This Privacy Policy applies to all services provided by 91pha through its platform at 91pha.app. It covers how we handle the personal information of everyone who visits, registers, or plays on the 91pha platform — including players, prospective registrants, and individuals who contact our support team.
91pha operates in the Philippines and complies with Republic Act No. 10173, known as the Data Privacy Act of 2012, and its implementing rules and regulations. We are committed to protecting your privacy and handling your data with care, integrity, and full transparency.
By registering an account or continuing to use the 91pha platform, you acknowledge that you have read and understood this Privacy Policy. If you disagree with any part of it, please stop using the platform and contact us at support@91pha.app to discuss your options.
91pha collects personal data in several ways — directly from you when you register or interact with the platform, automatically as you use our services, and occasionally from third parties as part of identity verification and fraud prevention processes.
The categories of personal data we collect include:
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, government ID number | Registration & KYC verification |
| Contact Data | Email address, mobile number, residential address | Registration & account updates |
| Financial Data | GCash/Maya account reference, bank account name, card type (not full card number) | Deposits & withdrawals |
| Transaction Data | Deposit/withdrawal amounts, dates, game history, bet records | During platform use |
| Technical Data | IP address, device type, browser, operating system, session times | Automatic — on every visit |
| Verification Data | Copies of government-issued ID, selfie photos for liveness checks | KYC process |
| Communications Data | Support chat transcripts, email correspondence, feedback | When you contact support |
91pha does not collect special categories of sensitive personal data (e.g. health data, biometric data beyond liveness verification, or data about religious beliefs) except as strictly required by law or regulatory obligation.
91pha uses your personal data only for legitimate, clearly defined purposes. We do not use your data for purposes that are incompatible with why it was originally collected. Here is how we use the information we hold:
- Account creation and management: To register your account, verify your identity and age, and maintain your player profile on the 91pha platform.
- Processing transactions: To handle deposits, withdrawals, and the crediting/debiting of your account balance in connection with gameplay and promotions.
- Platform provision and improvement: To deliver the games, sports betting markets, and other features of the 91pha platform. To analyse usage patterns and improve how the platform works and looks.
- Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, prohibited conduct, money laundering, and other illegal activities. 91pha is legally obligated to perform these checks under Philippine AML regulations.
- Regulatory compliance: To comply with our licensing conditions, Philippine law, court orders, and requests from regulatory authorities.
- Customer support: To respond to your queries, resolve disputes, and improve the quality of our support service based on previous interactions.
- Responsible gaming: To monitor gameplay patterns that may indicate problem gambling, and to enforce self-exclusion or deposit limits set by you.
- Marketing communications: To send you information about 91pha promotions, bonuses, and new features — but only if you have opted in to receive such communications. You can opt out at any time.
91pha does not use automated decision-making in ways that produce legal or similarly significant effects for players without human oversight.
Under the Philippine Data Privacy Act (RA 10173), 91pha processes your personal data on one or more of the following lawful bases:
- Contractual necessity: Processing your data is required to fulfil our contract with you — delivering the 91pha platform, processing your bets, and handling your account.
- Legal obligation: Certain processing is required by Philippine law, including AML obligations, age verification requirements, and responses to regulatory authority requests.
- Legitimate interests: 91pha has a legitimate interest in fraud prevention, platform security, and service improvement — provided those interests do not override your fundamental rights.
- Consent: For marketing communications and the use of non-essential cookies, we rely on your explicit consent. You can withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
91pha does not sell, rent, or trade your personal data to any third party for commercial purposes. Period. However, to operate the 91pha platform effectively and comply with our legal obligations, we do share limited data with the following categories of trusted partners:
- Payment processors: GCash, Maya, BDO, BPI, UnionBank, Visa/Mastercard acquiring banks, and other payment partners receive transactional data necessary to process your deposits and withdrawals. These partners are independently regulated and maintain their own data security standards.
- Identity verification providers: Third-party KYC and AML service providers process your identity documents and perform liveness checks to verify your age and identity. They are bound by strict data processing agreements with 91pha.
- Game content providers: The studios and technology providers whose games are hosted on the 91pha platform receive game session data (player ID, bet amounts, game results) as needed to operate their titles and resolve disputes. They do not receive your full personal profile.
- IT infrastructure providers: Hosting, cloud storage, and cybersecurity service providers who process data on 91pha's behalf under contractual data processing agreements.
- Regulatory authorities: The relevant Philippine gaming and data protection authorities, law enforcement agencies, and courts — when required by law or a valid legal order.
