Privacy Policy

1. Overview and Scope

This Privacy Policy ("Policy") is issued by 99pow ("we," "us," "our," or "the Platform") and applies to all personal data collected from individuals ("you," "Player," or "User") who access or use the 99pow website, mobile platform, games, and related services (collectively, the "Services") available at 99pow.app.

99pow is committed to protecting the privacy and security of your personal information 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. We are registered with and subject to the oversight of the National Privacy Commission (NPC) of the Philippines.

By registering for an account, accessing the platform, or otherwise using the Services, 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 Services immediately.

2. Personal Data We Collect

99pow collects only the personal data that is necessary to provide you with a safe, fair, and compliant gaming experience. The categories of personal data we collect include:

2.1 Identity and Contact Information

• Full legal name as it appears on a government-issued identification document
• Date of birth (to verify that you are 21 years of age or older)
• Email address
• Philippine mobile number
• Residential address (province, city, barangay)
• Nationality and country of residence

2.2 Identity Verification Documents

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or liveness verification images where required for KYC compliance

2.3 Financial Information

• Payment method details (e.g., GCash mobile number, PayMaya account, BPI, BDO, or Metrobank account details)
• Transaction history, including deposits, withdrawals, and wager records
• Account balance information

2.4 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, login timestamps, and activity logs
• Game play history and betting patterns
• Cookie identifiers and similar tracking data (see Section 9)

2.5 Communications Data

• Records of your communications with our customer support team
• Feedback, survey responses, and promotional opt-in preferences

3. How We Collect Your Data

99pow collects personal data through the following channels:

3.1 Directly from You

The majority of personal data we hold is provided directly by you during the account registration process, KYC verification, payment transactions, customer support interactions, and when you participate in promotions or surveys on the 99pow platform.

3.2 Automatically Through Technology

When you access the 99pow platform, certain technical data is collected automatically through cookies, web beacons, log files, and similar technologies. This includes your IP address, device identifiers, browser type, and browsing behavior on the platform. Please refer to Section 9 for full details on our use of cookies.

3.3 From Third Parties

In certain circumstances, 99pow may receive personal data about you from third parties, including:

• Payment service providers (e.g., GCash, PayMaya) for transaction verification purposes
• Identity verification and fraud prevention service providers
• Regulatory authorities and law enforcement agencies where legally required
• Publicly available sources for due diligence and AML screening purposes

4. Purposes of Processing

99pow processes your personal data for the following specific and legitimate purposes:

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 99pow processes your personal data on the following legal grounds:

• Consent: You have provided explicit consent for us to process your data for specific purposes, such as marketing communications.
• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions) and to provide the gaming services you have requested.
• Legal Obligation: Processing is required to comply with Philippine laws and regulations, including AML, KYC, tax reporting, and gaming license obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests do not override your fundamental rights and freedoms.

6. Sharing and Disclosure

99pow does not sell, rent, or trade your personal data to third parties for their own marketing purposes. However, we may share your data with the following categories of recipients where necessary:

6.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including payment processing (GCash, PayMaya, banks), identity verification, fraud detection, cloud hosting, customer support platforms, and marketing tools. These providers are contractually bound to process your data only as instructed by 99pow and to maintain appropriate security measures.

6.2 Regulatory and Law Enforcement Authorities

99pow may disclose your personal data to Philippine regulatory bodies (including PAGCOR and the National Privacy Commission), law enforcement agencies, tax authorities, and courts where required by law or in response to valid legal process.

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this Policy.

6.4 With Your Consent

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

7. Data Retention

99pow retains your personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal and regulatory requirements.

7.1 Active Accounts

While your 99pow account remains active, we retain your personal data to provide ongoing services, process transactions, and maintain account security.

7.2 Closed Accounts

After you close your account, 99pow will retain certain personal data for a period of seven (7) years from the date of account closure to comply with Philippine AML regulations, tax obligations, and to resolve any disputes or legal claims that may arise.

7.3 Marketing Data

If you have opted in to receive marketing communications, we will retain your contact details until you withdraw your consent or until the data is no longer relevant for marketing purposes.

