7spin8 PRIVACY POLICY

1. Introduction

7spin8 is the Philippines' premier online gaming destination, offering live casino, JILI slots, sports betting, sabong, and bingo to Filipino players across the archipelago. As part of operating our platform, we necessarily process certain personal data about you — both to deliver the services you request and to comply with our legal and regulatory obligations under Philippine law.

We take data privacy seriously. The 7spin8 platform is built with privacy considerations embedded throughout its design and operations. We do not sell your personal data to third parties for their own marketing purposes. We do not collect more data than we need. And we implement robust technical and organizational safeguards to protect the personal information entrusted to us by our players from Manila to Mindanao.

This Policy applies to all personal data processed by 7spin8 in connection with your use of the Platform, including data collected through our website, mobile browser interface, customer support channels, and promotional activities. By registering a 7spin8 account or continuing to use the Platform after this Policy has been made available to you, you acknowledge that you have read and understood how your personal data is processed as described herein.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, 7spin8 acts as the personal information controller in respect of the personal data of players using the Platform. As data controller, 7spin8 determines the purposes and means by which personal data is processed and bears primary accountability for its lawful and secure handling.

Our designated Data Protection Officer (DPO) oversees compliance with this Policy and applicable data protection laws. If you have questions, concerns, or wish to exercise your data subject rights as described in Section 11 of this Policy, you may direct your inquiry to the 7spin8 Data Protection Officer via the contact channel specified in Section 15.

3. Personal Data We Collect

7spin8 collects personal data from you through several channels and at various points during your engagement with the Platform. The categories of personal data we collect are described below.

3.1 Registration Data

When you create a 7spin8 account, we collect: your full legal name, date of birth, gender, Philippine residential address, mobile phone number (Philippine prefix), and email address. This information is mandatory — without it, we cannot create your account or verify your identity as required under PAGCOR regulations.

3.2 Identity Verification (KYC) Data

To comply with our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, we collect copies of government-issued Philippine identification documents (e.g., PhilSys National ID, Passport, Driver's License, SSS/GSIS ID, Voter's ID, PRC ID), proof of address documents, and payment method ownership verification documents. This data includes the personal data visible on these documents, including ID numbers, photographs, and address details.

3.3 Financial & Transaction Data

We collect records of all financial transactions on the Platform, including deposit amounts and timestamps, withdrawal requests and processing status, GCash/PayMaya account reference numbers (not full account credentials), bank transfer references, gaming transaction histories, and bonus claim and wagering records. We do not store full bank account credentials or complete payment card numbers.

3.4 Gaming Activity Data

We collect data about your activity on the Platform, including: game sessions played, wager amounts and outcomes, session duration and frequency, game preferences, and betting patterns. This data is used for responsible gaming monitoring, fraud detection, personalization, and regulatory reporting.

3.5 Technical & Device Data

When you access the Platform, our systems automatically collect: IP address, device type and model, operating system and version, browser type and version, screen resolution, time zone, session timestamps, and pages visited within the Platform. This technical data is collected through our servers and analytics systems.

3.6 Communications Data

We retain records of communications between you and the 7spin8 customer support team, including live chat transcripts, email correspondence, and any documentation submitted in connection with disputes, complaints, or account inquiries.

4. How We Use Your Personal Data

7spin8 uses the personal data we collect for the following specific purposes:

• Account creation and management: Setting up and maintaining your 7spin8 player account, verifying your identity, and enabling you to access Platform features;
• Service delivery: Processing your deposits and withdrawals, facilitating game sessions, and delivering the gaming services you request;
• KYC and AML compliance: Verifying your identity, age (21+ as required by PAGCOR), and the legitimacy of your transactions as required under Philippine anti-money laundering regulations;
• Fraud prevention and platform security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, bonus abuse, and other violations of our Terms & Conditions;
• Responsible gaming monitoring: Tracking gaming patterns to identify players who may be experiencing gambling-related difficulties and providing appropriate interventions or information;
• Customer support: Responding to your inquiries, resolving disputes, and providing assistance through our 24/7 support channels;
• Regulatory reporting: Fulfilling our mandatory reporting obligations to PAGCOR and other competent Philippine regulatory and law enforcement authorities;
• Platform improvement: Analyzing aggregated, anonymized usage data to improve the performance, features, and user experience of the 7spin8 Platform;
• Marketing communications: Sending you promotional offers, bonus notifications, and Platform updates where you have opted in to receive such communications (you may opt out at any time).

