91piso Privacy Policy

1.1 Purpose of This Policy. This Privacy Policy describes how 91piso collects, uses, stores, discloses, and protects personal data in connection with your use of the 91piso online casino platform and all associated services. It is designed to give you a clear and honest account of our data practices so you can make informed decisions about using the platform.

1.2 Applicable Law. 91piso operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA"), its Implementing Rules and Regulations, and the circulars and advisory opinions issued by the National Privacy Commission of the Philippines (NPC). Where international data flows are involved, applicable international standards are observed.

1.3 Relationship to Terms & Conditions. This Privacy Policy forms part of the 91piso Terms & Conditions and is incorporated therein by reference. Defined terms used in this Privacy Policy carry the same meaning as in the Terms & Conditions unless otherwise stated.

2.1 Who Controls Your Data. The data controller responsible for your personal data processed in connection with the 91piso platform is the 91piso operating entity ("91piso," "we," "us," or "our"). The Data Protection Officer (DPO) appointed by 91piso can be reached at the contact details specified in Section 14 of this Policy.

2.2 Data Protection Officer. In accordance with Section 21 of the DPA and its Implementing Rules, 91piso has designated a Data Protection Officer who is responsible for overseeing the platform's compliance with data protection law, handling data subject requests, and acting as the primary point of contact for the National Privacy Commission.

3.1 Categories of Data. 91piso collects personal data across the following categories, depending on how you interact with the platform:

3.2 Special Categories. 91piso does not intentionally collect sensitive personal information as defined under Section 3(l) of the DPA (e.g., health data, religious beliefs, political affiliations) unless expressly required by law or necessary for the provision of responsible gaming support services, in which case explicit consent will be obtained.

3.3 Voluntary Provision. Where personal data is provided voluntarily (such as in support interactions), you are not obligated to provide it. However, failure to provide certain mandatory information — such as identity documents for KYC — will prevent 91piso from fulfilling its legal obligations and may result in restrictions on your account's withdrawal capability.

4.1 Primary Purposes. 91piso processes your personal data for the following primary purposes:

• Account Management: Creating, maintaining, and administering your 91piso player account, including authentication and session management;
• Identity Verification (KYC): Complying with PAGCOR and Anti-Money Laundering Council (AMLC) requirements to verify the identity of players and prevent financial crime;
• Transaction Processing: Processing deposits, withdrawals, and bonus credits through GCash, PayMaya, and bank transfer integrations;
• Gaming Services: Providing access to the game catalogue, recording gaming activity, and ensuring fair play through RNG certification compliance;
• Customer Support: Responding to inquiries, resolving disputes, and providing account assistance through our 24/7 Filipino-speaking support team;
• Fraud Prevention & Security: Detecting and preventing unauthorized access, fraud, money laundering, bonus abuse, and other prohibited conduct;
• Regulatory Compliance: Fulfilling reporting obligations to PAGCOR, the AMLC, the NPC, and other relevant Philippine regulatory authorities;
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behavior and administering self-exclusion and limit programs.

4.2 Secondary Purposes (With Consent). With your separate, explicit consent, 91piso may also process your personal data for the following secondary purposes: sending promotional offers, bonus notifications, and marketing communications via email or SMS; conducting player satisfaction surveys; and personalizing your game lobby based on your activity history. You may withdraw consent for secondary purposes at any time by contacting support or updating your communication preferences in account settings.

5.1 Criteria for Lawful Processing. Under Section 12 of the DPA, 91piso processes personal data only where at least one of the following lawful bases applies:

• Contractual Necessity: Processing necessary to perform the contract between you and 91piso — i.e., providing the gaming platform, processing payments, and managing your account;
• Legal Obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulatory requirements, AMLC reporting obligations, and NPC directives;
• Legitimate Interests: Processing necessary for the legitimate interests of 91piso, including fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your fundamental rights;
• Consent: Processing for marketing communications and non-essential personalization, where you have provided freely given, specific, informed, and unambiguous consent.

6.1 No Sale of Personal Data. 91piso does not, under any circumstances, sell, rent, or trade your personal data to third parties for commercial marketing purposes. This commitment is absolute and unconditional.

