n33 Privacy Policy

For the purposes of this Privacy Policy, the following definitions apply:

• "n33," "we," "us," "our" — the n33 platform and its operating entity responsible for processing your personal data.
• "Platform" — the n33 website at https://n33.app including all pages, games, account features, and support channels.
• "Player," "you," "your" — any individual who accesses, registers on, or uses the Platform.
• "Personal Data" — any information relating to an identified or identifiable natural person, consistent with the definition under Republic Act No. 10173 (Data Privacy Act of 2012).
• "Processing" — any operation performed on Personal Data, whether automated or manual, including collection, recording, organisation, storage, use, disclosure, or deletion.
• "DPA" — Republic Act No. 10173, the Data Privacy Act of 2012, and its implementing rules and regulations.
• "NPC" — the National Privacy Commission of the Philippines, the regulatory body responsible for enforcing the DPA.
• "PAGCOR" — the Philippine Amusement and Gaming Corporation.
• "KYC" — Know Your Customer, the identity verification process required by PAGCOR and applicable anti-money laundering regulations.

n33 acts as the Personal Information Controller (PIC) with respect to all Personal Data collected through the Platform, as defined under Section 3(h) of the DPA. As PIC, n33 determines the purposes and means of processing your Personal Data and is responsible for its lawful and fair handling.

n33 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and with applicable Philippine data privacy law. Enquiries addressed to the DPO may be submitted through the support contact described in Section 14 of this Policy.

n33 collects Personal Data in several ways and across multiple contexts during your use of the Platform. The categories of data collected are described below.

3.1 Registration Data

When you create an n33 account, we collect the information you provide during the registration process, which includes your full name, date of birth, mobile number or email address, and the password you set for your account. This data is required to create and maintain your account.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR requirements and Philippine anti-money laundering regulations, n33 conducts identity verification before processing withdrawals. KYC data collected includes a copy of your valid Philippine government-issued identification document (such as a PhilSys ID, UMID, driver's licence, or passport) and, where required, supplementary documentation such as proof of address or source of funds declarations.

3.3 Financial Data

n33 collects information necessary to process deposits and withdrawals, including your GCash account number, PayMaya number, or bank account details. n33 does not store full payment card numbers. Financial transaction data — including deposit and withdrawal history, amounts, timestamps, and payment method references — is recorded in your account transaction history.

3.4 Gaming Activity Data

n33 records a complete log of your gaming activity on the Platform, including game sessions, bets placed, game outcomes, bonus usage, and session durations. This data is used for account management, dispute resolution, regulatory reporting, and responsible gaming monitoring.

3.5 Technical and Device Data

When you access the Platform, n33 automatically collects certain technical data, including your IP address, device type and operating system, browser type and version, referring URL, and session timestamps. This data is used for security monitoring, fraud prevention, and platform performance optimisation.

n33 processes your Personal Data for the following specific purposes:

• Account creation and management: Registering your account, maintaining your profile, and administering your relationship with n33.
• Identity verification and KYC compliance: Verifying your identity and age (21+) as required by PAGCOR and Philippine anti-money laundering law.
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported Philippine payment channels.
• Game provision: Enabling your access to and participation in n33 games, including live casino, slots, bingo, and dice.
• Customer support: Responding to your enquiries, complaints, and support requests, and maintaining records of our communications.
• Security and fraud prevention: Monitoring for suspicious activity, protecting your account from unauthorised access, and detecting and preventing fraud, money laundering, and prohibited conduct.
• Responsible gaming: Monitoring gaming patterns to identify indicators of problem gambling and enabling the delivery of responsible gaming tools and interventions in accordance with PAGCOR requirements.
• Regulatory compliance: Meeting n33's obligations to PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), and other applicable Philippine regulatory authorities.
• Platform improvement: Analysing aggregated, anonymised usage data to improve platform performance, user experience, and game offering.
• Promotional communications: Sending you information about bonuses, promotions, and platform updates, subject to your communication preferences.

n33 processes your Personal Data on the following legal bases under the DPA and its implementing rules:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you accepted at registration, including account management, game provision, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing requirements, the Anti-Money Laundering Act, and the DPA itself.
• Legitimate interests: Processing undertaken in pursuit of n33's legitimate business interests — such as fraud detection, security monitoring, and platform analytics — provided those interests do not override your fundamental privacy rights.
• Consent: Where n33 relies on consent as the legal basis for processing — for example, for direct marketing communications — you will be asked for your explicit consent, and you may withdraw that consent at any time without affecting the lawfulness of prior processing.

n33 does not sell, rent, or trade your Personal Data. We share your data only in the limited circumstances described below:

6.1 Service Providers (Personal Information Processors)

n33 engages certain third-party service providers who process Personal Data on our behalf and under our instruction as Personal Information Processors (PIPs) under the DPA. These include payment processors (GCash/GXI, Maya Philippines, and partner banks), identity verification providers, game software providers, cloud hosting providers, and customer support platform operators. All PIPs are contractually bound to process your data only for specified purposes and to implement appropriate security measures.

6.2 Regulatory Authorities

n33 is required by law to disclose certain player data to PAGCOR as part of its licensing obligations, and to the AMLC or other Philippine law enforcement agencies where required to comply with the Anti-Money Laundering Act or a valid court order. Such disclosures are made only to the extent strictly required by the applicable legal obligation.

6.3 Game Providers

Certain game providers who supply live dealer or digital game content to n33 receive limited gaming activity data necessary to operate their game systems and ensure game integrity. This data does not include your full identity or financial details beyond what is operationally necessary.

n33 uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies: Required for the Platform to function correctly. These include session authentication cookies that keep you logged in during your visit and security cookies that help detect fraudulent activity. These cannot be disabled.
• Functional cookies: Allow the Platform to remember your preferences — such as language settings and game display options — between sessions. These enhance your user experience but are not essential to Platform operation.
• Analytics cookies: Collect aggregated, anonymised information about how players use the Platform, including pages visited, session duration, and navigation paths. This data helps n33 improve the Platform's design and performance.

