Privacy Policy P9Game –
Your Data Protected by the LGPD

1. Who We Are and How to Contact Us

P9game is an online casino and Sports Betting platform operated for the Brazilian market, accessible at p9game.best. For the purposes of this Privacy Policy, p9game is the controller of the personal data of players registered on the platform — meaning we are the ones who define the purposes and means by which your information is processed.

Our platform offers digital entertainment services including slots, live casino with real dealers, European roulette, blackjack, crash games, baccarat, live Sports Betting on football (Brasileirão Série A, Copa do Brasil, Copa Libertadores), MMA/UFC, basketball (NBB), e-sports, and other available categories. To operate these services safely and legally in Brazil, the processing of personal data is both necessary and unavoidable — and that is exactly why this document exists.

2. Data We Collect About You

P9game collects only the data necessary to operate the platform, process financial transactions, and meet legal obligations. Below we detail each category of data collected and its source:

2.1 Data You Provide During Registration

• Full name as it appears on an official ID.
• CPF (Individual Taxpayer Registry of the Federal Revenue Service).
• Date of birth.
• Full residential address (ZIP code, street, number, neighborhood, city, state).
• Active email address.
• Mobile number with area code.
• Access password (stored in encrypted format only — never as plain text).

2.2 Identity Verification Data (KYC)

• Front and back image of a government-issued ID (RG, CNH, or Passport).
• Selfie holding the document or digital proof of life.
• Recent proof of address (utility bill for electricity, water, or gas, or a bank statement).

Identity verification is required in accordance with withdrawal limits and anti-money laundering (AML) obligations. Submitted documents are retained for the legally required period.

2.3 Financial Transaction Data

• Pix key used for deposits and withdrawals.
• Bank details for TED withdrawals (bank, branch, and account number — never your banking password).
• Partial credit/debit card details (last 4 digits and card brand — the full card number is processed by a secure payment gateway certified by the Central Bank of Brazil).
• Deposit and withdrawal history: dates, amounts in R$, payment methods used, and transaction status.

2.4 Platform Usage Data

• Full betting history: games accessed, amounts wagered in R$, results, and timestamps.
• Gaming sessions: duration, frequency, and usual access times.
• Support interactions: conversation history from live chat, WhatsApp, and email.
• VIP Program level and history of bonuses and cashback received.

2.5 Technical Data Collected Automatically

• Access IP address.
• Device type and version (Android phone, iPhone, tablet, desktop).
• Operating system and browser version.
• Approximate geolocation data (IP-based, not GPS).
• Cookies and session identifiers (detailed in section 6).

3. How We Use Your Data

Every piece of data collected by p9game has a specific purpose. The table below maps each data type to its corresponding use:

P9game does not carry out fully automated decision-making that produces legal effects or significantly impacts players, except in documented cases of automatic fraud detection — which may result in a preventive account suspension, always subject to human review upon request.

4. Legal Basis for Data Processing

The LGPD requires that every personal data processing activity have a specific legal basis. p9game relies on the following legal bases, as set out in Article 7 of Law No. 13,709/2018:

• Contract performance (art. 7, V): The primary legal basis for p9game's operations. Data processing is necessary to create and manage your account, process financial transactions, operate the VIP Program, and deliver all services described in the Terms and Conditions.
• Legal or regulatory obligation (Art. 7, II): Identity verification (KYC), anti-money laundering (AML), compliance with court orders, and responses to requests from competent authorities.
• Legitimate interest (art. 7, IX): Platform security, fraud detection, responsible gambling monitoring, product improvement, and performance analysis — always respecting the rights and reasonable expectations of the data subject.
• Consent (art. 7, I): Used solely to send marketing communications, promotions, and platform updates by email or phone. You may withdraw this consent at any time in your account settings or by clicking "unsubscribe" in any email you receive.

5. Data Sharing with Third Parties

P9game does not sell players' personal data. Data is shared only in the situations listed below, with partners who are contractually and legally obligated to protect the data they receive:

• Payment processors: To process deposits and withdrawals via Pix, TED, credit/debit card, PicPay, and Mercado Pago, minimal financial data is shared with payment processors approved by p9game, all operating under regulation by the Central Bank of Brazil.
• Identity verification (KYC) providers: To verify documents and prevent fraud, p9game may use specialized biometric and CPF verification services. These providers act as data processors under p9game's instruction and are subject to the same LGPD obligations.
• Game providers: To operate the platform's games (slots, Live Casino, roulette, blackjack, etc.), providers such as Pragmatic Play and Evolution Gaming receive minimal technical session data required to load the games. They do not receive your full personal data.
• IT infrastructure and security: Server hosting, CDN, DDoS protection, and cybersecurity providers that process technical data to keep the platform operational and secure.
• Public authorities: In response to court orders, requests from the Public Prosecutor's Office, the Federal Police, or any other competent authority with legal power to requisition data in Brazil.

All third parties with whom p9game shares personal data sign Data Processing Agreements (DPAs) requiring compliance with the LGPD and equivalent protection standards. p9game maintains an up-to-date register of all data processors it works with.

6. Cookies and Tracking Technologies

P9game uses cookies and similar technologies to ensure the platform functions correctly, personalize your experience, and analyze service usage. Each type is explained below:

• Essential cookies: Required for the platform's core functionality — keeping your session active while you play, remembering your language preferences, and processing transactions. These cookies cannot be disabled, as the platform will not work correctly without them.
• Performance and analytics cookies: Used to understand how players navigate the platform — which games are most accessed, which registration steps generate the most questions, and which features need improvement. Data is aggregated and does not identify you individually.
• Functionality cookies: They remember your personal preferences — such as the game you were playing when you last left, your Live Casino volume settings, and other customizations that make the experience smoother on both mobile and desktop.
• Security cookies: They detect suspicious access, protect against CSRF attacks, and help identify unauthorized login attempts. These cookies are a core part of p9game's account protection system.

