ph91 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how ph91 ("ph91," "we," "us," "our") collects, uses, stores, discloses, and protects the personal data of individuals ("you," "your," "the Player," "the User") who access or use the ph91 platform, website located at https://ph91.asia, and all associated services, features, and communications.

ph91 is committed to protecting your privacy in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

By registering an account, using the ph91 platform, or otherwise providing personal data to ph91, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing, and use of your personal data as described herein. If you do not consent to this Policy, you must refrain from using the ph91 platform.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal data is ph91, the operator of the platform at https://ph91.asia.

All inquiries regarding the processing of your personal data, data subject rights requests, and privacy-related complaints should be directed to the ph91 Data Privacy Officer at: [email protected]

ph91 has designated a Data Privacy Officer (DPO) in accordance with the requirements of Republic Act 10173 and NPC regulations. The DPO is responsible for ensuring ph91's ongoing compliance with applicable data protection laws and for handling data subject requests in a timely manner.

3 Personal Data We Collect

ph91 collects personal data in several categories. The specific data collected depends on the nature of your interaction with the platform:

3.1 Registration and Identity Data

• Full legal name
• Date of birth
• Gender
• Philippine mobile number or email address
• Username and encrypted password
• Nationality and country of residence

3.2 KYC and Verification Data

• Government-issued identification documents (PhilSys ID, UMID, Driver's License, Passport, or PRC License)
• Proof of address documentation
• Selfie or liveness verification image (where required for identity confirmation)
• Source of funds documentation (where requested for AML compliance)

3.3 Financial Data

• Deposit and withdrawal transaction records
• GCash account reference (not your GCash PIN — we never receive or store your GCash credentials)
• Bank account details for bank transfer withdrawals
• Transaction timestamps, amounts, and processing statuses

3.4 Gaming Activity Data

• Game sessions, wagers placed, and game results
• Bonus usage and promotional participation history
• Account balance history
• Responsible gaming settings and self-imposed limits

3.5 Technical and Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser type
• Session duration and login timestamps
• Cookie identifiers and session tokens
• Network connection type (WiFi, mobile data, carrier)

3.6 Communications Data

• Customer support conversation records (chat, email)
• Feedback and survey responses
• Promotional communication preferences

4 How We Collect Your Data

ph91 collects personal data through the following means:

1. Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, respond to a survey, or participate in a promotion.
2. Automatically through platform use — when you browse the ph91 website or use the gaming platform, technical data is collected automatically through cookies, server logs, and session tracking technologies.
3. From payment providers — when you initiate a GCash, PayMaya, or bank transfer transaction, ph91 receives transaction reference data and confirmation of payment from your payment provider. ph91 does not receive your payment credentials.
4. From identity verification services — if ph91 uses a third-party identity verification provider to assist with KYC, that provider may share verification outcomes and document check results with ph91.
5. From fraud prevention and security services — ph91 may receive data from fraud detection services that monitor for suspicious activity patterns across the gaming industry.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act, ph91 processes your personal data on the following legal bases:

6 How We Use Your Personal Data

ph91 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, secure, and administer your ph91 account, including processing your login credentials, balance, and transaction history.
• Identity Verification: To verify your identity and age (21+) as required by applicable Philippine gaming regulations and anti-money laundering obligations.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods in Philippine Peso.
• Responsible Gaming: To administer deposit limits, session tracking, self-exclusion tools, and cooling-off mechanisms that protect player wellbeing.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, account takeover attempts, and other security threats to the platform and its players.
• Customer Support: To respond to your inquiries, resolve disputes, process complaints, and provide technical support related to your ph91 account.
• Legal Compliance: To fulfill ph91's obligations under the Philippine Data Privacy Act, anti-money laundering regulations, and other applicable Philippine laws.
• Platform Improvement: To analyze usage patterns, identify technical issues, and improve the performance, features, and user experience of the ph91 platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and gaming updates — only where you have consented to receive such communications.

ph91 does not use automated decision-making that produces legal or similarly significant effects on players without appropriate human review. Risk-based decisions, such as enhanced due diligence triggers, involve human oversight from the ph91 compliance team.

7 Data Sharing and Disclosure

ph91 does not sell, rent, or trade your personal data to third parties for commercial purposes. Personal data is shared only in the circumstances described below, and only to the extent necessary for the stated purpose:

7.1 Service Providers

ph91 engages third-party service providers to support platform operations, including payment processors (GCash operator, banks), identity verification providers, cloud hosting services, fraud detection platforms, and customer support tools. All service providers are bound by data processing agreements requiring them to protect your data and process it only on ph91's documented instructions.

7.2 Game Providers

To facilitate gaming sessions, ph91 shares a limited player identifier with game providers whose titles are hosted on the platform. This allows the game provider's system to recognize your session and record game outcomes. Game providers do not receive your full personal profile, payment details, or KYC documentation.