6.2 Authorized Third-Party Processors. 91piso shares personal data with the following categories of third-party processors only to the extent strictly necessary for the stated purpose, and only under appropriate data processing agreements:

• Payment Service Providers: GCash (G-Xchange Inc.), PayMaya (Maya Philippines Inc.), BDO Unibank, Bank of the Philippine Islands, Metrobank — for processing deposits and withdrawals;
• Game Technology Providers: JILI Technology, Pragmatic Play, PG Soft, Evolution Gaming — these providers receive only the minimum session and game data required to deliver their gaming services;
• Identity Verification Services: Third-party KYC service providers engaged to assist with document verification and identity screening;
• Cloud Infrastructure Providers: Hosting and database service providers operating under strict data processing agreements with appropriate security certifications;
• Fraud Prevention Services: Specialist fraud detection and anti-money laundering technology providers;
• Customer Support Systems: Third-party helpdesk and live chat platform providers used by our support team.

6.3 Regulatory Disclosures. 91piso will disclose personal data to PAGCOR, the AMLC, the NPC, law enforcement agencies, and other Philippine government authorities where required by law, a court order, or valid regulatory directive. Where permissible by law, 91piso will endeavor to notify you of such disclosures in advance.

7.1 What Are Cookies. Cookies are small text files placed on your device by the 91piso platform when you visit the site. They allow the platform to recognize your device on subsequent visits, maintain your session state, and collect usage analytics data.

7.2 Types of Cookies Used. 91piso uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the operation of the platform. These include session authentication tokens, CSRF protection cookies, and load-balancing cookies. These cannot be disabled without impairing platform functionality;
• Performance & Analytics Cookies: Used to collect aggregated, anonymized data about how players use the platform, which pages are visited most frequently, and where errors occur. This information is used solely to improve platform performance;
• Functionality Cookies: Remember your preferences such as language settings, game lobby layout, and notification preferences;
• Security Cookies: Used for fraud detection, device fingerprinting, and identifying unusual login patterns to protect your account.

7.3 Managing Cookies. You can manage or delete cookies through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in to your 91piso account. For other cookie categories, disabling them may reduce platform functionality but will not prevent basic access to the site.

8.1 Retention Principles. 91piso retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with applicable legal and regulatory retention obligations, and to resolve disputes or enforce agreements. When data is no longer required, it is securely deleted or anonymized.

8.2 Retention Periods. The following indicative retention periods apply:

• Account and Identity Data: Retained for the duration of your account's active status, plus five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and AMLC obligations;
• Financial Transaction Records: Retained for five (5) years from the date of each transaction, as required by BSP and AMLC regulations;
• Gaming Activity Data: Retained for three (3) years from the date of each recorded session;
• KYC Documents: Retained for five (5) years from account closure or the date of last transaction, whichever is later;
• Support Communications: Retained for two (2) years from the date of the final communication in each support case;
• Technical/Log Data: Retained for twelve (12) months from the date of collection, unless extended for active fraud investigation purposes.

9.1 Technical Safeguards. 91piso implements the following technical security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

• Transport Layer Security (TLS 1.3) with 256-bit AES encryption on all data transmissions between your device and the 91piso platform;
• Encrypted storage of all sensitive data fields, including identity documents, at rest using AES-256 encryption;
• Password hashing using industry-standard bcrypt algorithms — plain-text passwords are never stored or accessible to any 91piso personnel;
• Multi-factor authentication available and recommended for all player accounts;
• Automated intrusion detection and prevention systems monitoring for unusual access patterns;
• Regular penetration testing conducted by independent security professionals;
• Strict role-based access controls ensuring that only personnel with a legitimate operational need can access specific data categories.

9.2 Organizational Safeguards. In addition to technical measures, 91piso maintains organizational safeguards including mandatory data protection training for all staff, documented data processing procedures, a formal data breach response plan, and regular internal privacy audits.

9.3 Data Breach Notification. In the event of a personal data breach that is likely to result in harm to affected individuals, 91piso will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects as required by the DPA and NPC regulations.