Most browsers and mobile devices allow you to manage cookie preferences in your privacy settings. However, disabling essential cookies may prevent the platform from functioning properly. On p9game's native app for Android and iOS, cookies are replaced by session identifiers that work in an equivalent way.

7. Data Security

P9game employs a comprehensive set of technical and organizational measures to protect players' personal data against unauthorized access, loss, alteration, or improper disclosure:

• 256-bit SSL/TLS encryption across all client-server communications.
• Player passwords are stored exclusively as salted hashes — never in plain text. Not even p9game staff can see your password.
• Two-factor authentication (2FA) available and recommended for all players.
• Internal access controls based on the principle of least privilege — each p9game team member can only access the data necessary for their specific role.
• Continuous monitoring of suspicious activity across systems and player accounts.
• Regular penetration testing and security audits conducted by specialized firms.
• Documented incident response plan, including notification timelines for data subjects and the ANPD as required by the LGPD.

In the event of a security incident that may affect your data, p9game is committed to notifying you by email within 72 hours of confirming the incident, describing what happened, which data was affected, and the steps taken to mitigate the risks.

8. How Long We Retain Your Data

P9game retains players' personal data only for as long as strictly necessary to fulfill the purposes described in this policy and to comply with applicable legal obligations in Brazil. The specific timeframes are:

• Active account data: For as long as the account remains active on the platform.
• Data after account closure: Retained for 5 years to meet legal obligations under the Brazilian Civil Code (art. 206), anti-money laundering laws (Law No. 9,613/1998), and potential legal disputes.
• KYC documents (ID, proof of address): Retained for a minimum of 5 years after account closure, in accordance with anti-money laundering requirements.
• Financial transaction records: Retained for 5 years for tax and regulatory compliance purposes.
• Marketing data (email, phone number with consent): Retained while consent remains active. Following withdrawal of consent, deleted within up to 30 days.
• Technical and security logs: Retained for up to 12 months for security and incident analysis purposes.

Once retention periods have expired, data is securely and irreversibly deleted or anonymized. Anonymization means the data can no longer identify you as an individual and therefore ceases to be personal data under the LGPD.

9. Your Rights as a Data Subject (LGPD)

Law No. 13,709/2018 grants you, as a personal data subject, a set of rights that p9game is committed to respecting and making easy to exercise. Learn about each one below:

To exercise any of these rights, simply send an email to suporte@p9game.best with the subject line "LGPD Request – [type of right]", including your full name and registered CPF. We will respond within 15 business days. For more complex cases, we may request identity verification before processing the request.

If you believe p9game has not adequately handled a request related to your rights, you may file a complaint directly with the National Data Protection Authority (ANPD) at gov.br/anpd.

10. Minors

P9game is a platform exclusively for users aged 18 and over. We do not intentionally collect personal data from minors. The registration process requires date-of-birth confirmation, and where there is any indication of underage use, age verification documents may be requested.

If we become aware that data from a user under 18 has been inadvertently collected, we immediately close the account, return any real-money balance deposits via Pix, and delete all associated personal data within 30 days.

If you are the guardian of a minor and believe they have created an account on p9game, please contact our support team immediately via live chat or at suporte@p9game.best. We will take the necessary steps as a top priority.

11. International Data Transfers

Some of the technology providers used by p9game — such as cloud server infrastructure providers and international game suppliers — may process data on servers located outside Brazil. In such cases, p9game ensures that international data transfers occur only to countries offering an adequate level of protection, or through the adoption of specific legal safeguard mechanisms, such as:

• Standard contractual data protection clauses compatible with the LGPD.
• Terms of use and privacy policies from providers that meet standards equivalent to those required by the Brazilian LGPD.
• Specific Data Processing Agreements (DPAs) with each international vendor.

P9game does not carry out international data transfers without adequate contractual safeguards. If you have any questions about specific transfers, you can request detailed information by email at suporte@p9game.best.

12. Changes to this Privacy Policy

P9game may update this Privacy Policy to reflect changes in data processing practices, updates to Brazilian legislation (including ANPD guidance), or improvements to the platform's services. Whenever material changes are made, you will be notified at least 7 days in advance via:

• Email sent to the address registered on the account.
• A prominent notice on the platform's home screen or in the p9game app.
• Updating the "last updated" date at the top of this document.

For minor changes — such as text corrections, contact updates, or clarifications that do not alter the substance of the practices described — only the update date will be revised. Continued use of the platform after a new version of this policy takes effect constitutes acceptance of those changes. If you do not agree, you have the right to close your account and request deletion of your data as outlined in section 9.

We recommend reviewing this policy periodically. The most up-to-date version is always available at p9game.best/privacy-policy.

13. Contact, DPO and Privacy Channel

For any questions related to privacy, data protection, or the exercise of rights under the LGPD, please reach out through p9game's privacy channel:

P9game has an internal designated officer responsible for personal data handling (equivalent to the DPO — Data Protection Officer set out in Article 41 of the LGPD). This professional oversees the platform's privacy practices, guides the team on legal obligations, and serves as the primary point of contact with the ANPD when required.

If your request involves third-party data or is urgent in nature (such as suspected unauthorized access to your account), please make that clear when you get in touch — these situations receive priority handling at p9game.