nicph Privacy Policy

1. Who We Are — Data Controller

nicph ("nicph", "we", "us", "our") is the data controller responsible for the personal information collected through nicph.org and any associated mobile application or service. nicph operates as an online gaming platform serving Filipino players in accordance with a PAGCOR-compliant framework.

This Privacy Policy is issued pursuant to Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations. By registering an account or using any nicph service, 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.

Questions regarding this Privacy Policy or your personal data should be directed to our Data Protection Officer (DPO) at support at nicph.org.

2. Personal Data We Collect

nicph collects the following categories of personal data:

Category	Examples	When Collected
Identity Data	Full legal name, date of birth, nationality, government ID number	Registration & KYC
Contact Data	Philippine mobile number, email address	Registration
Financial Data	GCash number, PayMaya account, bank account details, transaction history	Deposit & withdrawal
KYC Documents	Government-issued ID image, selfie verification photo	Identity verification
Gaming Data	Game history, bets placed, winnings, session duration, wagering activity	Throughout gameplay
Technical Data	IP address, device type, browser, operating system, session timestamps	Each site visit
Communications Data	Customer support chat logs, emails, complaint records	Support interactions
Marketing Data	Promotion preferences, email opt-in status	Account settings

nicph does not knowingly collect sensitive personal information beyond what is strictly required for identity verification, age verification, and anti-money laundering compliance. We do not collect information about race, ethnicity, religion, political views, or health condition except where voluntarily disclosed in a responsible gaming context (e.g., self-exclusion requests).

3. How We Collect Your Data

nicph collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or updating your profile settings.
• Automated collection: Technical data collected automatically when you visit nicph.org, including IP address, device identifiers, browser type, and page interaction data collected via cookies and similar technologies.
• Payment processors: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, and card payment processors when you initiate a deposit or withdrawal.
• Identity verification services: Data returned from third-party KYC providers used to verify the authenticity of government-issued identification documents submitted by you.
• Gaming activity: Bet history, game outcomes, wagering activity, session timing data, and responsible gaming tool usage generated through your interaction with games on the Platform.

4. How We Use Your Personal Data

nicph processes your personal data for the following purposes:

• Account management: Creating and maintaining your nicph account, verifying your identity and age (21+), enabling secure login, and managing account preferences.
• Service delivery: Processing deposits and withdrawals, recording gaming activity, awarding bonuses, and providing access to games and platform features.
• Regulatory compliance: Meeting KYC, AML (Anti-Money Laundering), and CTF (Counter-Terrorism Financing) obligations applicable to PAGCOR-compliant gaming operators. This includes reporting obligations to relevant Philippine regulatory and law enforcement authorities.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior, administering deposit limits, loss limits, cooling-off periods, and self-exclusion requests.
• Customer support: Responding to inquiries, complaints, and dispute resolution requests.
• Security and fraud prevention: Detecting, investigating, and preventing fraudulent transactions, unauthorized access, and other prohibited conduct.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates — only where you have provided opt-in consent. You may withdraw marketing consent at any time through your account settings.
• Platform improvement: Analyzing aggregate usage data to improve game offerings, site performance, and user experience.

5. Legal Basis for Processing

nicph processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and nicph — including account registration, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AML/CTF legislation, and data retention requirements.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregate analytics, where these interests are not overridden by your privacy rights.
• Consent: Marketing communications and any non-essential data processing for which nicph has obtained your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

nicph does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and card scheme operators for the purpose of processing financial transactions.
• KYC and identity verification providers: Third-party services used to verify the authenticity and validity of government-issued IDs submitted during account verification.
• Game software providers: Licensed game studios and providers (e.g., JILI, Pragmatic Play, PG Soft) who receive the minimum data necessary to deliver game services and maintain game integrity records.
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government authorities where nicph is legally required to disclose data.
• Law enforcement: Philippine law enforcement agencies where nicph receives a valid legal order, subpoena, or compulsion requiring disclosure.
• IT and infrastructure providers: Cloud hosting, security, and platform infrastructure providers who process data on nicph's behalf under data processing agreements that require them to maintain confidentiality and comply with the DPA.

All third-party service providers engaged by nicph are required to implement appropriate technical and organizational measures to protect personal data consistent with the requirements of the Data Privacy Act of 2012.