7.4 Secure Deletion

Once the retention period expires, 99pow will securely delete or anonymize your personal data in accordance with industry best practices.

8. Data Security

99pow takes the security of your personal data extremely seriously. We implement a comprehensive range of technical and organizational measures to protect your information from unauthorized access, disclosure, alteration, or destruction.

8.1 Technical Safeguards

• Encryption: All data transmitted between your device and the 99pow platform is encrypted using industry-standard SSL/TLS protocols.
• Secure Storage: Personal data is stored on secure servers with restricted access controls and regular security audits.
• Firewalls and Intrusion Detection: Our infrastructure is protected by advanced firewalls and real-time intrusion detection systems.
• Two-Factor Authentication: We offer 2FA to add an extra layer of security to your account login.

8.2 Organizational Safeguards

• Access to personal data is restricted to authorized 99pow personnel on a need-to-know basis.
• All employees and contractors are bound by confidentiality obligations and receive regular data protection training.
• We conduct regular security assessments and penetration testing to identify and address vulnerabilities.

9. Cookies and Tracking Technologies

99pow uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and deliver personalized content.

9.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They allow the website to recognize your device and remember certain information about your preferences and activity.

9.2 Types of Cookies We Use

• Essential Cookies: Required for the platform to function properly, including authentication and security features. These cannot be disabled.
• Performance Cookies: Collect anonymous data about how you use the platform to help us improve performance and user experience.
• Functional Cookies: Remember your preferences (e.g., language settings) to provide a more personalized experience.
• Marketing Cookies: Track your activity across websites to deliver targeted advertising and measure campaign effectiveness (only with your consent).

9.3 Managing Cookies

You can control and delete cookies through your browser settings. However, disabling essential cookies may affect the functionality of the 99pow platform. For more information on managing cookies, please refer to your browser's help documentation.

10. Your Privacy Rights

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

10.1 Right to Access

You have the right to request a copy of the personal data we hold about you. We will provide this information in a commonly used electronic format within thirty (30) days of your request.

10.2 Right to Rectification

If any of your personal data is inaccurate or incomplete, you have the right to request that we correct or update it. You can update most information directly through your account settings.

10.3 Right to Erasure

You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw your consent. Please note that we may be required to retain certain data to comply with legal obligations.

10.4 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes at any time. You can opt out of marketing communications by clicking the unsubscribe link in any promotional email or by contacting our support team.

10.5 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 service provider where technically feasible.

10.6 Right to Lodge a Complaint

If you believe that 99pow has violated your privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Contact details are provided in Section 14.

11. Protection of Minors

99pow is committed to protecting minors from exposure to online gambling. The platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations.

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 information and close the associated account.

If you are a parent or guardian and believe that your child has provided personal data to 99pow, please contact us immediately at [email protected] so that we can take appropriate action.

12. Cross-Border Data Transfers

99pow primarily operates within the Philippines, and your personal data is stored on servers located within the country. However, in certain circumstances, we may transfer your data to service providers located outside the Philippines for purposes such as cloud hosting, payment processing, or technical support.

Where we transfer your data internationally, we ensure that appropriate safeguards are in place to protect your information in accordance with the Data Privacy Act of 2012 and its Implementing Rules and Regulations. These safeguards may include:

• Standard contractual clauses approved by the National Privacy Commission
• Transfers to countries recognized as providing adequate data protection
• Binding corporate rules for intra-group transfers

13. Changes to This Policy

99pow reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. When we make material changes to this Policy, we will notify you by:

• Posting a prominent notice on the 99pow platform
• Sending an email notification to the address associated with your account
• Updating the "Effective Date" at the top of this Policy

Your continued use of the 99pow platform following the posting of changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

14. Contact and Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or how 99pow handles your personal data, please contact us using the details below:

99pow Data Protection Officer

Email: [email protected]

General Support: [email protected]

Response Time: We aim to respond to all privacy inquiries within 48 hours.

National Privacy Commission (Philippines)

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission:

Website: privacy.gov.ph

Email: [email protected]

Address: 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City, Metro Manila, Philippines