7spin8 will not use your personal data for any purpose that is incompatible with the purposes listed above without providing you prior notice and, where required, obtaining your consent.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 7spin8 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you (i.e., to operate your player account and deliver gaming services);
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, PAGCOR requirements, tax obligations, and lawful orders from competent authorities;
• Legitimate interests: Processing necessary for 7spin8's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

7spin8 does not sell your personal data to third parties. We may share your personal data only in the following circumstances and with the following categories of recipients:

6.1 Service Providers

We engage trusted third-party service providers who process personal data on our behalf under data processing agreements that require them to handle your data securely and exclusively for the purposes we specify. These include: KYC/identity verification providers, payment processors (GCash, PayMaya, and banking partners), game software providers, cloud hosting and infrastructure providers, customer support platform providers, and fraud detection technology providers.

6.2 Regulatory and Law Enforcement Authorities

We are legally required to share certain data with PAGCOR and, where applicable, with the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and law enforcement agencies acting under lawful authority. Such disclosures are made strictly in accordance with applicable Philippine law and only to the extent legally required.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of the 7spin8 business, your personal data may be transferred to the successor entity as part of that transaction, subject to the successor's assumption of privacy obligations no less protective than those described in this Policy.

6.4 With Your Consent

We may share your personal data with additional third parties where you have given your explicit consent to such sharing. You may withdraw such consent at any time by contacting our Data Protection Officer.

7. Cookies & Tracking Technologies

The 7spin8 Platform uses cookies and similar tracking technologies (including local storage and session storage) to operate and improve the Platform. The categories of cookies we use are:

• Strictly necessary cookies: Essential for core Platform functionality, including maintaining your login session and security tokens. These cannot be disabled without breaking core Platform features;
• Functional cookies: Remember your preferences such as language settings, game history, and responsible gaming tool configurations;
• Analytics cookies: Collect aggregated, anonymized data about how players use the Platform — which games are most popular, how players navigate the interface, and where technical issues occur — to help us improve the Platform;
• Security cookies: Support our fraud detection and account security systems by helping us identify unusual access patterns that may indicate unauthorized activity.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use the Platform. 7spin8 does not use third-party advertising or retargeting cookies.

8. Data Retention

7spin8 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. Our standard retention periods are:

• Account data and KYC records: Retained for a minimum of five (5) years from account closure, as required under Philippine AML regulations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with BIR and AMLC requirements;
• Gaming activity logs: Retained for three (3) years for operational and responsible gaming purposes;
• Customer support communications: Retained for two (2) years from the date of the last communication;
• Technical and device data: Retained for twelve (12) months for security and fraud detection purposes;
• Marketing preference records: Retained for the duration of your account and for two (2) years following account closure.

When personal data is no longer required and no legal obligation mandates its retention, 7spin8 will securely delete or anonymize it. Anonymized data derived from your information may be retained for longer periods for analytical purposes, as anonymized data no longer constitutes personal data under the DPA.

9. Data Security Measures

7spin8 implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, accidental loss, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and the 7spin8 Platform is encrypted using Transport Layer Security (TLS). Sensitive data at rest, including KYC documents and financial records, is encrypted using AES-256 encryption;
• Access controls: Personal data is accessible only to 7spin8 personnel and service providers with a verified need-to-know, enforced through role-based access controls, multi-factor authentication, and comprehensive access logging;
• Infrastructure security: The Platform is hosted on secure cloud infrastructure subject to regular independent security assessments, penetration testing, and vulnerability management programs;
• Data breach procedures: 7spin8 maintains a data breach response plan. In the event of a personal data breach that poses a risk to affected individuals, we will notify the National Privacy Commission within 72 hours and notify affected players without undue delay, in accordance with the DPA;
• Staff training: All 7spin8 employees with access to personal data receive regular data protection training and are bound by confidentiality obligations.

