ph91 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how ph91 ("ph91," "we," "us," "our"), operator of the online gaming platform at ph91.vip, collects, uses, stores, discloses, and protects the personal data of registered players, website visitors, and prospective users ("you," "Player," "Data Subject") in connection with the ph91 Platform and related services.

ph91 is committed to protecting the privacy and personal data of all Filipino players in accordance with the Republic Act 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations, the National Privacy Commission (NPC) issuances, applicable Bangko Sentral ng Pilipinas (BSP) regulations, and PAGCOR's data protection requirements applicable to online gaming operators.

By registering an account or using the ph91 Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy is incorporated by reference into ph91's Terms and Conditions. If you do not agree with this Policy, please do not register or continue to use the Platform.

2. Data Controller

ph91 acts as the personal information controller (PIC) with respect to the personal data it collects and processes in connection with the Platform. ph91 is registered with and regulated by PAGCOR and has designated a Data Protection Officer (DPO) responsible for ensuring compliance with the Data Privacy Act and this Policy.

For any data privacy matters, including the exercise of Data Subject rights, Players may contact the ph91 Data Protection Officer via the customer support channels described in Section 15 of this Policy.

3. Data We Collect

ph91 collects the following categories of personal data, as applicable to the nature of the interaction:

4. How We Collect Data

ph91 collects personal data through the following means:

4.1 Direct Collection

Data you provide directly during account registration, KYC document submission, deposit and withdrawal requests, bonus claim forms, and communications with customer support.

4.2 Automated Collection

Data collected automatically through your use of the Platform, including IP address, device and browser information, session logs, and gameplay data collected through ph91's server logs and analytics systems. Cookies and similar tracking technologies are used as described in Section 10.

4.3 Third-Party Sources

Data received from third parties in limited circumstances, including:

• Payment processors (GCash, Maya, BPI, BDO) to confirm transaction status and verify payment method ownership;
• Identity verification service providers engaged to assist with KYC compliance;
• PAGCOR and government databases, where ph91 is authorized to conduct exclusion list checks;
• Fraud prevention and AML screening services used to comply with Bangko Sentral ng Pilipinas requirements.

5. Purpose of Processing

ph91 processes personal data for the following specific, legitimate purposes:

• Account management: Creating, maintaining, and administering Player accounts on the Platform;
• Identity verification: Conducting KYC checks to verify Player identity and age (21+) as required by PAGCOR;
• Payment processing: Processing deposits and withdrawals in Philippine Peso via GCash, Maya, BPI, BDO, and other supported payment methods;
• Legal compliance: Complying with PAGCOR regulatory requirements, BSP Anti-Money Laundering obligations under RA 9160 (as amended), tax reporting obligations to the Bureau of Internal Revenue (BIR), and other applicable Philippine laws;
• Fraud prevention and security: Detecting, investigating, and preventing fraud, account abuse, collusion, money laundering, and other prohibited activities;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling indicators and administering self-exclusion and deposit limit tools;
• Customer support: Responding to Player enquiries, resolving complaints, and providing technical assistance;
• Platform improvement: Analyzing aggregated, anonymized usage data to improve Platform performance, game selection, and user experience;
• Marketing communications: Sending promotional offers and bonus notifications to Players who have opted in to marketing communications (Players may opt out at any time via account settings).

6. Legal Basis for Processing

ph91 processes personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between ph91 and the Player (account management, payment processing, game delivery);
• Legal obligation: Processing required to comply with PAGCOR regulations, BSP AML obligations, BIR tax reporting, and other mandatory Philippine regulatory requirements;
• Consent: Where processing is based on the Player's freely given, specific, and informed consent (e.g., marketing communications);
• Legitimate interests: Processing necessary for ph91's legitimate interests in fraud prevention, platform security, and responsible gaming compliance, where such interests are not overridden by the Player's fundamental rights.

7. Data Sharing & Disclosure

ph91 does not sell, rent, or trade your personal data to third parties for commercial purposes. Personal data may be disclosed to the following categories of recipients under appropriate data sharing agreements:

7.1 Service Providers (Personal Information Processors)

Third-party vendors engaged by ph91 to provide specific services, including payment processors (GCash/Maya/BPI/BDO), identity verification providers, cloud hosting providers, game software providers (JILI, PG Soft, etc.), and customer support platforms. These processors are contractually bound to handle data only on ph91's documented instructions and in compliance with RA 10173.

7.2 Regulatory and Government Authorities

ph91 may disclose personal data to PAGCOR, the BSP Financial Intelligence Unit, the Bureau of Internal Revenue, the National Privacy Commission, and other Philippine government authorities where required by law, court order, or regulatory directive.

