91piso Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 91piso ("91piso," "we," "us," "our") — the operator of the online gaming platform at https://91piso.vip — collects, uses, stores, shares, and protects the personal information of players, visitors, and other users ("you," "your") of the 91piso Platform.

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines. It should be read together with our Terms and Conditions, which govern your use of the 91piso Platform as a whole.

By accessing the 91piso Platform or creating an account, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree to this Policy, please do not use the 91piso Platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, 91piso is the personal information controller responsible for the personal data collected through the Platform. Our designated Data Protection Officer ("DPO") can be contacted at the details specified in Section 14 of this Policy.

91piso is registered as a personal information controller with the National Privacy Commission of the Philippines in accordance with NPC registration requirements applicable to personal information controllers processing sensitive personal information.

3. Data We Collect

3.1 Registration Data

When you create a 91piso account, we collect: full legal name, date of birth, gender, residential address in the Philippines, email address, Philippine mobile number, and username and password (password stored in irreversibly hashed form only).

3.2 Identity Verification (KYC) Data

To comply with PAGCOR licence conditions and AMLA obligations, we collect: government-issued Philippine ID number and type (PhilSys, passport, driver's licence, UMID, SSS, or GSIS), a photograph of the ID document, and a selfie or biometric comparison image. This constitutes sensitive personal information under the DPA and is processed with additional safeguards.

3.3 Financial Data

We collect transaction records including deposit amounts, withdrawal requests, GCash or Maya account reference numbers, bank account details where applicable, and transaction timestamps. Full GCash MPIN, full bank account passwords, and full card numbers are never collected or stored by 91piso.

3.4 Gaming Activity Data

We maintain records of games played, bet amounts, game outcomes, session durations, bonus usage, and wagering history. This data is required for regulatory compliance, dispute resolution, and responsible gaming monitoring.

3.5 Technical and Device Data

We automatically collect IP address, device type and operating system, browser type and version, referring URL, pages visited and time spent, and session identifiers. This data is used for security monitoring, fraud prevention, and platform optimisation.

3.6 Communications Data

If you contact 91piso support via live chat or email, we retain a record of that communication including content, timestamps, and any supporting files you provide, for quality assurance and dispute resolution purposes.

4. How We Use Your Data

91piso processes your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your 91piso account; authenticating your identity at login.
• Regulatory compliance: Fulfilling obligations under PAGCOR licence conditions, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012, including mandatory reporting to PAGCOR and AMLC where required.
• Payment processing: Facilitating deposits and withdrawals via GCash, Maya, and other supported Philippine payment channels.
• Game delivery and fairness: Operating casino games, sports betting, bingo, and sabong products; logging game outcomes for dispute resolution.
• Responsible gaming: Monitoring gaming patterns to identify potentially problematic play; enforcing self-exclusions and deposit limits; complying with PAGCOR responsible gaming requirements.
• Fraud prevention and security: Detecting and preventing unauthorised access, bonus abuse, money laundering, and other fraudulent or prohibited activity.
• Customer support: Responding to your queries, resolving disputes, and improving support quality.
• Platform improvement: Analysing aggregated and anonymised usage data to improve Platform performance and game selection.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates — only where you have provided explicit consent and subject to your right to withdraw consent at any time.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 91piso processes your personal data on the following legal bases:

• Contract performance: Processing necessary to fulfil the 91piso Terms and Conditions agreement, including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AMLA, NPC regulations, and other applicable Philippine law.
• Legitimate interests: Processing for fraud prevention, platform security, and aggregated analytics, where our legitimate interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications, where your separate, freely given, specific, informed, and unambiguous consent has been obtained.

For sensitive personal information (including KYC biometric data), processing is conducted on the basis of legal obligation under PAGCOR regulations and AMLA, and explicit consent obtained during the KYC process.

6. Data Sharing and Third Parties

91piso does not sell your personal data. We share your data only in the following limited circumstances:

• Payment processors: GCash (Mynt / Globe Fintech Innovations), Maya (PayMaya Philippines), and other Philippine payment partners receive the minimum data necessary to process your transactions. These processors are bound by contractual data protection obligations and their own privacy policies.
• KYC and identity verification providers: Third-party identity verification services process your government ID and biometric data for KYC compliance. These providers are ISO 27001 certified and contractually bound to process data only for the specified purpose.
• Game content providers: Software providers supplying games accessible through 91piso may receive anonymised session identifiers and game data necessary to deliver the game. They do not receive your personal identity information.
• Regulatory authorities: PAGCOR, AMLC, the National Privacy Commission, and other Philippine government bodies as required by law, regulation, or lawful order.
• Cloud and infrastructure providers: Hosting and technical infrastructure providers operating within or providing services to the Philippines, bound by data processing agreements.
• Professional advisers: Legal, compliance, and audit professionals under professional confidentiality obligations.

