Rich 9 Privacy Policy

01 About This Policy

This Privacy Policy ("Policy") describes how Rich 9 ("we," "us," or "our") collects, uses, stores, and protects the personal data of users ("you" or "your") who access or use the Rich 9 online gaming platform at rich-9.com (the "Platform").

Rich 9 is committed to protecting your privacy and handling your personal data in a transparent, lawful, and responsible manner. This Policy is written in compliance with applicable Philippine data privacy laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

By registering an account or using the Rich 9 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the Platform.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy.

02 Data We Collect

Rich 9 collects the following categories of personal data:

We do not collect sensitive personal information (as defined under RA 10173) unless strictly required for identity verification or regulatory compliance, and only with your explicit consent.

03 How We Collect Data

Rich 9 collects your personal data through the following means:

• Direct interactions: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions.
• Automated technologies: When you use the Platform, we automatically collect technical and usage data through cookies, web beacons, log files, and similar tracking technologies. See Section 7 for details.
• Third-party sources: We may receive data from payment processors (such as GCash and PayMaya), identity verification providers, fraud prevention services, and analytics partners, where permitted by law.
• Publicly available sources: In limited circumstances, we may collect data from publicly available sources for fraud prevention or regulatory compliance purposes.

04 How We Use Your Data

Rich 9 uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your Rich 9 account, including identity verification and age verification (21+ requirement).
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver customer support.
• Regulatory compliance: To comply with Philippine online gaming regulations, anti-money laundering (AML) obligations, and counter-terrorism financing (CTF) requirements. This includes reporting obligations to relevant Philippine authorities.
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other security threats.
• Responsible gaming: To monitor gaming behaviour and identify patterns that may indicate problem gambling, and to enforce self-exclusion requests.
• Communications: To send you transactional notifications (e.g., deposit confirmations, withdrawal updates, OTPs) and, where you have opted in, promotional communications about Rich 9 offers.
• Platform improvement: To analyse usage patterns and improve the performance, features, and user experience of the Rich 9 Platform.
• Legal proceedings: To establish, exercise, or defend legal claims where necessary.

Rich 9 will not use your personal data for any purpose incompatible with those listed above without first obtaining your consent or as otherwise permitted by applicable law.

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, Rich 9 processes your personal data on the following legal bases:

• Consent: Where you have given clear, informed consent to the processing of your data for a specific purpose (e.g., receiving promotional communications).
• Contractual necessity: Where processing is necessary to perform our contract with you — i.e., to operate your Rich 9 account and deliver the services you have requested.
• Legal obligation: Where processing is required to comply with a legal or regulatory obligation applicable to Rich 9, including AML/CTF reporting requirements.
• Legitimate interests: Where processing is necessary for our legitimate business interests (such as fraud prevention, security, and platform improvement), provided those interests are not overridden by your rights and interests.

06 Sharing Your Data

Rich 9 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:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions.
• Identity verification providers: Third-party KYC service providers who assist in verifying your identity and age in compliance with regulatory requirements.
• Regulatory and law enforcement authorities: Philippine government agencies, including PAGCOR, the Anti-Money Laundering Council (AMLC), and law enforcement bodies, where required by law or regulation.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection providers who process data on our behalf under strict data processing agreements.
• Professional advisers: Lawyers, auditors, and other professional advisers where necessary for legal or compliance purposes.

All third parties with whom Rich 9 shares personal data are required to maintain appropriate security standards and to process your data only for the specified purpose.

Where data is transferred outside the Philippines, Rich 9 ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012 and NPC guidelines.

07 Cookies & Tracking

Rich 9 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. You cannot opt out of these without ceasing to use the Platform.
• Functional cookies: Remember your preferences such as language settings and display options to personalise your experience.
• Analytics cookies: Collect anonymised data about how users interact with the Platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity checks.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. Rich 9 does not use cookies to serve third-party advertising.

08 Data Retention

Rich 9 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements under Philippine law.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship.
• Support communications: Retained for up to two (2) years from the date of the interaction, unless required longer for dispute resolution.
• Technical and usage data: Typically retained for up to twelve (12) months, after which it is anonymised or deleted.

When personal data is no longer required, Rich 9 will securely delete or anonymise it in accordance with our internal data disposal procedures.

09 Data Security

Rich 9 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Rich 9 Platform.
• Encryption at rest for sensitive data stored on our servers, including financial information and identity documents.
• Multi-factor authentication (MFA) options for account access, including OTP verification via your registered Philippine mobile number.
• Access controls: Personal data is accessible only to authorised Rich 9 personnel who require it to perform their job functions, under strict role-based access policies.
• Regular security audits and penetration testing conducted by independent cybersecurity professionals.
• Incident response procedures: In the event of a data breach that poses a risk to your rights and freedoms, Rich 9 will notify the National Privacy Commission and affected users within the timeframes required by the Data Privacy Act of 2012.

10 Your Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by Rich 9:

• Right to be informed: You have the right to know what personal data Rich 9 collects about you and how it is used — which is the purpose of this Policy.
• Right of access: You may request a copy of the personal data Rich 9 holds about you at any time.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data. You can update most account information directly through your account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: You may 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 applicable legal grounds.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Right to lodge a complaint: You have 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 our Data Protection Officer using the contact details in Section 13. Rich 9 will respond to all verified requests within fifteen (15) business days in accordance with NPC guidelines.

11 Children's Privacy

The Rich 9 Platform is strictly intended for adults aged 21 years and above. Rich 9 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on the Rich 9 Platform, please contact us immediately using the details in Section 13 so we can investigate and take appropriate action.

12 Changes to This Policy

Rich 9 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered users via email or an in-platform notification, and update the "Last Updated" date at the top of this page.

We encourage you to review this Policy periodically. Your continued use of the Rich 9 Platform following the publication of any changes constitutes your acceptance of the updated Policy. If you do not agree with the revised Policy, you must cease using the Platform and may request account closure as described in our Terms & Conditions.

13 Contact Us

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

• Live Chat: Available 24/7 directly on the Rich 9 Platform — fastest response for urgent concerns.
• Email (plain text): [email protected]
• Subject line for data requests: "Data Privacy Request – [Your Registered Email]"
• Response time: Within 15 business days for formal data privacy requests; within 4 hours for general support queries.

For complaints that remain unresolved after contacting Rich 9, you may escalate your concern to the National Privacy Commission (NPC) of the Philippines, which is the regulatory body responsible for enforcing the Data Privacy Act of 2012.