ninogames Privacy
Policy & Data Protection

1.1  ninogames is an online gaming platform dedicated to Filipino players. We take the privacy and security of our players' personal data seriously — not merely because Philippine law requires it, but because we understand that trust is the foundation of our relationship with the Filipino gaming community.

1.2  This Policy has been prepared in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations, as overseen by the National Privacy Commission ("NPC"). For matters related to payment processing and anti-money laundering, we also comply with relevant AMLC (Anti-Money Laundering Council) regulations and PAGCOR requirements.

1.3  The terms "personal data" and "personal information" in this Policy carry the meanings assigned to them by the DPA: any information from which your identity is apparent or can reasonably and directly be ascertained, or from which ninogames can identify you when combined with other information.

2.1  For the purposes of the DPA and this Policy, ninogames acts as the personal information controller in respect of personal data collected from players and visitors through the ninogames.one platform.

2.2  ninogames has designated a Data Privacy Officer ("DPO") responsible for overseeing the implementation of this Policy and for serving as the primary contact point for data privacy inquiries, complaints, and requests from data subjects. The DPO can be reached via the contact channel described in Section 15 of this Policy.

ninogames collects the following categories of personal data from players:

3.2  ninogames does not collect special categories of sensitive personal information (such as racial or ethnic origin, religious beliefs, health data, or political opinions) except where required by applicable law or regulation.

ninogames collects personal data through the following means:

• Account Registration: Information you provide directly when creating your ninogames account, including your name, mobile number, and date of birth.
• KYC Verification: Identity documents you submit in connection with account verification requirements.
• Deposits and Withdrawals: Payment information associated with transactions made through GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and InstaPay.
• Platform Interaction: Data generated automatically when you use ninogames, including gaming activity, session data, and navigation behavior.
• Technical Collection: Device identifiers, IP addresses, and browser information collected automatically through cookies, log files, and similar technologies (see Section 8).
• Support Interactions: Information you provide when contacting ninogames via live chat or email.
• Third-Party Verification: In certain circumstances, ninogames may verify identity information against third-party data sources as part of KYC and AML compliance procedures.

ninogames processes personal data for the following specific purposes:

• Account management: Creating, operating, and maintaining your ninogames player account.
• Identity and age verification: Verifying that you are who you say you are and that you meet the 21+ age requirement mandated by PAGCOR for online gaming in the Philippines.
• Financial transaction processing: Processing deposits and withdrawals in Philippine Peso via your chosen payment method.
• Anti-money laundering (AML) compliance: Monitoring transactions for patterns consistent with money laundering or financial crime, as required by Philippine AMLC regulations.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, account abuse, and security incidents on the ninogames platform.
• Responsible gaming: Monitoring gaming activity for indicators of problem gambling and enforcing player-set responsible gaming limits, as required by ninogames' operating framework.
• Customer support: Responding to your inquiries, complaints, and service requests.
• Regulatory reporting: Complying with reporting obligations to PAGCOR and other relevant Philippine regulatory authorities.
• Platform improvement: Analyzing aggregate platform usage data to improve game performance, loading speeds, and user experience.
• Marketing communications: Sending you promotional offers, bonus notifications, and updates about ninogames — only where you have given explicit consent or where permitted by applicable law.

Under the Data Privacy Act of 2012, ninogames relies on the following legal bases for processing personal data:

• Contractual necessity: Processing required to create and operate your ninogames account and to fulfill our obligations to you under the Terms and Conditions.
• Legal obligation: Processing required to comply with PAGCOR licensing requirements, AML obligations, age verification requirements, NPC regulations, and other applicable Philippine law.
• Legitimate interests: Processing for fraud prevention, security monitoring, and platform improvement, where such interests do not override your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications, where consent has been specifically obtained. You have the right to withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7.1  ninogames does not sell, rent, or otherwise commercially disclose your personal data to third parties for their own marketing purposes. We share personal data only in the following defined circumstances:

• Payment processors: We share the financial data necessary to process deposits and withdrawals with our payment service providers (GCash/GXchange, Maya Philippines, and Philippine banking partners). These providers process data only as instructed by ninogames and under data processing agreements.
• Game providers: Game studios whose titles appear in the ninogames lobby may receive technical identifiers (non-name player IDs, session tokens) necessary to serve their games. No personally identifiable information beyond what is technically necessary is shared with game studios.
• Regulatory and law enforcement authorities: ninogames is legally required to share certain data with PAGCOR, the AMLC, the NPC, and Philippine law enforcement agencies when demanded pursuant to their legal authority. We comply with such demands after reviewing their legal validity.
• KYC and fraud prevention services: We may use third-party identity verification and fraud screening services. These providers process data solely for the purpose of providing their service to ninogames under strict contractual obligations.
• Professional advisers: Lawyers, auditors, and other professional advisers bound by confidentiality obligations, where necessary in connection with legal claims or regulatory proceedings.

7.2  In the event of a merger, acquisition, or corporate restructuring involving ninogames, personal data may be transferred to the relevant successor entity, subject to the same privacy protections described in this Policy.

