Privacy Policy — 7spine

Introduction and Scope

This Privacy Policy ("Policy") is issued by the operator of 7spine ("7spine," "we," "us," or "the Operator"), the online gaming platform accessible at https://7spine.app. This Policy governs the collection, use, storage, disclosure, and protection of personal information provided by or collected about registered players and visitors ("you" or "the Data Subject") in connection with the 7spine platform and its associated services.

7spine operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines. Where applicable, 7spine also adheres to relevant PAGCOR data governance requirements for licensed online gaming operators.

By registering an account on 7spine, depositing funds, or otherwise using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal information as described herein. If you do not agree to this Policy, you must not use the 7spine platform.

Legal Basis for Processing

7spine processes your personal data on one or more of the following legal bases as defined under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is required to create and manage your 7spine account, process deposits and withdrawals, and deliver the gaming services you have contracted to receive.
• Legal Obligation: 7spine is required by PAGCOR regulations, Philippine anti-money laundering law (Republic Act No. 9160, as amended), and tax regulations to collect and retain certain personal data. Compliance with these obligations is non-negotiable.
• Legitimate Interests: 7spine processes certain data to detect and prevent fraud, protect platform security, investigate potential breaches of our Terms and Conditions, and improve the quality of the 7spine platform — where such interests are not overridden by your rights.
• Consent: Where 7spine sends you marketing communications, offers, or personalized promotions, we rely on your explicit consent, which you may withdraw at any time by contacting our support team.

Personal Data We Collect

7spine collects personal data through several channels: directly from you during registration and account use, automatically through your interaction with the platform, and from third-party service providers (such as payment processors and identity verification services). The categories of personal data collected are as follows:

3.1 Registration and Identity Data

• Philippine mobile number (primary account identifier)
• Full legal name (collected during KYC verification)
• Date of birth (to verify the 21+ age requirement)
• Government-issued ID information (Philippine National ID, UMID, driver's license, or passport number and copy)
• Residential address

3.2 Transaction and Financial Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references
• GCash, Maya, BPI, BDO, or other payment method account identifiers (as applicable)
• Account balance history and wagering records
• Bonus and promotional credit activity

3.3 Technical and Usage Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type
• Session duration, page views, and feature interaction logs
• Cookie identifiers and tracking pixel data (see Section 5)

3.4 Communications Data

• Content of live chat and Telegram support conversations
• Complaint and dispute correspondence
• Responses to surveys or feedback requests (where voluntarily provided)

3.5 Responsible Gaming Data

• Voluntary deposit limits, session time limits, and cooling-off periods set by you
• Self-exclusion status and duration
• Problem gambling referral records (where applicable)

How 7spine Uses Your Personal Data

7spine uses the personal data collected for the following specific purposes:

7spine does not use your personal data for any purpose not listed in this table without first obtaining your explicit consent or establishing a valid legal basis under the Data Privacy Act of 2012.

Cookies and Tracking Technologies

7spine uses cookies and similar tracking technologies to operate the platform effectively, remember your session preferences, and analyze platform usage patterns. Cookies are small data files stored on your device by your browser when you visit the 7spine website.

5.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged in to your 7spine account during a session. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and game lobby filters. These improve your experience but are not strictly required for the platform to operate.
• Analytics Cookies: Used to understand how players interact with the 7spine platform — which features are used most, where sessions begin and end, and how performance can be improved. Analytics data is aggregated and does not identify individual players.
• Security Cookies: Used to detect fraudulent activity, unusual login behavior, and potential account security threats.

5.2 Managing Cookies

You may configure your browser to block or delete cookies at any time. Please note that disabling strictly necessary cookies will prevent you from logging in to your 7spine account. Instructions for managing cookies are available in the help documentation of your browser (Chrome, Samsung Internet, Firefox, Safari, etc.).

Data Sharing and Disclosure

7spine does not sell, rent, or trade your personal information to any third party. We share personal data only in the following limited circumstances:

6.1 Service Providers

7spine engages third-party service providers to assist with specific operational functions, including payment processing (GCash, Maya, BPI, BDO, InstaPay, and others), identity verification services, cloud hosting infrastructure, and customer communication platforms. These providers access only the personal data necessary to perform their contracted function and are bound by data processing agreements requiring them to maintain confidentiality and comply with applicable data protection law.

6.2 Regulatory and Law Enforcement Authorities

7spine discloses personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other Philippine government authorities when required to do so by law, court order, or regulatory directive. 7spine will not notify you of such disclosures where doing so would interfere with a legal investigation.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving the 7spine platform, personal data held about players may be transferred to the acquiring entity as part of the transaction, subject to the same privacy protections described in this Policy. Players will be notified of any material change to data controllership resulting from such a transaction.

6.4 Professional Advisers

7spine may share personal data with legal counsel, auditors, and compliance consultants on a strictly confidential basis where necessary to obtain professional advice or defend legal claims.

International Data Transfers

The 7spine platform primarily stores and processes personal data within server infrastructure located in the Asia-Pacific region. Where any transfer of personal data outside the Philippines is necessary — for example, to cloud infrastructure providers or game platform operators with servers in other jurisdictions — 7spine ensures that such transfers are made only to countries or organizations that provide an adequate level of data protection, or under contractual arrangements that impose data protection obligations equivalent to those required under Philippine law.

Players with questions about the specific jurisdictions to which their data may be transferred may submit a request to our Data Protection Officer using the contact details in Section 15.

