games99 Privacy Policy

1 Introduction

games99 ("we," "us," "our") operates the online gaming platform at games99.club and is committed to protecting the privacy and personal data of all users ("you," "your," "Player"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information when you access or use the games99 platform.

games99 recognizes the importance of data privacy as a fundamental right of every Filipino. We are committed to full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission (NPC). This policy is designed to give you clear, honest, and complete information about how your data is handled.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, games99 is the Personal Information Controller (PIC) in respect of the personal data you provide when using games99.club. games99 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine privacy law.

games99 has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection strategy and implementation. Contact details for the DPO are provided in Section 14 of this policy.

3 Personal Data We Collect

games99 collects the following categories of personal data from Players:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, nationality, government-issued ID number	Account registration, KYC verification, age verification (21+)
Contact Data	Email address, mobile number, residential address	Account communication, support, regulatory notices
Financial Data	GCash number, Maya account, bank account details, transaction history	Deposit and withdrawal processing, AML compliance
Technical Data	IP address, device type, browser type, operating system, session logs	Security monitoring, fraud prevention, platform optimization
Usage Data	Games played, wager amounts, session duration, feature interactions	Responsible gaming monitoring, personalization, analytics
Communications Data	Live chat transcripts, support ticket content, email correspondence	Customer support, dispute resolution, quality assurance
KYC Documents	Passport, driver's license, SSS/UMID card, proof of address, selfie photos	Identity verification, regulatory compliance, fraud prevention

games99 does not collect sensitive personal information (as defined under RA 10173) unless strictly required for regulatory compliance, in which case such collection will be clearly disclosed and subject to heightened protection measures.

4 How We Collect Your Data

games99 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access games99.club, including through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment data from GCash, Maya, and banking partners (limited to what is necessary for transaction processing).
• Publicly available sources: In limited circumstances, games99 may verify information against publicly available government databases or records for compliance purposes.

5 Purposes of Processing

games99 processes your personal data for the following specific, legitimate purposes:

• Account management: Creating, maintaining, and administering your games99 account, including authentication and access control.
• Identity and age verification: Confirming that you meet the 21+ age requirement and verifying your identity in compliance with PAGCOR regulations and KYC obligations.
• Payment processing: Processing deposits and withdrawals via GCash, Maya, bank transfer, and debit card; reconciling transactions; and maintaining financial records.
• Regulatory compliance: Fulfilling obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws and regulations.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, money laundering, and other illegal conduct.
• Responsible gaming: Monitoring gaming behavior to identify signs of problem gambling; administering deposit limits, cooling-off periods, and self-exclusion requests; and complying with PAGCOR's responsible gaming requirements.
• Customer support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Platform improvement: Analyzing usage patterns and technical performance data to improve the games99 platform, fix bugs, and develop new features.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates — but only where you have provided explicit consent to receive such communications. You may withdraw consent at any time.
• Legal proceedings: Establishing, exercising, or defending legal claims in connection with your use of the games99 platform.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, games99 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and games99 (i.e., providing the gaming platform and associated services).
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing conditions, AMLA obligations, and NPC requirements.
• Legitimate interests: Processing necessary for games99's legitimate interests in fraud prevention, platform security, and business analytics, provided such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

games99 does not sell your personal data. We share your data only in the following limited circumstances, and only to the extent strictly necessary:

• KYC and identity verification providers: Third-party services that assist games99 in verifying your identity and age in compliance with PAGCOR and AMLA requirements.
• Payment processors: GCash, Maya, and banking partners who process your deposit and withdrawal transactions. These providers receive only the data necessary to complete the transaction.
• IT and cloud service providers: Hosting, database, and security service providers who process data on games99's behalf under strict data processing agreements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or regulatory mandate.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other lawful process.
• Professional advisers: Lawyers, auditors, and accountants who provide professional services to games99, subject to confidentiality obligations.

All third parties with whom games99 shares personal data are required to implement appropriate technical and organizational security measures and to process your data only for the specified purposes and in accordance with games99's instructions.

8 Data Security

games99 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and games99.club.
• Encryption at rest for sensitive stored data, including passwords (hashed using bcrypt), payment details, and KYC documents.
• Multi-factor authentication (MFA) options for Player accounts to prevent unauthorized access.
• Role-based access controls ensuring that games99 staff can only access personal data on a strict need-to-know basis.
• Regular security audits and penetration testing conducted by independent cybersecurity professionals.
• Intrusion detection systems and 24/7 security monitoring to detect and respond to threats in real time.
• Data breach response procedures in compliance with NPC notification requirements under RA 10173.

While games99 takes all reasonable steps to protect your data, no internet transmission or electronic storage system is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying games99 immediately if you suspect unauthorized access to your account.

9 Data Retention

games99 retains your personal data for the following periods, after which data is securely deleted or irreversibly anonymized:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR licensing conditions and AMLA record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by AMLA and PAGCOR regulations.
• KYC documents: Retained for a minimum of five (5) years after the end of the business relationship, in accordance with AMLA obligations.
• Customer support communications: Retained for two (2) years from the date of the last interaction, for dispute resolution and quality assurance purposes.
• Technical and usage logs: Retained for twelve (12) months for security monitoring and platform analytics purposes.
• Marketing consent records: Retained for the duration of your consent and for one (1) year after withdrawal of consent, as evidence of lawful processing.

10 Cookies & Tracking Technologies

games99 uses cookies and similar technologies (such as web beacons and local storage) on games99.club. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the platform, including session management, authentication, and security. These cannot be disabled without affecting platform functionality.
• Performance and analytics cookies: Used to collect anonymized data about how Players use games99.club, helping us identify and fix technical issues and improve the platform experience.
• Functional cookies: Used to remember your preferences (such as language settings and responsible gaming limits) to provide a more personalized experience.

games99 does not use third-party advertising or cross-site tracking cookies. You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling certain cookies may affect the functionality of the games99 platform.

11 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by games99:

• Right to be informed: The right to be told what personal data games99 collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data games99 holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data games99 holds about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to games99's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller, where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe games99 has violated your data privacy rights.

To exercise any of these rights, please contact the games99 Data Protection Officer using the contact details in Section 14. games99 will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

12 Children's Privacy

The games99 platform is strictly intended for individuals who are 21 years of age or older, in compliance with PAGCOR regulations governing online gaming in the Philippines. games99 does not knowingly collect personal data from individuals under the age of 21.

If games99 discovers that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, all associated data will be deleted, and any funds held in the account will be handled in accordance with applicable PAGCOR guidelines. If you believe a minor has registered on the games99 platform, please contact us immediately using the details in Section 14.

13 Changes to This Privacy Policy

games99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, games99 will notify registered Players via email or an in-platform notification at least seven (7) days before the changes take effect, where reasonably practicable.

The "Last Updated" date at the top of this policy will always reflect the date of the most recent revision. Your continued use of the games99 platform after the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes. We encourage you to review this policy periodically.

14 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by games99, please contact our Data Protection Officer:

• Data Protection Officer: games99 DPO
• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 on games99.club
• Response Time: Within 15 business days for formal data subject requests

If you are not satisfied with games99's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.