Privacy Policy

1. Introduction

91pha ("we," "us," "our") operates the online casino and sports betting platform accessible at 91pha.net. We are committed to protecting the privacy and personal data of all users of the 91pha Platform ("you," "your," "Player"). This Privacy Policy describes how 91pha collects, uses, stores, shares, and protects personal information in connection with your use of the Platform and all associated services.

This Privacy Policy is incorporated into and forms part of the 91pha Terms & Conditions. By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, you must not use the Platform.

91pha's data practices are governed by the Republic Act No. 10173, also known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

2. Personal Data We Collect

91pha collects personal data in the following categories:

• Registration Data: Full legal name, date of birth, Philippine mobile number, email address, and username provided when you create a 91pha account.
• Identity Verification (KYC) Data: Government-issued identification documents (e.g., Philippine passport, SSS ID, driver's licence, PhilSys national ID), selfie photographs, and proof of address, collected to comply with anti-money laundering (AML) and know-your-customer (KYC) obligations.
• Financial Data: GCash account details, PayMaya account details, bank account numbers (BPI, BDO, Metrobank), and transaction history related to deposits and withdrawals on the Platform.
• Gameplay Data: Game history, wager amounts, win/loss records, session durations, and responsible gaming tool usage.
• Device and Technical Data: IP address, device type, operating system, browser type, and unique device identifiers collected automatically when you access the Platform.
• Communications Data: Records of your interactions with 91pha customer support, including live chat transcripts and email correspondence.
• Marketing Preferences: Your opt-in or opt-out status for promotional communications via SMS, email, and push notifications.

3. How We Use Your Personal Data

91pha uses the personal data we collect for the following purposes:

• To create and manage your 91pha player account;
• To process deposits, withdrawals, and other financial transactions;
• To verify your identity and age (21+) in compliance with Philippine gaming regulations and AML obligations;
• To provide customer support and respond to your enquiries;
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited conduct;
• To personalise your experience on the Platform, including game recommendations and promotional offers;
• To send you transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts);
• To send you marketing communications where you have opted in to receive them;
• To comply with applicable Philippine laws, regulations, and regulatory obligations;
• To analyse Platform usage and improve our services, games, and user experience.

4. Legal Basis for Processing

91pha processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract between you and 91pha, including account management, payment processing, and game provision;
• Legal Obligation: Processing required to comply with applicable Philippine laws, including AML regulations, KYC requirements, and gaming regulatory obligations;
• Legitimate Interests: Processing necessary for 91pha's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent, including for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing and Disclosure

91pha does not sell, rent, or trade your personal data to third-party marketers. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay, to process your financial transactions;
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged to assist with identity verification;
• Game Providers: Third-party game software providers who supply games available on the Platform, to the extent necessary for game operation and fairness auditing;
• Regulatory Authorities: Philippine government agencies, including the National Privacy Commission, PAGCOR, and the Anti-Money Laundering Council (AMLC), where disclosure is required by law or regulatory obligation;
• IT and Security Service Providers: Cloud hosting, cybersecurity, and technical infrastructure providers engaged to operate and secure the Platform;
• Professional Advisers: Legal, accounting, and auditing firms engaged by 91pha, subject to professional confidentiality obligations.

All third-party service providers engaged by 91pha are contractually required to process personal data only in accordance with 91pha's instructions and applicable Philippine data protection law.

6. Cookies and Tracking Technologies

91pha uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you access the Platform. We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function, including session management and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming limits.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform to help us improve performance and user experience.
• Marketing Cookies: Used to deliver relevant promotional content where you have consented to receive marketing communications.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Platform.

7. Data Retention

91pha retains your personal data for as long as your account is active and for a period thereafter as required by applicable Philippine law and regulatory obligations. Specifically:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• KYC documentation is retained for the period required by applicable Philippine gaming and AML regulations;
• Customer support communications are retained for a minimum of two (2) years;
• Marketing preference records are retained until you withdraw consent or close your account.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 91pha's data disposal procedures.

8. Data Security

91pha implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption on all data transmissions between your device and the Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting access to personal data to authorised personnel only;
• Regular security audits, penetration testing, and vulnerability assessments;
• Two-factor authentication (2FA) available for player accounts;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 91pha will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

9. Your Data Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 91pha:

• Right to be Informed: The right to be informed of how your personal data is collected and processed, as set out in this Privacy Policy;
• Right of Access: The right to request a copy of the personal data 91pha holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to applicable legal retention requirements;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated .

To exercise any of these rights, please contact the 91pha Data Privacy Officer via live chat or by email at [email protected]. We will respond to all verified requests within fifteen (15) business days in accordance with the Data Privacy Act of 2012.

10. Children's Privacy

The 91pha Platform is strictly intended for persons aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from an underage individual, we will immediately close the relevant account, forfeit any associated balances, and securely delete the personal data in question. If you believe that an underage person has registered on the Platform, please notify us immediately at [email protected].

11. Changes to This Privacy Policy

91pha reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Where material changes are made, we will notify registered players via email or in-platform notification prior to the changes taking effect. The date of the most recent revision is indicated at the top of this page. Continued use of the Platform following notification of changes constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 91pha protects your personal data.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or 91pha's data practices, please contact our Data Privacy Officer through any of the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 through the Platform

Our support team is available around the clock and is fluent in both English and Filipino. We are committed to resolving all privacy-related concerns promptly and transparently.