nicph Privacy Policy

This Privacy Policy ("Policy") describes how nicph ("nicph," "we," "us," "our") collects, uses, stores, shares, and protects the personal information of users ("you," "Player," "Data Subject") of the nicph online gaming platform at nicph.net. This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as well as applicable PAGCOR regulations governing player data.

By registering for or using the nicph platform, 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. If you do not agree to this Policy, please do not use the nicph platform.

1. Who We Are

1.1 nicph is an online gaming platform operating under applicable Philippine gaming regulations and PAGCOR oversight, accessible at nicph.net. nicph acts as the Personal Information Controller ("PIC") in respect of the personal data collected through the platform.

1.2 nicph has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with the DPA and this Policy. Contact details for the DPO are provided in Section 15 of this Policy.

2. Personal Data We Collect

nicph collects the following categories of personal data from players and platform users:

2.1 Identity and Registration Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (for age verification — 21+ requirement);
• Gender (optional, for personalisation purposes);
• Philippine mobile number and/or email address;
• Username and encrypted password;
• Government-issued ID type and number (for KYC verification).

2.2 Financial and Payment Data

• GCash or PayMaya account number (last four digits only, for verification);
• Bank account details (bank name, account number — for withdrawal processing);
• Debit card details (card type, last four digits — stored in tokenised form only);
• Transaction history, including deposit amounts, withdrawal amounts, and dates.

2.3 KYC and Verification Documents

• Scanned or photographed copies of government-issued identification documents (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys ID);
• Proof of address documents (e.g., utility bill, bank statement);
• Selfie or liveness verification image (where required for identity confirmation).

2.4 Usage and Technical Data

• IP address and approximate geolocation (country/region level);
• Device type, operating system, and browser information;
• Session duration, login timestamps, and platform navigation data;
• Game history, wagering activity, and bonus usage records;
• Customer support interaction records, including chat logs and email correspondence.

2.5 Responsible Gaming Data

• Self-imposed deposit limits, loss limits, and session time limits;
• Cooling-off period and self-exclusion records;
• Responsible gaming assessment responses (where voluntarily provided).

3. How We Collect Your Data

3.1 Directly from you — when you register a nicph account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to surveys or promotions.

3.2 Automatically — through cookies, web beacons, and similar tracking technologies when you access and use the nicph platform. See Section 9 for full details on our cookie practices.

3.3 From third parties — from payment service providers (GCash, PayMaya, banks) for transaction verification; from identity verification service providers for KYC processing; and from PAGCOR or other regulatory bodies where required by law.

4. How We Use Your Personal Data

nicph processes your personal data for the following purposes:

• Account management — creating, maintaining, and securing your nicph account;
• Identity verification — confirming your identity and age (21+) in compliance with PAGCOR KYC requirements;
• Payment processing — processing deposits, withdrawals, and refunds via your chosen payment method;
• Regulatory compliance — meeting PAGCOR reporting obligations, anti-money laundering (AML) requirements, and other applicable Philippine legal obligations;
• Responsible gaming — monitoring gameplay patterns to identify potential problem gambling behaviour and enforcing player-set limits and self-exclusion requests;
• Customer support — responding to your enquiries, complaints, and dispute resolution requests;
• Platform improvement — analysing usage data to improve platform performance, game selection, and user experience;
• Marketing communications — sending you promotional offers, bonus notifications, and platform updates, where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time.

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 fulfil our obligations under the nicph Terms & Conditions, including account management, payment processing, and game provision;
• Legal obligation — processing required to comply with PAGCOR regulations, AML obligations, tax reporting requirements, and other applicable Philippine laws;
• Legitimate interests — processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights;
• Consent — processing for marketing communications and optional personalisation features, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 nicph does not sell, rent, or trade your personal data to third parties for commercial purposes.