7. Cookies and Tracking Technologies

The 91piso Platform uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function — session management, authentication tokens, and security cookies. These cannot be disabled without preventing Platform use.
• Functional cookies: Remember your preferences such as language settings, last visited game category, and responsible gaming limits you have set.
• Analytics cookies: Aggregate, anonymised data on how players navigate and use the Platform, used to identify technical issues and improve user experience. No individual player is identified in analytics reports.
• Security cookies: Fraud detection and bot prevention tools that analyse session behaviour to protect the integrity of the Platform.

You may manage non-essential cookies through your browser settings. Blocking strictly necessary cookies will prevent you from accessing the Platform. 91piso does not use third-party advertising or retargeting cookies.

8. Data Retention

91piso retains your personal data for the following periods:

• Account and KYC data: Retained for the duration of your account plus five (5) years after account closure, as required by PAGCOR licence conditions and AMLA record-keeping requirements.
• Financial transaction records: Retained for five (5) years from the date of the transaction, in compliance with AMLA obligations.
• Gaming activity records: Retained for three (3) years, or longer if required for an ongoing regulatory investigation or player dispute.
• Support communications: Retained for two (2) years from the date of the communication.
• Technical and device logs: Retained for six (6) months on active storage; archived for up to two (2) years for security investigation purposes.
• Marketing consent records: Retained for the duration of the consent plus three (3) years.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised.

9. Data Security

91piso implements the following security measures to protect your personal data:

• TLS 1.3 encryption for all data in transit between your device and 91piso servers.
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records.
• Passwords stored using irreversible bcrypt hashing — no 91piso employee or system can read your password in plain text.
• Role-based access controls limiting employee access to personal data to those with a documented operational need.
• Multi-factor authentication for all 91piso staff accessing production systems containing player data.
• Regular penetration testing and vulnerability assessments conducted by independent security professionals.
• 24/7 security monitoring with automated anomaly detection and incident response procedures.

No data security system is completely impenetrable. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 91piso will notify affected players and the National Privacy Commission within 72 hours of becoming aware of the breach, as required by the DPA.

10. Your 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 91piso:

• Right to be informed: You have the right to know what personal data 91piso collects, processes, and retains about you, and the purposes for which it is processed — as set out in this Policy.
• Right of access: You may request a copy of the personal data 91piso holds about you. We will provide this within 15 business days of a verified request.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data. Many details can be updated directly in your account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to legal retention obligations that override this right (including AMLA and PAGCOR record-keeping requirements).
• Right to object: You may object to processing based on legitimate interests or for direct marketing purposes. Marketing communications can be unsubscribed at any time via the unsubscribe link in any 91piso email.
• Right to data portability: You may request your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to lodge a complaint: If you believe 91piso has processed your personal data in breach of the DPA, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, contact our Data Protection Officer at the details in Section 14. We may require proof of identity before processing requests to protect against unauthorised access to other players' data.

11. Children's Privacy

The 91piso Platform is strictly for persons aged 21 years and older. We do not knowingly collect personal data from persons under 21. If we discover that an account has been registered by a person under 21, the account will be immediately closed, KYC data deleted within 30 days of closure (subject to any regulatory hold obligations), and any deposits returned to the source payment method.

If you are a parent or guardian and believe your child has registered an account on 91piso, please contact our support team immediately so we can investigate and take appropriate action.

12. Cross-Border Data Transfers

Where personal data is transferred to service providers or infrastructure located outside the Philippines — for example, to internationally-hosted cloud infrastructure used to deliver the Platform — 91piso ensures that such transfers comply with Section 21 of the Data Privacy Act and NPC guidelines on cross-border data flows. Specifically:

• Transfers are conducted only to countries or recipients that provide an adequate level of data protection comparable to Philippine standards.
• Data processing agreements incorporating standard contractual clauses are in place with all non-Philippine recipients of personal data.
• KYC biometric data is processed only within NPC-approved jurisdictions.

13. Policy Updates

91piso may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or Platform functionality. Material changes will be notified to registered players by email to their registered address at least 14 days before the changes take effect.

We will update the "Last updated" date at the top of this Policy with each revision. Your continued use of the 91piso Platform after the effective date of any update constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

Previous versions of this Policy are available on request by contacting our Data Protection Officer.

14. Contact & Data Protection Officer

For any privacy-related queries, requests to exercise your data subject rights, or concerns about 91piso's handling of your personal data, please contact our Data Protection Officer:

Complaints that cannot be resolved with 91piso directly may be escalated to the National Privacy Commission of the Philippines through the NPC's official complaints portal.