While we implement robust security measures, no digital system is completely immune to risk. You play an important role in keeping your account secure by maintaining a strong, unique password and enabling two-factor authentication on your 7spin8 account.

10. Cross-Border Data Transfers

Some of the third-party service providers engaged by 7spin8 may be located or operate infrastructure outside the Philippines. Where personal data is transferred to recipients in jurisdictions outside the Philippines, 7spin8 ensures that such transfers are conducted in compliance with the Data Privacy Act of 2012 and its Implementing Rules and Regulations, including by entering into appropriate data transfer agreements with recipient entities that impose data protection obligations consistent with Philippine standards.

7spin8 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate contractual safeguards. If you have questions about the specific countries to which your data may be transferred, please contact our Data Protection Officer.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 7spin8:

• Right to be informed: The right to be notified that your personal data is being collected and processed — fulfilled through this Privacy Policy;
• Right of access: The right to obtain confirmation of whether 7spin8 holds personal data about you, and to receive a copy of that data;
• Right to rectification: The right to have inaccurate or incomplete personal data corrected without undue delay;
• Right to erasure (right to be forgotten): 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 overriding legal retention obligations;
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format for transfer to another service provider, where technically feasible;
• Right to object: The right to object to processing based on legitimate interests or for direct marketing purposes;
• Right to restrict processing: The right to request that 7spin8 restricts the processing of your personal data in certain circumstances;
• Right to withdraw consent: The right to withdraw previously given consent at any time, without affecting the lawfulness of processing conducted prior to withdrawal.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details in Section 15 of this Policy. We will respond to verified requests within the timeframes required under the DPA. We may need to verify your identity before processing your request to protect against unauthorized access.

12. Minors & Age Policy

The 7spin8 Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR age restriction requirements applicable to online gaming in the Philippines. We do not knowingly collect personal data from persons under 21 years of age.

During registration, all players are required to declare that they are at least 21 years old. This declaration is subject to mandatory KYC identity verification using valid Philippine government-issued identification. Any account found to have been registered by a person under 21 years of age will be immediately suspended, all associated personal data will be securely deleted, and any funds in the account will be handled in accordance with applicable regulatory guidance.

If you are a parent or guardian and believe that a minor has registered on the 7spin8 Platform without your knowledge or consent, please contact our Data Protection Officer immediately so we can take appropriate action.

13. Third-Party Services

The 7spin8 Platform integrates third-party services, including game software providers (such as JILI and Evolution Gaming), payment gateway processors, and customer support tools. These third parties operate under their own privacy policies and data processing terms, which govern how they handle the data that flows through their systems in connection with your use of 7spin8.

7spin8 selects service providers that demonstrate appropriate data protection practices and binds them to contractual data processing obligations consistent with the Data Privacy Act of 2012. However, 7spin8 is not responsible for the privacy practices of third parties beyond the scope of their data processing agreements with us. We encourage you to review the privacy policies of third-party services where relevant.

14. Changes to This Privacy Policy

7spin8 reviews and, where necessary, updates this Privacy Policy periodically to reflect changes in our data processing practices, the Platform's features and services, or applicable Philippine law and regulatory requirements. The date of the most recent revision is indicated at the top of this document.

Material changes to this Policy that affect your rights or the way we process your personal data will be communicated to registered players via the email address associated with your account and/or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the 7spin8 Platform following notification of material changes constitutes your acceptance of the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 7spin8 handles your personal data.

15. Contact Us & Complaints

If you have questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how 7spin8 handles your personal data, please contact our Data Protection Officer:

If you are not satisfied with 7spin8's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the regulatory authority responsible for enforcing the Data Privacy Act of 2012. Information on filing a complaint with the NPC is available through the NPC's official published channels.