Privacy Policy

1. Who We Are

This Privacy Policy applies to the online gaming platform operated under the brand name ii89, accessible at ii89.club and its associated subdomains (collectively, the "Platform"). References to "ii89," "we," "us," or "our" in this Policy refer to the operator of the ii89 Platform.

ii89 is committed to protecting the personal data of all players and visitors in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC). We also comply with applicable PAGCOR data handling requirements.

2. Data We Collect

When you register, use, or interact with the ii89 Platform, we may collect the following categories of personal data:

2.1 Identity and Contact Data

• Full legal name, date of birth, gender
• Email address, mobile number
• Residential address (city, province, postal code)
• Government-issued ID details submitted during KYC verification (e.g., passport number, driver's license number, PhilSys reference number)

2.2 Financial Data

• GCash account name and registered mobile number
• PayMaya/Maya account details
• Bank account name and account number (for bank transfer transactions)
• Debit card details (card type, last four digits, expiry — full card numbers are never stored by ii89)
• Transaction history: deposits, withdrawals, bonus credits, and adjustments

2.3 Gaming and Behavioral Data

• Game history, bet amounts, win/loss records, session durations
• Bonus and promotion usage
• Responsible gaming tool settings (deposit limits, self-exclusion status)

2.4 Technical and Device Data

• IP address, browser type and version, operating system
• Device identifiers, screen resolution, time zone
• Pages visited, links clicked, session timestamps
• Cookies and similar tracking technologies (see Section 8)

2.5 Communications Data

• Live chat transcripts and support ticket records
• Email correspondence with ii89 support
• Survey responses and feedback submissions

3. How We Use Your Data

ii89 processes your personal data only for lawful purposes. The table below summarizes our primary processing activities and the legal basis for each:

Purpose	Legal Basis
Account registration and identity verification (KYC)	Contractual necessity; legal obligation
Processing deposits and withdrawals	Contractual necessity
Providing access to games and platform features	Contractual necessity
Anti-money laundering (AML) and fraud prevention	Legal obligation; legitimate interest
Responsible gaming monitoring and intervention	Legal obligation; legitimate interest
Customer support and dispute resolution	Contractual necessity; legitimate interest
Sending transactional notifications (e.g., deposit confirmations)	Contractual necessity
Sending promotional communications (bonuses, offers)	Consent (you may opt out at any time)
Platform analytics and performance improvement	Legitimate interest
Compliance with PAGCOR reporting requirements	Legal obligation

4. Sharing Your Data

ii89 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash (Mynt), PayMaya/Maya, and partner banks, solely to facilitate deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers who assist in verifying your identity documents.
• Game software providers: Licensed game studios whose titles are available on the ii89 Platform may receive anonymized or pseudonymized gameplay data for technical and audit purposes.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where required by law.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection vendors operating under strict data processing agreements.
• Legal and professional advisors: Lawyers, auditors, and compliance consultants bound by professional confidentiality obligations.

All third-party service providers engaged by ii89 are required to implement appropriate technical and organizational security measures and to process personal data only on ii89's documented instructions.

5. Data Retention

ii89 retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods include:

• Account and KYC records: Retained for a minimum of five (5) years after account closure, in compliance with PAGCOR and AMLC requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support communications: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter for audit purposes.
• Technical logs: Retained for up to twelve (12) months, unless required for longer periods for security investigations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with ii89's data disposal procedures.

6. Data Security

ii89 implements a layered security framework to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the ii89 Platform.
• Encryption at rest for sensitive data stored in our databases, including financial records and identity documents.
• Two-factor authentication (2FA) available on all player accounts.
• Role-based access controls limiting internal access to 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.

Despite these measures, no system is completely immune to security risks. In the event of a personal data breach that is likely to result in harm to affected individuals, ii89 will notify the National Privacy Commission and affected players in accordance with the Data Privacy Act of 2012 and NPC Circular 16-03.

7. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ii89:

• Right to be informed: You have the right to know what personal data ii89 collects and how it is processed.
• Right of access: You may request a copy of the personal data ii89 holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure or blocking: You may request deletion or blocking of your personal data where processing is no longer necessary or lawful, subject to ii89's legal retention obligations.
• Right to object: You may object to processing based on legitimate interest, including direct marketing.
• Right to data portability: You may request your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: You have the right to file a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact the ii89 Data Privacy Officer at [email protected] (plain text — not a clickable link). We will respond to verified requests within fifteen (15) business days.

8. Cookies and Tracking Technologies

ii89 uses cookies and similar technologies to operate the Platform, remember your preferences, analyze usage patterns, and deliver relevant promotional content. The types of cookies we use include:

• Essential Required for the Platform to function. These cannot be disabled without affecting core features such as login sessions and game loading.
• Functional Remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics Help us understand how players navigate the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Marketing Used to deliver promotional content relevant to your interests. These are only activated with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies may impair your ability to use the ii89 Platform.

9. Children's Privacy

The ii89 Platform is strictly intended for individuals aged 21 years and above. ii89 does not knowingly collect personal data from anyone under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the ii89 Platform, please contact us immediately at [email protected].

10. International Data Transfers

ii89's primary data processing infrastructure is located within the Philippines. Where data is transferred to service providers operating in other jurisdictions, ii89 ensures that appropriate safeguards are in place, including contractual clauses that require the recipient to protect personal data to a standard equivalent to that required under Philippine law.

11. Changes to This Policy

ii89 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. When we make material changes, we will post the updated Policy on this page with a revised effective date and, where appropriate, notify registered players via email or in-platform notification. Your continued use of the ii89 Platform after the effective date of any updated Policy constitutes your acceptance of the changes.

12. Contact and Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ii89, please contact our Data Privacy Officer:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the ii89 Platform

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with our response to your data privacy concern.