6.2 nicph may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers — GCash, PayMaya, and banking partners, for the purpose of processing deposits and withdrawals;
• KYC and identity verification providers — third-party services engaged to verify your identity and age in compliance with PAGCOR requirements;
• Game software providers — licensed game studios whose products are available on the nicph platform, to the extent necessary for game operation and fairness auditing;
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law or regulatory directive;
• Professional advisers — lawyers, auditors, and accountants engaged by nicph, subject to professional confidentiality obligations;
• Business successors — in the event of a merger, acquisition, or sale of nicph's business, your data may be transferred to the successor entity, subject to equivalent data protection standards.

7. International Data Transfers

7.1 Where nicph transfers personal data outside the Philippines — for example, to game software providers or cloud infrastructure partners located in other countries — such transfers are conducted in compliance with the DPA's requirements for cross-border data transfers, including the use of appropriate contractual safeguards.

7.2 nicph will not transfer your personal data to a country that does not provide an adequate level of data protection without implementing appropriate safeguards, such as standard contractual clauses approved by the National Privacy Commission.

8. Data Retention

8.1 nicph retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and PAGCOR regulations. Specifically:

• Account and KYC data — retained for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML obligations;
• Transaction records — retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act;
• Customer support records — retained for three (3) years from the date of the interaction;
• Marketing consent records — retained until you withdraw consent or for three (3) years from the date of last interaction, whichever is earlier.

8.2 Upon expiry of the applicable retention period, nicph will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9. Cookies and Tracking Technologies

9.1 nicph uses the following categories of cookies and similar technologies on the platform:

• Essential cookies — required for the platform to function, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies — used to remember your preferences, such as language settings and display options.
• Analytics cookies — used to collect aggregated, anonymised data about how players use the platform, helping nicph improve performance and user experience.
• Marketing cookies — used to deliver relevant promotional content within the nicph platform, based on your activity and preferences. These are only set with your consent.

9.2 You can manage non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the nicph platform.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by nicph:

• Right to be informed — the right to know what personal data nicph collects and how it is used, as set out in this Policy;
• Right of access — the right to request a copy of the personal data nicph holds about you;
• Right to rectification — the right to request correction of inaccurate or incomplete personal data;
• Right to erasure — the right to request deletion of your personal data, subject to nicph's legal retention obligations;
• Right to object — the right to object to certain types of processing, including direct marketing;
• Right to data portability — the right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint — the right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact nicph's Data Protection Officer using the details in Section 15. nicph will respond to all data subject requests within fifteen (15) calendar days of receipt.

11. Children and Minors

11.1 The nicph platform is strictly for individuals aged 21 years and older. nicph does not knowingly collect personal data from individuals under 21 years of age.

11.2 If nicph becomes aware that personal data has been collected from a person under 21, the associated account will be suspended immediately and the personal data will be deleted in accordance with applicable law, subject to any mandatory retention obligations.

11.3 If you believe that a minor has registered on the nicph platform, please contact nicph support immediately at the details provided in Section 15.

12. Security Measures

12.1 nicph implements the following technical and organisational security measures to protect your personal data:

• 256-bit SSL/TLS encryption on all data transmissions between your device and the nicph platform;
• Encrypted storage of passwords using industry-standard hashing algorithms;
• Payment card data tokenisation — nicph does not store full card numbers;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing of platform infrastructure;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

12.2 While nicph takes all reasonable steps to protect your personal data, no internet transmission is completely secure. You are responsible for maintaining the confidentiality of your nicph account credentials.

13. Third-Party Links

The nicph platform may contain references to third-party services such as payment providers. nicph is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party services you use in connection with your nicph account.

14. Changes to This Privacy Policy

14.1 nicph reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered players via email or in-platform notification at least seven (7) days before the changes take effect.

14.2 The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the nicph platform after the effective date of any revision constitutes your acceptance of the updated Policy.

15. Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data rights, please contact nicph's Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Response Time: Within 15 calendar days for data subject requests
• Support Hours: 24 hours a day, 7 days a week

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. Information about the NPC and its complaint procedures is available through official Philippine government channels.