Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 91pha ("we," "us," or "our"), the operator of the online gaming platform available at 91pha.cam, collects, uses, stores, shares, and protects the personal information of individuals ("you," "the Player," or "the User") who register an account, visit the Platform, or otherwise interact with our services.

91pha is committed to protecting your privacy and handling your personal data with transparency, integrity, and in accordance with applicable data protection laws, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

By accessing 91pha, registering an account, or using any feature of the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal information as described herein. If you do not agree with any provision of this Policy, you should discontinue your use of the Platform immediately.

This Policy should be read together with our Terms and Conditions, which are incorporated herein by reference.

2. Data Controller

For the purposes of applicable data privacy law, 91pha acts as the data controller in respect of personal information collected from players and visitors of the Platform. As data controller, 91pha is responsible for determining the purposes and means by which your personal data is processed.

For any privacy-related enquiries, including requests to exercise your data subject rights, please contact us using the details provided in Section 15 of this Policy. We have designated a responsible point of contact for privacy matters who is available through our standard customer support channels.

3. Data We Collect

91pha collects personal data necessary to operate the Platform, fulfil our legal obligations, and deliver the services you have requested. The categories of personal data we may collect include:

3.1 Registration and Identity Data

• Full legal name
• Date of birth (for age verification purposes)
• Residential address, including city and province (e.g., Metro Manila, Cebu, Davao)
• Email address
• Mobile number
• Username and account credentials (passwords are stored in hashed form only)

3.2 Verification and KYC Data

• Government-issued identification documents (e.g., Philippine passport, driver's license, UMID, SSS ID, PhilSys card)
• Proof of address documentation
• Selfie or live verification image where required
• Payment method verification documents

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash mobile number, PayMaya account reference, bank account details for BPI, BDO, or Metrobank transfers)
• Account balance history
• Bonus and promotional transaction records

3.4 Gaming and Activity Data

• Game session records, including game type, stake amounts, outcomes, and session duration
• Sports betting selections and wager history
• Responsible gaming tool settings and usage
• Bonus claims and wagering progress

3.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and login history
• Cookie data and Platform interaction logs

3.6 Communications Data

• Records of support interactions via live chat or email
• Feedback and survey responses
• Marketing communication preference settings

4. How We Collect Your Data

91pha collects personal data through the following means:

• Directly from you: Information you provide during registration, account verification, deposits, withdrawals, customer support interactions, and completion of surveys or promotions.
• Automatically: Technical data collected when you access the Platform, including IP address, device identifiers, browser type, and session activity logs generated during your use of 91pha.
• From third parties: Identity verification and KYC data obtained from licensed verification service providers; payment-related data received from payment processors; fraud and risk assessment data from authorised third-party risk management partners.
• Cookies and similar technologies: Data collected through cookies, web beacons, and similar tracking technologies as described in Section 8 of this Policy.

5. How We Use Your Data

91pha uses your personal data for the following purposes:

Purpose	Description
Account Management	Creating, verifying, and maintaining your 91pha player account and associated access credentials.
Service Delivery	Enabling access to casino games, live dealer tables, sports betting markets, and all other Platform features.
Payment Processing	Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels.
Identity Verification	Conducting KYC checks to verify your identity, age (21+), and eligibility to use the Platform in compliance with regulatory requirements.
Fraud Prevention	Detecting and preventing fraudulent activity, money laundering, account abuse, and other prohibited conduct.
Legal Compliance	Fulfilling obligations under applicable Philippine laws, including the Data Privacy Act, anti-money laundering regulations, and gaming regulatory requirements.
Customer Support	Responding to your enquiries, resolving account issues, and providing technical assistance via live chat and email.
Responsible Gaming	Monitoring gaming behaviour to identify potential problem gambling indicators and to administer responsible gaming tools including deposit limits and self-exclusion.
Marketing	Sending promotional communications about bonuses, new games, and platform updates, subject to your communication preferences and applicable opt-out rights.
Platform Improvement	Analysing usage patterns and technical data to improve platform performance, user experience, and game selection.

6. Legal Basis for Processing

91pha processes your personal data under one or more of the following lawful bases as applicable under the Data Privacy Act of 2012 and its Implementing Rules:

• Consent: Where you have given explicit consent to the processing of your personal data for a specific purpose (e.g., receipt of marketing communications).
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and 91pha — specifically, the delivery of the gaming services you have registered to access.
• Legal Obligation: Where processing is required to comply with applicable laws and regulations, including KYC obligations, anti-money laundering requirements, and gaming licensing conditions.
• Legitimate Interests: Where processing is necessary for 91pha's legitimate business interests, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your privacy rights and freedoms.