7. Data Retention

nicph retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC data: Retained for a minimum of 5 years following account closure, in accordance with AML record-keeping requirements applicable to Philippine gaming operators.
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction.
• Gaming activity data: Retained for a minimum of 3 years from the date of the activity.
• Customer support communications: Retained for 2 years from the date of the communication, or longer if the matter is subject to an ongoing dispute or regulatory inquiry.
• Marketing consent records: Retained for the duration of your opt-in consent plus 1 year following withdrawal of consent, as evidence of compliance.

Upon expiry of the applicable retention period, nicph will securely delete or anonymize personal data unless a longer retention period is required by applicable law.

8. Cookies and Tracking Technologies

nicph.org uses cookies and similar tracking technologies to operate the Platform, maintain your session state, and analyze usage patterns. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function, including session authentication tokens and security cookies. These cannot be disabled without breaking core functionality.
• Functional cookies: Remember your language preferences, game settings, and login state to improve your experience across sessions.
• Analytics cookies: Collect aggregate, anonymized data about how players use nicph.org to help us improve site performance and game offerings. No individual player is identified in analytics reports.
• Marketing cookies: Used only where you have consented to receive targeted promotions. You may manage cookie preferences through your browser settings or the nicph cookie preference center.

9. Data Security

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

• TLS/SSL encryption for all data transmitted between your device and nicph.org.
• Encryption at rest for sensitive personal data, including KYC documents and financial information.
• Multi-factor authentication (SMS OTP) for all nicph account logins.
• Role-based access controls limiting nicph staff access to personal data on a strict need-to-know basis.
• Regular security audits and penetration testing of Platform infrastructure.
• A dedicated fraud and AML monitoring team reviewing unusual account activity in real time.

While nicph takes all reasonable steps to secure your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your account credentials and should notify nicph immediately at support at nicph.org if you suspect unauthorized access to your account.

10. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by nicph:

• Right to be informed: The right to know how your personal data is being collected and processed — fulfilled by this Privacy Policy.
• Right of access: The right to request a copy of the personal data nicph holds about you.
• Right to rectification: The right to correct inaccurate or incomplete personal data in your nicph account.
• Right to erasure: The right to request deletion of your personal data, subject to nicph's legal retention obligations.
• Right to data portability: The right to receive your personal data in a structured, machine-readable format.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe nicph has violated your data privacy rights.

To exercise any of the above rights, submit a written request to our Data Protection Officer at support at nicph.org with the subject line "Data Privacy Request". nicph will acknowledge your request within 3 business days and respond substantively within 15 business days, as required by the DPA Implementing Rules.

11. Children's Privacy — 21+ Platform

nicph is an online gaming platform restricted to individuals who are 21 years of age or older in accordance with PAGCOR regulations. nicph does not knowingly collect personal data from persons under 21 years of age. If nicph becomes aware that personal data has been collected from an individual under 21, the account will be immediately closed and all personal data deleted in accordance with applicable law. If you believe a minor has registered on nicph, please notify us immediately at support at nicph.org.

12. Cross-Border Data Transfers

nicph's primary data processing infrastructure is located in the Philippines. Where personal data is processed by third-party service providers whose infrastructure is located outside the Philippines (such as international cloud hosting providers or game software studios), nicph ensures that such transfers comply with the requirements of the Data Privacy Act of 2012, including through the use of appropriate contractual safeguards such as standard data processing agreements that require recipient parties to maintain data protection standards equivalent to those required under Philippine law.

13. Changes to This Privacy Policy

nicph may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform services. When material changes are made, nicph will notify registered players via email or an in-platform notification at least 7 days before the revised Policy takes effect, where practicable. The "Last updated" date at the top of this page will always reflect the date of the most recent revision. Continued use of nicph following the effective date of a revised Policy constitutes your acceptance of the changes.

14. Contact — Data Protection Officer

For all data privacy inquiries, access requests, correction requests, or complaints, contact nicph's Data Protection Officer at:

Email: support at nicph.org

Please include "Data Privacy" in the subject line of your message, along with your nicph account username and a clear description of your request. nicph's DPO is available Monday to Sunday, and will respond to all data privacy requests within the timelines required by the Data Privacy Act of 2012.