction, as required by the AMLC and PAGCOR.
• Gaming activity logs: Retained for a minimum of two (2) years from the date of each gaming session.
• Customer support records: Retained for two (2) years from the date of the last interaction, or longer if the matter relates to an unresolved dispute or legal proceeding.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter for compliance documentation purposes.

Upon expiry of the applicable retention period, m9apiso will securely delete or anonymize your personal data in accordance with our data disposal procedures. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

9. Data Security

m9apiso implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the m9apiso Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including financial information and KYC documents, is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorized m9apiso personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Two-factor authentication: m9apiso supports and encourages the use of two-factor authentication (2FA) for player accounts to prevent unauthorized access.
• Regular security audits: The Platform undergoes regular penetration testing and security audits by independent third-party security firms.
• Incident response: m9apiso maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, m9apiso will notify the National Privacy Commission and affected players within the timeframes prescribed by the Data Privacy Act.

10. Cookies & Tracking Technologies

m9apiso uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyze usage patterns. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that prevent cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations. Disabling these may affect your experience.
• Analytics cookies: Help m9apiso understand how players use the Platform by collecting aggregated, anonymized usage data. This data is used solely to improve the Platform and is not shared with third-party advertisers.
• Security and fraud-detection cookies: Used to identify suspicious activity and protect the integrity of the Platform.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the m9apiso Platform. m9apiso does not use third-party advertising cookies or behavioral tracking cookies for cross-site advertising purposes.

11. Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by m9apiso. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

m9apiso will respond to all data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further sixty (60) days, in which case we will notify you of the extension and the reasons for it. There is no fee for exercising your data rights, unless requests are manifestly unfounded or excessive.

If you are not satisfied with m9apiso's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

12. Minors & Age Restriction

The m9apiso Platform is strictly intended for individuals who are at least 21 years of age, in accordance with PAGCOR regulations governing casino-style online gambling in the Philippines. m9apiso does not knowingly collect personal data from individuals under 21 years of age.

If m9apiso discovers or has reasonable grounds to believe that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data to the extent permitted by law, and report the matter to PAGCOR as required.

If you are a parent or guardian and believe that your child under 21 has provided personal data to m9apiso, please contact our Data Protection Officer immediately using the contact details in Section 14.

13. Changes to This Privacy Policy

m9apiso reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, m9apiso will notify registered players by email or through a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how m9apiso protects your personal data. Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the changes.

14. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by m9apiso, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe m9apiso has not handled your personal data in accordance with the Data Privacy Act of 2012.