7.3 Legal and Regulatory Obligations

ph91 may disclose personal data to Philippine government authorities, regulatory bodies, law enforcement agencies, or courts where required to do so by applicable law, court order, or in connection with a legal investigation. ph91 will notify affected players of such disclosures where legally permitted to do so.

7.4 Business Transfers

In the event that ph91 undergoes a merger, acquisition, or sale of all or substantially all of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material change to this Privacy Policy that results from it.

8 Data Security

ph91 implements technical and organizational security measures appropriate to the sensitivity of the personal data we process. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and ph91 servers.
• Password hashing using industry-standard algorithms (bcrypt with appropriate work factors) — your password is never stored in plain text.
• Two-Factor Authentication (2FA) available to all players for additional login security.
• Segregated data environments — player funds and personal data are held in systems isolated from ph91's general operational infrastructure.
• Access controls — internal access to player data is restricted to authorized personnel on a need-to-know basis and is logged for audit purposes.
• Regular security assessments — ph91 conducts periodic technical security reviews of its platform infrastructure.
• Incident response procedures — in the event of a data breach that poses risk to player rights, ph91 will notify affected players and the NPC in accordance with applicable Philippine data breach notification requirements.

While ph91 takes data security seriously and applies industry-standard protections, no digital system can guarantee absolute security. You are also responsible for maintaining the security of your ph91 login credentials and for reporting any suspected unauthorized access to your account immediately.

9 Data Retention

ph91 retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention standards:

• Account and identity data: Retained for the lifetime of your account plus a minimum of five (5) years following account closure, to satisfy AML record-keeping obligations under Philippine law.
• KYC documentation: Retained for a minimum of five (5) years from the date of verification, in accordance with Philippine AML/CTF requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of the recorded activity.
• Customer support records: Retained for two (2) years from the resolution of the relevant support interaction, or longer if related to an open legal dispute.
• Technical logs: Typically retained for twelve (12) months, or longer where relevant to a security investigation.
• Marketing preferences: Retained until you withdraw consent or close your account.

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

10 Cookies and Tracking Technologies

ph91 uses cookies and similar tracking technologies to deliver and improve the platform experience. The categories of cookies used on ph91 are as follows:

ph91 does not use third-party advertising cookies or tracking pixels for the purpose of targeting you with advertisements on other websites. You may manage cookie preferences through your browser settings at any time, though disabling essential cookies will prevent you from logging into your ph91 account.

11 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph91:

To exercise any of the above rights, submit a written request to ph91's Data Privacy Officer at [email protected] with the subject line "Data Subject Rights Request." ph91 will acknowledge your request within five (5) business days and complete the response within the timeframe prescribed by applicable law (generally thirty (30) days for standard requests).

ph91 may require identity verification before processing a data subject request to ensure that data is disclosed only to the person it belongs to. ph91 reserves the right to refuse requests that are manifestly unfounded, excessive, or where fulfillment would conflict with ph91's legal obligations (such as AML record-keeping requirements).

If you believe your data rights have not been adequately addressed, you may lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

12 Children's Privacy and Age Restriction

The ph91 platform is strictly intended for adults aged 21 years and older in accordance with Philippine gaming regulations. ph91 does not knowingly collect personal data from persons under the age of 21.

Age verification is conducted as a mandatory step in the ph91 KYC process. Where ph91 becomes aware that personal data has been collected from a person under 21, that data will be promptly deleted and the associated account suspended.

If you are a parent or guardian and believe that a minor has registered on the ph91 platform using false age information, please contact ph91 immediately at [email protected] so that appropriate action can be taken.

13 Cross-Border Data Transfers

Some of ph91's third-party service providers — including cloud infrastructure providers and game software platforms — may process data in jurisdictions outside the Philippines. Where such transfers occur, ph91 ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply a standard of data protection equivalent to that required by Philippine law.
• Transfers only to jurisdictions or recipients that offer adequate data protection standards as recognized by the NPC.
• Data Processing Agreements that bind recipients to ph91's data protection requirements.

By using the ph91 platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside the Philippines under the safeguards described above, where necessary for the delivery of the service.

14 Amendments to This Privacy Policy

ph91 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or platform features. When material changes are made, ph91 will provide notice via one or more of the following: a notification displayed on the ph91 platform, an email to your registered address, or an SMS to your registered Philippine mobile number.

Your continued use of the ph91 platform following the effective date of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not accept the updated Policy, you must cease using the platform and may request account closure.

The current version of this Privacy Policy, including its effective date, is always available at https://ph91.asia/privacy-policy.

15 Contact and Privacy Complaints

For all privacy-related inquiries, data subject rights requests, or complaints regarding ph91's handling of your personal data, please contact the ph91 Data Privacy Officer:

Data Privacy Officer, ph91
Email: [email protected]
Subject line: Privacy Policy Inquiry / Data Subject Request

ph91 aims to acknowledge all privacy inquiries within five (5) business days. If you remain unsatisfied with ph91's response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.