On your first visit to the Platform, you will be presented with a cookie consent notice. You may accept all cookies or manage your preferences for non-essential cookie categories. You may also manage cookie settings through your browser's settings at any time. Note that disabling certain cookies may affect Platform functionality.

n33 retains your Personal Data for the period necessary to fulfil the purposes for which it was collected, subject to the following retention standards:

• Account data: Retained for the duration of your account and for a period of five (5) years following account closure, as required by PAGCOR licensing conditions and applicable Philippine law.
• KYC and identity documents: Retained for a minimum of five (5) years following the last transaction on your account, in accordance with anti-money laundering regulations.
• Financial transaction records: Retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act and PAGCOR requirements.
• Gaming activity logs: Retained for three (3) years for dispute resolution and regulatory audit purposes.
• Technical and device data: Retained for twelve (12) months for security and fraud prevention purposes, after which it is anonymised or deleted.
• Customer support records: Retained for two (2) years from the date of the last support interaction.

Where retention is no longer necessary beyond these periods and no legal obligation requires continued storage, n33 will securely delete or anonymise your Personal Data.

n33 implements a layered set of technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• TLS 1.2 or higher encryption for all data in transit between your device and n33 servers
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records
• Role-based access controls limiting access to Personal Data to n33 personnel who require it for their specific job function
• Multi-factor authentication requirements for n33 staff accessing systems that process Personal Data
• Regular penetration testing and vulnerability assessments conducted by independent security specialists
• Continuous server and application monitoring for anomalous access patterns and potential intrusions
• Formal incident response procedures aligned with NPC breach notification requirements

While n33 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials and for notifying n33 immediately if you suspect that your account has been compromised.

Under the Data Privacy Act of 2012, you have the following rights with respect to your Personal Data held by n33:

• Right to be Informed: The right to know whether n33 holds Personal Data about you, what data is held, and the purposes and means of its processing.
• Right of Access: The right to obtain a copy of the Personal Data n33 holds about you, together with information about how that data is being processed.
• Right to Rectification: The right to have inaccurate or incomplete Personal Data corrected or updated. You may update certain account information directly through your n33 account settings at any time.
• Right to Erasure / Right to be Forgotten: The right to request the deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to n33's legal retention obligations as described in Section 8.
• Right to Object: The right to object to the processing of your Personal Data for direct marketing purposes or on the grounds of legitimate interests, where such processing is not required by law.
• Right to Data Portability: The right to receive a copy of your Personal Data in a structured, commonly used, and machine-readable format, and to transmit that data to another personal information controller where technically feasible.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe that your data privacy rights have been violated by n33.

To exercise any of the above rights, please contact n33 customer support as described in Section 14. n33 will acknowledge your request within 72 hours and respond substantively within thirty (30) calendar days. Where a request requires extended processing time, n33 will notify you of the reason for the delay and the expected completion date.

Where n33 discovers or has reason to believe that an account has been registered by an individual under 21 years of age, the account will be immediately suspended and any associated Personal Data will be deleted from n33 systems within a reasonable period, except to the extent that retention is required by law to record the violation.

If you believe that an individual under 21 has created an n33 account, please contact n33 customer support immediately so that the account can be reviewed and appropriate action taken.

n33 primarily processes and stores your Personal Data within the Philippines. Where the use of certain service providers — including game software vendors and cloud infrastructure partners — involves the transfer of Personal Data to servers or personnel located outside the Philippines, n33 ensures that such transfers comply with the requirements of the DPA and applicable NPC rules on cross-border data transfers.

Specifically, n33 ensures that any cross-border transfer of Personal Data occurs only where:

• The recipient country has been assessed as providing an adequate level of protection for Personal Data, or
• The recipient has entered into data processing agreements with n33 that include standard contractual clauses providing equivalent protection to that required under Philippine law, or
• The transfer is necessary for the performance of the contract between n33 and the Player (for example, to operate a live dealer game platform hosted by an international provider).

n33 reviews this Privacy Policy periodically and may update it to reflect changes in our data processing practices, regulatory requirements, or platform features. The effective date at the top of this Policy indicates when the current version was last reviewed and approved.

Where changes are material — meaning they significantly affect the way n33 processes your Personal Data or your rights with respect to it — n33 will provide not less than fourteen (14) days' prior notice via the email address associated with your account or through a prominent notice on the Platform. For minor or technical clarifications that do not affect the substance of the Policy, no advance notice will be required.

Your continued use of the n33 Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you must discontinue use of the Platform and may request account closure as described in the Terms and Conditions.

If you have any questions about this Privacy Policy, wish to exercise any of your rights under the DPA, or have a concern about how n33 is handling your Personal Data, you may contact us through the following channels:

Data Protection Officer: Enquiries addressed to n33's DPO may be submitted through the customer support channels below. Please mark your message clearly as a "Data Privacy Enquiry" to ensure it is routed appropriately.

Customer Support: Available 24 hours a day, 7 days a week through the live chat feature accessible from any page of the n33 Platform.

Email: support at n33.app — please use the subject line "Privacy Policy Enquiry" for data-related matters. Responses to data privacy enquiries are provided within one (1) business day for urgent matters and within five (5) business days for general enquiries.

If you are not satisfied with n33's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about the NPC complaints process is available on the official NPC website.

n33 is committed to resolving all data privacy concerns fairly, transparently, and in accordance with the DPA. We take all such concerns seriously and will investigate and respond to every complaint we receive.