7spine Privacy Policy

1. Introduction

7spine ("we," "us," or "our") operates the online gambling platform accessible at 7spine.vip (the "Platform"). In the course of providing our services to registered players in the Philippines and other permitted jurisdictions, 7spine collects and processes personal data. We take this responsibility seriously.

This Privacy Policy ("Policy") is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and the applicable issuances of the National Privacy Commission ("NPC"). This Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal data when you register, access, or use the 7spine platform.

By registering a 7spine account or using any part of the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not consent, you must not use the Platform.

2. Data Controller

7spine is the personal information controller ("PIC") in respect of all personal data collected and processed through the Platform. For the purposes of the Philippine Data Privacy Act, 7spine determines the purposes and means of processing your personal data.

Where 7spine engages third-party service providers to process personal data on its behalf (e.g., payment processors, KYC verification providers, cloud infrastructure providers), those parties act as personal information processors ("PIPs") and are bound by data processing agreements that impose obligations consistent with this Policy and the DPA.

3. Personal Data We Collect

Depending on how you interact with the 7spine platform, we may collect the following categories of personal data:

We collect only the personal data that is necessary for the specific purposes described in Section 4 of this Policy. We do not collect sensitive personal information beyond what is required for identity verification and AML compliance purposes.

4. How We Use Your Personal Data

7spine processes your personal data for the following purposes:

• Account Registration and Management: To create, maintain, and administer your 7spine player account, verify your identity, and enable access to Platform services.
• KYC and AML Compliance: To verify your identity, confirm your age (21+ requirement), and comply with Anti-Money Laundering obligations under Philippine law (RA 9160, as amended).
• Payment Processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other supported payment channels, and to maintain accurate financial records.
• Platform Operation and Game Delivery: To deliver gaming services, record game outcomes, calculate and credit winnings, and maintain the integrity of all games on the Platform.
• Fraud Prevention and Security: To detect and prevent unauthorized access, fraudulent transactions, bonus abuse, and other prohibited conduct described in 7spine's Terms & Conditions.
• Responsible Gaming: To monitor gambling behavior patterns, enforce player-set limits and self-exclusion elections, and identify players who may be exhibiting signs of problem gambling.
• Customer Support: To respond to your inquiries, resolve complaints, and provide assistance through our 24/7 live chat and email support channels.
• Legal and Regulatory Compliance: To comply with applicable Philippine laws, PAGCOR regulations, NPC directives, and court orders, including mandatory reporting obligations under the AMLA.
• Platform Improvement: To analyze Platform usage patterns (in aggregated, anonymized form where possible) to improve user experience, game performance, and platform stability.
• Marketing Communications: To send you promotional offers, bonus notifications, and product updates — but only where you have provided explicit consent and only through the communication channels you have opted into.

5. Legal Basis for Processing

7spine processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing is necessary to perform the contract between you and 7spine (i.e., the Terms & Conditions) — including account creation, payment processing, game delivery, and withdrawal handling.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including KYC/AML obligations, PAGCOR regulatory requirements, and NPC data privacy directives.
• Legitimate Interests: Processing is necessary for 7spine's legitimate interests in fraud prevention, platform security, responsible gaming enforcement, and customer support, where such interests are not overridden by your data privacy rights.
• Consent: Where processing is not covered by the above bases — in particular, for direct marketing communications — 7spine relies on your freely given, specific, informed, and unambiguous consent, which you may withdraw at any time.