7. Data Sharing and Disclosure

91pha does not sell your personal data. We may share your personal information with the following categories of recipients where necessary and lawful:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Licensed KYC and identity verification service providers engaged to confirm your identity and eligibility.
• Game Providers: Third-party casino game suppliers and live dealer studio operators whose products are integrated into the 91pha platform. These providers may receive limited technical data necessary to deliver game services.
• Fraud and Risk Management Partners: Authorised service providers engaged to detect and prevent fraud, money laundering, and other prohibited activity.
• Regulatory and Law Enforcement Authorities: Government agencies, regulators, and law enforcement bodies where disclosure is required by applicable Philippine law or court order, including AMLC and relevant gaming oversight bodies.
• Professional Advisors: Legal counsel, accountants, and auditors engaged by 91pha on a confidential basis where necessary for the conduct of our business.

All third parties with whom 91pha shares personal data are required to handle that data in accordance with applicable privacy laws and, where applicable, data processing agreements that impose appropriate confidentiality and security obligations.

8. Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. 91pha uses cookies and similar technologies (including web beacons and local storage) to operate the Platform, remember your preferences, and monitor usage patterns for performance improvement purposes.

8.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function. These include session cookies that maintain your login state and security tokens. They cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, game lobby display options, and responsible gaming tool configurations.
• Analytics Cookies: Collect anonymised data about how visitors use the Platform — pages visited, session duration, navigation paths — to help us improve the user experience. 91pha uses first-party analytics tools for this purpose.
• Security Cookies: Assist in identifying and preventing fraudulent access attempts, unusual login patterns, and other security threats.

8.3 Managing Cookies

You may control cookie settings through your browser's privacy or settings menu. Disabling essential cookies will impair your ability to log in and use the Platform. Disabling functional or analytics cookies may affect the quality of your experience but will not prevent access to core services.

9. Data Retention

91pha retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law, whichever is longer. Specifically:

• Active Accounts: Personal data associated with an active player account is retained for the duration of the account relationship and a period thereafter as required by anti-money laundering regulations and gaming licensing obligations.
• Closed Accounts: Following account closure, 91pha retains personal data for a minimum of five (5) years or such longer period as may be required under Philippine law, including tax, AML, and gaming regulatory record-keeping obligations.
• KYC Documents: Identity and verification documents are retained for a minimum of five (5) years following the end of the player relationship.
• Support Communications: Records of customer support interactions are retained for a minimum of two (2) years.
• Marketing Data: Where consent-based processing applies, data is retained until consent is withdrawn or until the purpose is fulfilled, after which it is securely deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

10. Data Security

91pha implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 91pha servers.
• Hashed and salted storage of account passwords — plaintext passwords are never stored.
• Access controls limiting personal data access to authorised personnel with a legitimate need to process it.
• Regular security assessments and vulnerability testing of the Platform infrastructure.
• Firewall protection, intrusion detection systems, and continuous monitoring of server environments.
• Staff training on data handling obligations and privacy best practices.

While 91pha takes all reasonable precautions, no data transmission over the internet can be guaranteed as completely secure. You accept the inherent risks of transmitting data online and acknowledge that 91pha cannot guarantee absolute security of information in transit.

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

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you hold the following rights in relation to your personal data held by 91pha:

• Right to be Informed: The right to know what personal data 91pha holds about you, the purposes for which it is processed, and with whom it is shared.
• Right of Access: The right to obtain a copy of the personal data we hold about you in a portable format.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held on your account.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to overriding legal retention obligations.
• Right to Object: The right to object to processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• 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 processing conducted prior to withdrawal.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe 91pha has not handled your personal data in accordance with applicable law.

To exercise any of the above rights, please contact the 91pha support team via live chat or at [email protected]. We will respond to verified requests within 30 calendar days. We may require verification of your identity before processing any data subject request.

12. Children and Minors

91pha's platform and services are strictly intended for individuals aged 21 years and above in accordance with applicable Philippine gaming regulations. We do not knowingly collect personal data from individuals below this age.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you have reason to believe a minor has registered an account on 91pha, please contact our support team immediately via live chat or at [email protected].

As part of our Know Your Customer process, 91pha verifies the age of all registered players. Players who cannot demonstrate they meet the minimum age requirement will have their accounts closed and any deposited funds returned to the verified source.

13. International Data Transfers

In the course of operating the Platform, your personal data may be transferred to and processed in countries outside the Philippines — for example, where third-party game providers or technical infrastructure providers are located. When such transfers occur, 91pha ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law.

These safeguards may include contractual protections such as data processing agreements incorporating appropriate data transfer clauses, or transfers to jurisdictions that provide an adequate level of data protection as recognised by the National Privacy Commission.

14. Updates 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 Platform features. When material changes are made, we will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date displayed at the top of this page indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how 91pha handles your personal information.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any change to this Policy, you should discontinue use of the Platform and contact us to close your account.

15. Contact Us

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

• Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week directly on the 91pha Platform

Please include your registered username, a clear description of your enquiry or request, and — for data subject rights requests — sufficient information to verify your identity. We will acknowledge receipt of your query within 48 hours and provide a substantive response within 30 calendar days for formal data subject rights requests.