Data Retention

7spine retains personal data for the period necessary to fulfill the purposes outlined in this Policy, or as required by Philippine law. The principal retention periods applicable to 7spine player data are as follows:

• Account and Identity Data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, as required by Philippine anti-money laundering regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLC reporting obligations and BIR requirements.
• KYC Documentation: Retained for a minimum of five (5) years following the end of the account relationship.
• Support Communications: Retained for three (3) years from the date of the communication, unless the content is relevant to an ongoing or anticipated legal matter.
• Technical and Usage Logs: Retained for twelve (12) months from the date of generation, unless required for an active security investigation.
• Marketing Consent Records: Retained for the duration of the consent and for three (3) years following withdrawal, to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Anonymized data — from which no individual can be identified — may be retained indefinitely for aggregate analytics and platform improvement purposes.

Your Data Privacy Rights

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

• Right to be Informed: You have the right to know what personal data 7spine collects about you, how it is used, and with whom it is shared. This Privacy Policy fulfills that obligation.
• Right of Access: You may request a copy of the personal data 7spine holds about you. 7spine will provide this within thirty (30) days of a verified request.
• Right to Rectification: If any personal data held by 7spine is inaccurate or incomplete, you have the right to request correction. For basic account data, corrections can be made through the account settings section or by contacting support.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. This right is subject to 7spine's legal obligations — for example, transaction records required by AMLC cannot be erased before the legally mandated retention period expires.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where your particular situation warrants it.
• Right to Data Portability: Where technically feasible and legally permissible, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: If you believe 7spine has violated your data privacy rights, you may file a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

Data Security Measures

7spine implements a layered set of technical and organizational security measures designed to protect your personal data against unauthorized access, alteration, disclosure, and destruction. These measures include:

• Transport Encryption: All data transmitted between your device and 7spine servers is encrypted using TLS (Transport Layer Security). This is the same encryption standard used by banks and financial institutions.
• Data-at-Rest Encryption: Personal data stored on 7spine servers is encrypted at rest using industry-standard algorithms.
• Access Controls: Access to personal data is restricted to authorized 7spine personnel on a strict least-privilege basis. All access is logged and subject to periodic review.
• OTP Authentication: Account-level changes, including password resets and payment method updates, require one-time password verification to your registered Philippine mobile number.
• Intrusion Detection: 7spine operates continuous monitoring systems to detect unusual access patterns and potential security incidents in real time.
• Periodic Security Assessments: 7spine conducts regular security assessments of its platform and third-party integrations to identify and remediate vulnerabilities.

10.1 Data Breach Response

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, 7spine will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act and NPC Circular No. 16-03.

Minors and Age Restriction

The 7spine platform is strictly intended for individuals who are twenty-one (21) years of age or older. 7spine does not knowingly collect personal data from persons under the age of 21. Registration on 7spine requires confirmation of the player's age, and identity verification procedures are in place to enforce this requirement.

If 7spine becomes aware that personal data has been collected from a person under the age of 21, the relevant account will be immediately suspended, the personal data will be deleted or anonymized, and any deposits made will be refunded to the originating payment method, subject to verification of the refund destination.

If you believe a person under the age of 21 has registered on 7spine, please contact our support team or Data Protection Officer immediately using the details in Section 15.

Responsible Gaming and Data Use

7spine uses gaming behavior data — including session frequency, betting patterns, deposit frequency, and use of responsible gaming tools — to fulfill its responsible gaming obligations. Specifically, this data is used to:

• Identify players who may be exhibiting signs of problem gambling behavior, as required under PAGCOR's responsible gaming guidelines.
• Enforce voluntary deposit limits, session time limits, and self-exclusion settings activated by the player.
• Contact players who have been flagged for responsible gaming review, where warranted by observed behavior patterns.
• Maintain self-exclusion records to prevent re-registration by excluded players during the exclusion period.

Third-Party Links and External Platforms

The 7spine platform does not include links to third-party websites or external platforms other than those listed in the 7spine navigation menu. Where your interaction with 7spine requires use of a third-party payment platform (such as GCash or Maya), that platform's own privacy policy governs the processing of your data within their system. 7spine is not responsible for the privacy practices of any third-party payment provider or service.

7spine encourages players to review the privacy policies of any external platforms they use in connection with their 7spine account, particularly those of their chosen e-wallet or banking provider.

Updates to This Privacy Policy

7spine may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or operational requirements. Material changes to this Policy will be communicated to registered players via a platform notification and/or an SMS to their registered Philippine mobile number, no fewer than seven (7) days before the revised Policy takes effect.

The most current version of this Privacy Policy is always available at https://7spine.app/privacy-policy. The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of 7spine following the effective date of any revision constitutes your acceptance of the updated Policy.

Contact and Data Protection Officer

For all data privacy-related inquiries, requests, or complaints, please contact the 7spine Data Protection Officer through the following channels:

• Live Chat: Available directly from the 7spine platform dashboard, 24 hours a day, 7 days a week. Select "Privacy / Data Request" from the support menu.
• Telegram: Via the official 7spine Telegram support channel, available 24/7 in Philippine Standard Time.
• Email: [email protected] — please use the subject line "Data Privacy Request — [Your Registered Mobile Number]" to ensure your request is routed directly to the Data Protection Officer.

7spine will acknowledge all data privacy requests within five (5) business days and provide a substantive response within thirty (30) days. Where a request is complex or involves a large volume of data, 7spine may extend this period by a further thirty (30) days, in which case you will be notified of the extension and the reason for it.

If you are not satisfied with 7spine's response to a data privacy request or complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines. Information about filing a complaint with the NPC is available at the NPC's official website.