7.3 Corporate Transactions

In the event of a merger, acquisition, or sale of ph91's business assets, personal data may be transferred to the acquiring entity, subject to the same data protection standards described in this Policy. Affected Players will be notified prior to any such transfer.

8. Data Retention

ph91 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC records: Retained for a minimum of five (5) years from account closure, as required by BSP AML regulations;
• Transaction records: Retained for five (5) years from the transaction date for tax and regulatory audit purposes;
• Gaming session logs: Retained for three (3) years from session date, as required by PAGCOR;
• Customer support records: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained until consent is withdrawn or for two (2) years of inactivity, whichever occurs first.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with ph91's data disposal procedures.

9. Data Security

ph91 implements organizational, technical, and physical security measures appropriate to the nature of the personal data processed and the risks involved, including:

• 256-bit SSL/TLS encryption for all data transmitted between users and ph91 servers;
• Encryption at rest for sensitive data including KYC documents and financial records;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Multi-factor authentication for ph91 staff accessing internal systems containing personal data;
• Regular security vulnerability assessments and penetration testing of the Platform;
• 24/7 monitoring of server infrastructure for unauthorized access attempts;
• Formal data breach response protocol with a 72-hour NPC notification obligation.

While ph91 implements reasonable security measures, no online platform can guarantee absolute security. Players are responsible for maintaining the confidentiality of their account credentials and should contact ph91 support immediately upon detecting any unauthorized account activity.

10. Cookies & Tracking Technologies

ph91 uses cookies and similar technologies to operate the Platform, enhance user experience, and support security and compliance functions. The types of cookies used include:

• Strictly necessary cookies: Required for Platform functionality including session management, login authentication, and security. These cannot be disabled without impairing Platform use.
• Analytics cookies: Used to collect aggregated, anonymized data on Platform usage patterns to improve performance and game selection. No personal information is transmitted to third-party analytics providers.
• Preference cookies: Store your language, display, and notification preferences so they are retained across sessions.

Players may manage cookie preferences through their browser settings. Note that disabling strictly necessary cookies may prevent access to certain Platform features. ph91 does not use third-party advertising or tracking cookies.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, ph91 Players have the following rights with respect to their personal data:

• Right to be Informed: To be notified of how your personal data is collected and processed, as described in this Policy;
• Right to Access: To obtain confirmation of whether ph91 processes your personal data and, if so, to receive a copy of the data held;
• Right to Rectification: To request correction of inaccurate or incomplete personal data held by ph91;
• Right to Erasure: To request deletion of your personal data where it is no longer necessary for the purposes collected, subject to ph91's legal retention obligations;
• Right to Object: To object to the processing of your personal data for direct marketing purposes at any time;
• Right to Data Portability: To receive your personal data in a structured, machine-readable format;
• Right to Damages: To claim compensation for damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data.

To exercise any of the above rights, contact ph91's Data Protection Officer via customer support. ph91 will respond to verified Data Subject requests within fifteen (15) business days. Some requests may require identity verification before processing.

12. Minors

The ph91 Platform is strictly restricted to persons who are 21 years of age or older as required by PAGCOR regulations. ph91 does not knowingly collect personal data from persons under 21. If ph91 discovers that personal data has been collected from a minor, the account will be immediately closed, all data will be deleted, and any funds deposited will be returned to the source payment method after completing appropriate regulatory reporting.

Parents or guardians who believe that their minor child has registered on the ph91 Platform should contact customer support immediately with supporting documentation.

13. Cross-Border Data Transfers

In limited circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international game software platforms. Such transfers are made only where:

• The recipient country provides adequate data protection standards as assessed by the National Privacy Commission;
• Appropriate contractual safeguards (e.g., Data Processing Agreements incorporating NPC-approved standard contractual clauses) are in place; or
• The transfer is necessary for the performance of the contract between ph91 and the Player.

ph91 will not transfer personal data internationally in a manner that undermines the protections afforded to Filipino players under the Data Privacy Act of 2012.

14. Changes to This Policy

ph91 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or Platform features. When material changes are made — particularly changes that affect the categories of data collected, purposes of processing, or Data Subject rights — ph91 will notify registered Players via:

• A notice prominently displayed on the Platform login page;
• An SMS notification to the mobile number registered on the Player's account; and/or
• An in-account notification visible upon the Player's next login.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Players are encouraged to review this Policy periodically. Continued use of the Platform following notification of changes constitutes acceptance of the revised Policy.

15. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or ph91's data processing practices, please contact the ph91 Data Protection Officer through any of the following channels:

If you believe that ph91 has violated your data privacy rights under the Data Privacy Act of 2012, you may also file a complaint with the National Privacy Commission (NPC) of the Philippines, the government authority responsible for enforcing RA 10173 and protecting the data privacy rights of Filipino citizens.