7spine Privacy Policy

This Privacy Policy (hereinafter "Policy") is issued by 7spine (hereinafter "7spine," "we," "us," or "the Company"), the operator of the online gaming platform accessible at https://7spine.net (the "Platform"). This Policy applies to all personal data processed in connection with your use of the Platform, including account registration, identity verification (KYC), gaming activity, deposits, withdrawals, customer support interactions, and promotional communications.

This Policy is designed to comply with the requirements of Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines (the "DPA"), the Implementing Rules and Regulations of the DPA, and the applicable circulars and advisories issued by the National Privacy Commission (NPC). It is also designed to be consistent with the data processing obligations imposed on 7spine by PAGCOR as a condition of its online gaming license.

By accessing the 7spine Platform, registering an account, or continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read and understood this Policy and consent to the collection, use, processing, and disclosure of your personal data as described herein.

For the purposes of the Data Privacy Act of 2012 and this Policy, the personal information controller responsible for your personal data is 7spine, operating the Platform at https://7spine.net under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR).

7spine has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with the DPA and this Policy, handling data subject rights requests, and managing any personal data incidents or breaches. The DPO can be contacted via the support channel at [email protected], with "Data Privacy" noted in your message subject. The DPO is required to be registered with the National Privacy Commission in accordance with NPC regulations.

7spine collects personal data across several categories, depending on how you interact with the Platform. The following table outlines the categories of data collected, examples of specific data points, and the primary purpose for which each category is collected.

3.1 Sensitive Personal Information

Under the DPA, certain categories of personal data are classified as sensitive personal information and require additional protection. 7spine may process the following sensitive personal information where required by PAGCOR or AML obligations: government-issued identification number (e.g., SSS number, PhilHealth number, UMID number) as part of KYC verification. Such data is collected only to the extent legally required and is subject to heightened security controls.

7spine collects personal data through the following channels and interactions:

• Account Registration: Information you provide directly when creating your 7spine account, including your name, email, date of birth, and Philippine mobile number.
• KYC Verification Process: Documents and information submitted during identity verification, including uploads of government-issued Philippine ID documents.
• Financial Transactions: Data generated when you make deposits via GCash, Maya, or Philippine bank transfers, or submit withdrawal requests. This includes transaction reference numbers and amounts.
• Platform Usage: Data collected automatically as you use the Platform — including pages visited, games launched, wagers placed, session durations, and navigation patterns — via server logs and application monitoring systems.
• Cookies and Tracking Technologies: Data collected via cookies, web beacons, and similar technologies as described in Section 9 of this Policy.
• Customer Support Interactions: Information you provide when contacting 7spine's support team via live chat or email, including your account details and the nature of your inquiry.
• Third-Party Service Providers: Information received from third-party identity verification providers, payment processors, fraud detection services, and game studio platforms operating within the 7spine ecosystem.

Under the DPA, personal data may only be processed where a lawful basis exists. 7spine processes personal data on the following legal grounds:

5.1 Contractual Necessity

Processing is necessary for the performance of the contract between you and 7spine (the Terms and Conditions). This covers: account creation and management; processing deposits and withdrawals through GCash, Maya, and Philippine banks; delivery of gaming services including slots, live casino, sports betting, sabong, and bingo; and communicating with you in connection with your account and transactions.

5.2 Legal and Regulatory Obligation

Processing is required to comply with legal and regulatory obligations applicable to 7spine as a PAGCOR-licensed online gaming operator. This includes: KYC identity verification and age verification (21+ requirement); AML monitoring and reporting under Republic Act No. 9160 as amended; PAGCOR reporting obligations on player activity and gaming revenue; and tax compliance under Philippine revenue regulations.

5.3 Consent

Where processing is not covered by contractual necessity or legal obligation, 7spine will seek your explicit consent. This applies primarily to direct marketing communications — promotional emails, SMS messages, and push notifications about 7spine offers, bonuses, and platform updates. You may withdraw marketing consent at any time through your account notification settings or by contacting support.