10.1 Rights Under the DPA. As a data subject under Philippine law, you have the following rights in relation to your personal data held by 91piso:

• Right to Be Informed (Section 16(a), DPA): The right to be informed of the collection, processing, and retention of your personal data — fulfilled by this Privacy Policy;
• Right of Access (Section 16(b), DPA): The right to request a copy of the personal data 91piso holds about you, along with information about how it is processed;
• Right to Rectification (Section 16(c), DPA): The right to request correction of any inaccurate, outdated, or incomplete personal data held by 91piso;
• Right to Erasure (Section 16(d), DPA): The right to request deletion of your personal data where there is no longer a lawful basis for retention, subject to 91piso's legal and regulatory retention obligations;
• Right to Data Portability (Section 18, DPA): The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Object (Section 16(f), DPA): The right to object to the processing of your personal data for direct marketing purposes, or where processing is based on legitimate interests;
• Right to Complain: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

10.2 How to Exercise Your Rights. To exercise any of the rights listed above, please submit a written request to the 91piso Data Protection Officer. Contact details are provided in Section 14. 91piso will respond to all verified data subject requests within fifteen (15) calendar days. Identity verification will be required before processing access or erasure requests to protect against unauthorized disclosure.

11.1 Strict 21+ Policy. The 91piso platform is strictly for individuals who are at least twenty-one (21) years of age, in compliance with PAGCOR regulations governing online gaming in the Philippines. 91piso does not knowingly collect, process, or retain personal data relating to individuals under the age of 21.

11.2 Discovery of Minor's Data. If 91piso discovers that personal data belonging to a person under the age of 21 has been collected — whether through fraudulent misrepresentation during registration or otherwise — the associated account will be immediately suspended, all funds will be returned to the originating payment method after verification, and all personal data related to the minor will be deleted from 91piso's systems within thirty (30) days, subject to any mandatory reporting obligations.

11.3 Reporting. If you have reason to believe that a person under the age of 21 has registered on the 91piso platform, please report this immediately to the 91piso support team or Data Protection Officer so that appropriate action can be taken without delay.

12.1 Cross-Border Processing. Some of 91piso's third-party service providers — including game technology providers and cloud infrastructure partners — may process personal data outside the Philippines. When this occurs, 91piso ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Philippine DPA.

12.2 Safeguards for Transfers. Safeguards applied to international data transfers include: contractual data processing agreements incorporating standard data protection clauses; transfer impact assessments evaluating the data protection standards of the receiving country; and, where applicable, adequacy determinations or equivalent certification mechanisms recognized by the NPC.

12.3 Right to Information. You may request details of any international data transfers affecting your personal data, including the identity of the recipient, the country of destination, and the safeguards in place, by contacting the Data Protection Officer.

13.1 Right to Update. 91piso reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in applicable law, NPC guidance, platform functionality, or data processing practices. The "Effective Date" and "Version" displayed at the top of this page will be updated whenever material changes are made.

13.2 Notification of Material Changes. Where changes to this Privacy Policy are material — meaning they significantly affect your rights or how your data is processed — 91piso will notify registered players via the email address on record at least fourteen (14) days before the changes take effect, except where more rapid implementation is required by law or for security reasons.

13.3 Continued Use. Your continued use of the 91piso platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree to material changes, you should cease using the platform and may request account closure and data deletion in accordance with Section 10.

13.4 Previous Versions. Previous versions of this Privacy Policy are archived and available upon request from the Data Protection Officer, together with a summary of the key changes made in each revision.

14.1 General Privacy Inquiries. For any questions about this Privacy Policy, how 91piso processes your personal data, or to exercise any of the rights described in Section 10, please contact the 91piso privacy team. Our 24/7 Filipino-speaking support team can also assist with general account data inquiries.

14.2 Data Protection Officer. Formal data subject requests, NPC complaint notifications, and sensitive privacy matters should be directed specifically to the Data Protection Officer:

14.3 National Privacy Commission. If you are not satisfied with how 91piso has handled a privacy concern, you have the right to submit a formal complaint to the National Privacy Commission of the Philippines. The NPC's contact and complaint submission details are available through official Philippine government channels.