6. Data Sharing and Disclosure

7spine does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing safeguards:

• Payment Processors: GCash (GXI / Globe), Maya (PayMaya Philippines), BPI, BDO, Metrobank, and other payment service providers for the purpose of processing deposits and withdrawals.
• KYC and Identity Verification Providers: Third-party identity verification services that assist in validating government-issued IDs and performing biometric checks as part of our KYC process.
• Game Providers and Studios: Game software providers (e.g., Pragmatic Play, PG Soft, Jili) receive limited transactional and session data necessary to operate their games within the 7spine platform.
• Cloud Infrastructure and IT Providers: Hosting, database, and security infrastructure providers who process data on 7spine's behalf under contractual data processing agreements.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the NPC, Philippine law enforcement agencies, and courts of competent jurisdiction — where disclosure is required by law, court order, or regulatory directive.
• Customer Support Platforms: Live chat and ticketing system providers used to deliver our 24/7 support service, subject to confidentiality obligations.

7. Cookies and Tracking Technologies

7spine uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for core platform functionality, including session management, login state persistence, and security token validation. These cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used in aggregated, anonymized form to understand how players navigate the Platform, which games are most accessed, and where technical errors occur.
• Preference Cookies: Store your language preferences, display settings, and responsible gaming limit configurations.
• Security Cookies: Help detect and prevent fraudulent sessions, bot activity, and multi-account behavior.

You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality. 7spine does not use third-party advertising tracking cookies or sell cookie data to advertising networks.

8. Data Retention

7spine retains your personal data for as long as necessary to fulfil the purposes described in this Policy, including for the duration of your active account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AML record-keeping obligations under Philippine law.

Financial transaction records are retained for a minimum of ten (10) years from the date of the transaction, as required by the Anti-Money Laundering Act of the Philippines. After the applicable retention period, your data is securely deleted or anonymized using industry-standard data destruction procedures.

9. Data Security

7spine implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 7spine's servers.
• Encrypted storage of passwords using salted cryptographic hashing algorithms — passwords are never stored in plain text.
• Role-based access controls limiting internal access to personal data to authorized personnel on a strict need-to-know basis.
• Regular penetration testing and security audits conducted by qualified third-party security professionals.
• Multi-factor authentication requirements for internal administrative access to player data systems.
• Incident response procedures consistent with NPC breach notification requirements under the DPA.

In the event of a personal data breach that is likely to result in harm to your rights and freedoms, 7spine will notify the NPC within 72 hours of becoming aware of the breach and will notify affected data subjects without undue delay where required by the DPA.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data processed by 7spine:

• Right to be Informed: The right to be notified of how your personal data is being collected and processed, as set out in this Policy.
• Right of Access: The right to request a copy of the personal data 7spine holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data, subject to overriding legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing or other purposes based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact 7spine's Data Protection Officer at the contact details in Section 14. 7spine will respond to verified data subject requests within fifteen (15) business days.

11. Children's Privacy

The 7spine platform is strictly for individuals aged 21 years and above. 7spine does not knowingly collect personal data from individuals under the age of 21. If 7spine discovers that personal data has been collected from an individual below the minimum age requirement, the relevant account will be immediately suspended, all funds will be withheld pending investigation, and the personal data will be deleted in accordance with applicable law.

If you believe that a minor has registered on the 7spine platform, please contact us immediately at [email protected] (plain text — not a clickable link).

12. Cross-Border Data Transfers

In order to deliver certain services — including game software, payment processing, and cloud infrastructure — 7spine may transfer your personal data to service providers located outside the Philippines. Where such transfers occur, 7spine ensures that appropriate safeguards are in place, including data transfer agreements that impose data protection standards equivalent to those required by the Philippine DPA and its IRR.

7spine does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate contractual, technical, and organizational safeguards as required by the NPC.

13. Updates to This Privacy Policy

7spine may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will publish the updated Policy on this page with a revised effective date. Where required by the DPA, we will provide direct notification to affected data subjects via their registered email address or mobile number.

Your continued use of the 7spine platform following publication of an updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with any update to this Policy, you should cease using the Platform and request account closure in accordance with the Terms & Conditions.

14. Contact & Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or the exercise of your data subject rights, please contact 7spine's Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 on the 7spine platform. Tagalog and English agents available.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with our response to your data subject request. Information about the NPC's complaint procedures is available on the NPC's official website.