8.1  ninogames uses cookies and similar tracking technologies on the ninogames.one platform. Cookies are small text files placed on your device that help ninogames recognize returning users, maintain session state, and analyze platform usage. The following categories of cookies are used:

• Strictly necessary cookies: Required for the platform to function. These cannot be disabled. They include session authentication tokens and security cookies that verify your identity during an active login session.
• Functional cookies: Remember your preferences such as language settings, last-played games, and display options. These improve your experience but are not essential.
• Analytics cookies: Collect anonymized data about how players navigate and use ninogames (pages visited, time spent, errors encountered). This data is used in aggregate form only to improve the platform.
• Security cookies: Help detect and prevent fraudulent access attempts, account takeovers, and session hijacking.

8.2  You can manage non-essential cookie preferences through your browser settings. Disabling functional or analytics cookies will not prevent you from using ninogames but may affect certain personalization features.

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

• 256-bit SSL/TLS encryption for all data in transit between your device and ninogames servers.
• Encryption of sensitive personal data (including identity documents and financial information) at rest on ninogames systems.
• Two-factor authentication (2FA) available to all players via SMS, strongly recommended for all accounts.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular third-party security audits and penetration testing of the ninogames platform.
• Automated monitoring for suspicious login activity, including logins from unrecognized devices or unusual geographic locations.
• Incident response procedures for detecting, containing, and recovering from security incidents.

9.2  Notwithstanding the above measures, no online platform can guarantee absolute security against all possible threats. ninogames encourages all players to use strong, unique passwords, enable 2FA, and maintain the security of their registered mobile devices.

10.1  ninogames retains personal data only for as long as necessary to fulfill the purposes for which it was collected, as described in this Policy, or for as long as required by applicable Philippine law and regulation.

10.2  Specific retention periods applicable to ninogames player data:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR and AML regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AML and financial record-keeping requirements.
• Gaming activity data: Retained for the duration of your account and for three (3) years following account closure, for regulatory reporting and dispute resolution purposes.
• Support communications: Retained for three (3) years from the date of the interaction, for quality assurance and dispute resolution purposes.
• Technical and log data: Retained for twelve (12) months from collection, except where retained longer for security incident investigation purposes.

10.3  Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with ninogames' data disposal procedures.

Under the Data Privacy Act of 2012 of the Philippines, ninogames players have the following rights regarding their personal data. To exercise any of these rights, contact the ninogames Data Privacy Officer as described in Section 15.

11.2  ninogames will respond to verified data rights requests within thirty (30) calendar days of receipt. Where a request is complex or voluminous, ninogames may extend this period by a further thirty (30) days, with written notice to the requesting player. We may need to verify your identity before processing a rights request — this is to protect you against unauthorized requests.

12.1  ninogames is strictly an adult gaming platform. In compliance with PAGCOR regulations, ninogames does not permit registration by or accept accounts from any individual under the age of twenty-one (21) years. This is a legal requirement, not a platform policy choice.

12.2  ninogames does not knowingly collect personal data from individuals under the age of 21. If ninogames becomes aware that an account has been created by an individual under 21, that account will be immediately closed, any balance will be handled in accordance with applicable regulations, and all personal data associated with that account will be deleted except as required to be retained for regulatory purposes.

12.3  If you have reason to believe that an individual under 21 has registered on ninogames, please contact our support team immediately at the contact details set out in Section 15.

13.1  ninogames may send you promotional offers, bonus notifications, and platform updates via SMS to your registered Philippine mobile number and/or to your registered email address, where you have provided consent to receive such communications at registration or subsequently through your Account Settings.

13.2  You may opt out of marketing communications at any time by updating your communication preferences in the ninogames Account Settings, or by contacting our support team. Opting out of marketing communications will not affect operational and transactional messages (such as deposit confirmations, withdrawal notifications, security alerts, and support responses), which ninogames must send as part of its service obligations.

13.3  ninogames does not share your contact details with third-party marketers or advertisers. All marketing communications from ninogames originate from ninogames directly.

14.1  ninogames reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, new regulatory requirements, or improvements to our platform. Updated versions will be published on this page with a revised effective date.

14.2  For material changes that significantly affect how ninogames processes your personal data or your rights under this Policy, ninogames will use commercially reasonable efforts to notify registered players via in-platform notification or SMS to your registered mobile number prior to the changes taking effect.

14.3  Your continued use of ninogames following the publication of a revised Privacy Policy constitutes your acknowledgment of the updated Policy. If you do not agree with any material change, you may close your account by contacting our support team.

For all data privacy-related inquiries, rights requests, or complaints, please contact the ninogames Data Privacy Officer through any of the following channels:

• Live Chat: Available 24/7 directly on the ninogames platform. State that your inquiry is data-privacy related and request escalation to the DPO team. Average response time is under 5 minutes during Philippine peak hours.
• Email: [email protected] — please use the subject line "Data Privacy Request" and include your registered mobile number for identity verification. The DPO team aims to acknowledge requests within one (1) business day.

If you are not satisfied with ninogames' response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) in accordance with the procedures set out on the NPC's official website.