5.4 Legitimate Interest

Where neither contractual necessity, legal obligation, nor consent applies, 7spine may process personal data where it has a legitimate interest that is not overridden by your rights and freedoms. This includes: fraud detection and prevention; platform security monitoring and anomaly detection; improving the Platform's performance and user experience through aggregated analytics; and responsible gaming monitoring to identify players who may be experiencing harm.

7spine retains personal data only for as long as is necessary for the purposes set out in this Policy and as required by applicable Philippine law and PAGCOR regulations. The following retention periods apply:

• KYC and Identity Documents: Retained for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and Philippine AML regulations (Republic Act No. 9160).
• Financial Transaction Records: Retained for a minimum of five (5) years following the date of each transaction, in compliance with AML reporting and audit requirements.
• Gaming Activity Data: Retained for a minimum of three (3) years following the date of each gaming session, for PAGCOR reporting, dispute resolution, and responsible gaming purposes.
• Customer Support Records: Retained for three (3) years following the conclusion of each support interaction, for dispute resolution and quality assurance purposes.
• Marketing Consent Records: Retained for the duration of the consent and for two (2) years following withdrawal of consent, to evidence compliance with consent requirements.
• Technical and Log Data: Retained for twelve (12) months from the date of collection, unless retained for a longer period as part of an active fraud investigation or legal proceeding.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised (so that it can no longer be linked to an identifiable individual) in accordance with 7spine's data disposal procedures.

7spine does not sell your personal data to third parties. Personal data is shared only in the following limited circumstances, each of which has a lawful basis under the DPA:

7.1 Regulatory and Law Enforcement Authorities

7spine is required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other Philippine government authorities as required by law, court order, or regulatory directive. Such disclosures are made without notice to the affected player where legally required or where providing notice would compromise the purpose of the disclosure.

7.2 Payment Processing Partners

To process deposits and withdrawals, 7spine shares necessary financial data with payment service providers including GCash (G-Xchange Inc.), Maya (PayMaya Philippines), and Philippine banking institutions (BPI, BDO, Metrobank). These providers process data only as necessary to complete payment transactions and are bound by their own privacy obligations under Philippine law.

7.3 KYC and Identity Verification Providers

7spine uses third-party identity verification services to conduct KYC checks required by PAGCOR and AML regulations. These providers process identity documents and biometric checks on behalf of 7spine under strict contractual data processing agreements that limit their use of your data to identity verification purposes only.

7.4 Game Content Providers

Game studios and providers whose games are integrated into the 7spine Platform (including Pragmatic Play, Microgaming, and Play'n GO) may receive session and gameplay data required to operate their games. This data is limited to what is technically necessary for game delivery and does not include full identity or financial data.

7.5 Platform Security and Fraud Prevention

7spine may share technical data (including IP addresses, device fingerprints, and session patterns) with fraud detection and cybersecurity service providers to identify and prevent fraudulent or abusive activity on the Platform.

The 7spine Platform primarily operates within the Philippines, and most personal data processing occurs on servers located in the Philippines. However, some third-party service providers — including certain game studios and technical infrastructure providers — may process personal data from servers located outside the Philippines.

Where personal data is transferred outside the Philippines, 7spine ensures that such transfers comply with Section 21 of the Data Privacy Act of 2012, which requires that the recipient country or organization provides a comparable level of data protection. This is achieved through: (a) standard contractual clauses in data processing agreements with third-party recipients; (b) processing only with recipients located in jurisdictions assessed to have adequate data protection frameworks; and (c) obtaining NPC approval where required for specific cross-border transfers.

You may request information about specific cross-border transfers affecting your personal data by contacting the 7spine Data Protection Officer as described in Section 15.

7spine uses cookies and similar tracking technologies (web beacons, pixel tags, local storage) on the Platform to operate core functionality, analyze performance, and where consent has been given, serve relevant promotional content to account holders.

