7spine Privacy Policy

1. Introduction

7spine ("we", "us", "our") is committed to protecting the personal information of every player who uses the 7spine online casino platform at 7spine.club ("the Platform"). This Privacy Policy is issued in compliance with Republic Act No. 10173, known as the Data Privacy Act of 2012 (DPA) of the Philippines, and its Implementing Rules and Regulations (IRR), as overseen by the National Privacy Commission (NPC).

This Policy applies to all personal data collected through the Platform, including during account registration, identity verification (KYC), financial transactions, gameplay activity, customer support interactions, and marketing communications. By registering an account with 7spine, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2. Personal Data We Collect

7spine collects the following categories of personal data in the course of providing its services to you:

7spine does not collect sensitive personal information as defined under Section 3(l) of the DPA (such as health records, sexual orientation, religious beliefs, or political affiliation) in the ordinary course of operations.

3. Legal Basis for Processing

7spine processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of your account agreement with 7spine, including account creation, deposits, gameplay, withdrawals, and customer support.
• Legal Obligation: Certain processing (particularly KYC, AML monitoring, and gaming regulatory reporting) is required to comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and NPC directives.
• Legitimate Interests: Security monitoring, fraud prevention, platform performance analytics, and responsible gaming monitoring are conducted on the basis of 7spine's legitimate interests as an online gaming operator.
• Consent: Marketing communications are sent only where you have expressly opted in. You may withdraw marketing consent at any time via your 7spine account settings or by contacting support.

4. How We Use Your Personal Data

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

• To create, verify, and maintain your 7spine account.
• To process deposits and withdrawals via GCash, Maya, BPI, BDO, and other Philippine payment channels.
• To comply with Know Your Customer (KYC) requirements before processing first withdrawals.
• To deliver the games, bonuses, tournaments, and other platform features you access on 7spine.
• To monitor account activity for signs of problem gambling and provide access to responsible gaming tools.
• To detect, investigate, and prevent fraudulent activity, unauthorized access, and financial crime.
• To send you transaction confirmations, security alerts, and account-related notifications via SMS or email.
• To send marketing and promotional communications to players who have opted in.
• To comply with reporting obligations to PAGCOR and other Philippine regulatory authorities.
• To improve platform performance, user experience, and game library based on aggregated, anonymized usage data.

5. Data Sharing and Third Parties

7spine does not sell your personal data to third parties. We share your personal data only in the following limited circumstances:

• Game Providers: Licensed game software providers (such as JILI, Pragmatic Play, PG Soft) receive anonymized session tokens necessary to deliver gameplay. They do not receive your identity or financial data.
• Payment Processors: GCash, Maya, and banking partners receive the minimum financial data required to process your transactions. These processors operate under their own privacy frameworks and are bound by contractual data protection obligations with 7spine.
• Identity Verification Services: Third-party KYC service providers may process copies of your government ID solely for the purpose of identity verification, under strict data processing agreements.
• Regulatory Authorities: 7spine is required by Philippine law to disclose certain data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies when required by lawful order or regulation.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under contractual data processing agreements that prohibit independent use of your data.

All third parties with whom 7spine shares personal data are required to handle it in compliance with the Data Privacy Act of 2012 and applicable Philippine regulations.

6. Data Retention

7spine retains your personal data for as long as your account remains active and for a period of five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act. KYC documents are retained for the period required by AMLC regulations. Gaming and transaction logs are retained for a minimum of five years for regulatory audit purposes.

Where personal data is no longer required for its original purpose or any secondary legal obligation, 7spine will securely delete or anonymize it in accordance with NPC-prescribed data disposal standards.

7. Data Security

7spine implements technical and organizational measures appropriate to the risk profile of online gaming operations to protect your personal data from unauthorized access, disclosure, alteration, and destruction. Key security measures include:

• 256-bit TLS/SSL encryption for all data transmitted between your device and the 7spine Platform.
• Passwords stored using bcrypt hashing with per-account salt — never in plaintext.
• Role-based access controls ensuring that internal staff access only the personal data necessary for their specific function.
• Automated intrusion detection and anomalous login monitoring with real-time alerting.
• Regular independent security audits and penetration testing of Platform infrastructure.
• PCI-DSS compliant payment processing for all financial transactions involving Philippine payment networks.

In the event of a personal data breach that poses a real risk of serious harm to affected individuals, 7spine will notify the National Privacy Commission and affected users within seventy-two (72) hours of discovery, as required under NPC Circular 16-03.

8. Cookies and Tracking Technologies

7spine uses cookies and similar tracking technologies to maintain your login session, remember your preferences, measure platform performance, and detect fraudulent activity. The following cookie categories are in use:

• Strictly Necessary Cookies: Required for core Platform functionality including authentication, session management, and security. These cannot be disabled without impairing your ability to use 7spine.
• Performance Cookies: Collect anonymized data about how players navigate the Platform to help us improve page load times and game lobby layout.
• Functionality Cookies: Remember your language preference, display settings, and last-used payment method to personalize your experience.
• Analytics Cookies: Aggregate, anonymized usage statistics used to improve Platform features and game library curation for Filipino players.

You may manage non-essential cookie preferences through your browser settings. Disabling functionality or analytics cookies may reduce your user experience but will not prevent you from using the core Platform features.

9. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by 7spine:

• Right to be Informed: To know how your personal data is being processed, as described in this Policy.
• Right to Access: To request a copy of the personal data 7spine holds about you.
• Right to Correction: To request correction of inaccurate or outdated personal data in your 7spine account.
• Right to Erasure: To request deletion of personal data where processing is no longer legally required — subject to 7spine's regulatory retention obligations under PAGCOR and AMLC rules.
• Right to Object: To object to processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: To receive a copy of your personal data in a structured, commonly used format where technically feasible.
• Right to Complain: To lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, contact the 7spine Data Privacy Officer via live chat support or by writing to support@7spine.club (plain text — not a clickable link). We will respond to all verified requests within thirty (30) days of receipt.

10. Children and Minors

The 7spine Platform is strictly for individuals aged 21 years and older in compliance with Philippine gaming regulations. 7spine does not knowingly collect personal data from minors. If we discover that an account has been registered by a person under 21 years of age, we will immediately suspend the account, initiate a full review, and securely delete any personal data associated with that account, subject to any legal retention requirements. Parents or guardians who believe a minor has registered with 7spine should contact our support team immediately.

11. Changes to This Privacy Policy

7spine may update this Privacy Policy from time to time to reflect changes in our data practices, Philippine regulatory requirements, or NPC guidance. Material changes will be communicated to registered players via email or on-platform notification at least seven (7) days before taking effect. The "Last Updated" date at the top of this Policy will be revised accordingly. Continued use of 7spine after the effective date of any update constitutes acceptance of the revised Policy.