9.1 Types of Cookies Used

You can manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will impair or prevent your use of the Platform. For all other cookie categories, you may opt out without affecting core functionality. Withdrawing consent for analytics or marketing cookies does not affect data already processed prior to withdrawal.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 7spine. These rights may be exercised by contacting the Data Protection Officer as described in Section 15.

Requests to exercise any of the above rights should be submitted via live chat or email to [email protected] with "Data Subject Rights Request" in the subject line. 7spine will respond within the timeframe required by the DPA and NPC regulations. Identity verification will be required before any request is fulfilled to prevent unauthorized access to your personal data.

If you believe that 7spine has not adequately addressed your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

7spine implements technical and organizational security measures designed to protect personal data against unauthorized access, disclosure, alteration, or destruction, in accordance with the DPA's security requirement under Section 20 and NPC Circular 16-03 on Security of Personal Data in Government Agencies.

• Encryption in Transit: All data transmitted between your browser and the 7spine Platform is protected using TLS 1.2 or higher (256-bit SSL). Login credentials and payment data are never transmitted in plain text.
• Encryption at Rest: Sensitive personal data — including KYC documents, financial data, and authentication credentials — is encrypted at rest using industry-standard encryption protocols.
• Access Controls: Access to personal data is restricted to authorised 7spine personnel and third-party processors on a strictly need-to-know basis. All access is logged and reviewed regularly.
• Two-Factor Authentication: Optional two-factor authentication is available for all player accounts. Internal systems containing personal data require multi-factor authentication for staff access.
• Incident Response: 7spine maintains a data breach response procedure consistent with NPC Circular 16-03's 72-hour breach notification requirement. In the event of a breach affecting your personal data, you will be notified in accordance with applicable law.
• Regular Security Reviews: Platform security is subject to regular internal review and periodic third-party security assessments to identify and address vulnerabilities.

The 7spine Platform is strictly intended for individuals who are at least 21 years of age. 7spine does not knowingly collect personal data from persons under 21 years of age. The mandatory KYC verification process is specifically designed to verify that all account holders meet the minimum age requirement before being permitted access to real-money gaming services.

If 7spine becomes aware that personal data has been collected from a person under 21 years of age, the affected account will be immediately suspended, all data associated with the account will be securely deleted beyond what is required for regulatory reporting, and any deposits held will be returned to the depositor in accordance with PAGCOR's underage gambling procedures.

Where you have provided consent during registration or account settings, 7spine may contact you with promotional communications about platform offers, bonuses, game launches, and other promotions relevant to your account. These communications may be delivered via email, SMS, or in-platform notifications.

Marketing communications from 7spine will include relevant bonus offers, free spin promotions, sports betting boosts (including PBA season offers, NBA finals promotions, and UFC event specials), bingo jackpot alerts, and VIP program updates. All marketing is targeted based on your gaming activity and preferences on the 7spine Platform only — we do not use third-party data for targeting purposes.

You may withdraw your consent to receive marketing communications at any time, without affecting your ability to use the Platform, by: (a) updating your notification preferences in account settings; or (b) clicking the unsubscribe link in any marketing email; or (c) contacting the support team via live chat or email. Opt-out requests will be processed within five (5) business days.

7spine reserves the right to amend this Privacy Policy from time to time to reflect changes in Philippine law, NPC regulations, PAGCOR licensing requirements, the Platform's data processing activities, or best practice in data protection. The current version of this Policy, with its effective date, will always be accessible at https://7spine.net/privacy-policy.

Where changes are material — for example, where new categories of data are being collected, or where data is being shared with new categories of third parties for new purposes — 7spine will provide advance notice via the email address registered to your account, a notification on the Platform, or both. For non-material changes (such as clarifications of existing language), the updated Policy will be published without individual notification, and your continued use of the Platform following the update will constitute acceptance.

We encourage you to review this Policy periodically to stay informed about how 7spine handles your personal data. If you have concerns about any changes, please contact the Data Protection Officer as described in Section 15 below.

For all data privacy inquiries, data subject rights requests, or concerns about the processing of your personal data, please contact the 7spine Data Protection Officer through the following channel:

If you are not satisfied with 7spine's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.