91pha uses cookies and similar tracking technologies on its platform to make the site work properly, remember your preferences, and understand how players use our services. Here's a breakdown of the cookie types we use:
You can manage your cookie preferences at any time through your browser settings. Disabling non-essential cookies will not prevent you from using the 91pha platform, though some personalisation features may not function as intended. Your consent choices are saved per browser and device.
91pha takes the security of your personal data seriously. We implement technical and organisational measures designed to protect your information against unauthorised access, loss, destruction, or alteration. These include:
- Encryption at rest and in transit: All personal data stored by 91pha is encrypted using AES-256 encryption. All data transmitted between your device and the 91pha platform is protected by TLS 1.2 or higher.
- Access controls: Access to personal data is restricted on a strict need-to-know basis. 91pha employees and contractors can only access data that is necessary for their specific role. Access logs are maintained and reviewed.
- Two-factor authentication: Player accounts support 2FA. Internally, all systems handling personal data require multi-factor authentication from 91pha staff.
- Regular security testing: The 91pha platform undergoes regular penetration testing and vulnerability assessments by qualified security professionals.
- Incident response: 91pha maintains a documented data breach response procedure. In the event of a breach affecting player data, we will notify affected players and the National Privacy Commission within the timeframe required by law.
91pha keeps your personal data for as long as your account is active and for a period afterward as required by law and our legitimate business needs. Here's the general retention framework 91pha follows:
- Active account data: Retained for the full duration of your account being open with 91pha, plus at least 5 years after your account is closed — in line with Philippine AML requirements for financial records.
- KYC and identity verification documents: Retained for a minimum of 5 years from the date of verification, or longer if required by applicable law or an ongoing regulatory investigation.
- Transaction records: Retained for a minimum of 5 years from the date of each transaction for AML compliance and dispute resolution purposes.
- Support communications: Retained for 2 years after your last interaction with 91pha support, unless the subject matter requires longer retention.
- Marketing preferences and consent records: Retained for the duration of your account plus 2 years to demonstrate compliance with consent obligations.
When data is no longer required and no legal obligation requires its retention, 91pha securely deletes or anonymises it so that it can no longer be linked to you as an individual.
Under the Philippine Data Privacy Act (RA 10173), you have clear, enforceable rights over your personal data. 91pha is committed to honouring these rights promptly and without charging you any fee for exercising them.
Right to Access
Request a copy of all personal data 91pha holds about you, including how it's used and who it's shared with.
Right to Correction
Request that inaccurate or outdated personal data we hold about you is corrected or updated.
Right to Erasure
Request deletion of your personal data where it is no longer necessary or where you withdraw consent — subject to our legal retention obligations.
Right to Object
Object to processing of your data for direct marketing at any time. We will stop immediately upon receipt of your objection.
Right to Portability
Request your personal data in a structured, commonly used, machine-readable format that can be transferred to another service provider.
Right to Complain
If you believe your data rights have been violated, you may lodge a complaint with the National Privacy Commission of the Philippines.
The 91pha platform is strictly for persons aged 21 years and older. 91pha does not knowingly collect personal data from individuals under the age of 21, and we actively verify age during the registration and KYC process to prevent underage access.
If 91pha becomes aware that a registered account belongs to a person under 21 years of age, the account will be immediately suspended, any balance will be returned (excluding bonus-derived winnings), and the personal data of the minor will be deleted from our systems as soon as legally permissible.
If you believe a minor has registered on the 91pha platform, please notify us immediately at support@91pha.app so we can investigate and take appropriate action.
91pha is based in the Philippines and processes most personal data within the country. In limited circumstances, personal data may be transferred to or accessed by service providers located in other countries — for example, cloud infrastructure providers or certain game software vendors.
Where data is transferred outside the Philippines, 91pha ensures that appropriate safeguards are in place in accordance with the Data Privacy Act and NPC guidelines. These safeguards include:
- Standard contractual clauses included in data processing agreements with overseas providers.
- Limiting overseas access to the minimum data necessary for the specific processing purpose.
- Selecting processors in countries recognised as providing adequate data protection, or requiring equivalent protections by contract.
You may contact support@91pha.app to request information about the specific safeguards in place for any particular international transfer of your data.
The 91pha platform does not include links to third-party websites as a matter of policy. Any references to payment providers or regulatory bodies are for informational purposes only and do not constitute endorsements. 91pha is not responsible for the privacy practices of any third-party service you choose to use independently, such as your GCash or bank app. We encourage you to review the privacy policies of any third-party services you use in connection with your 91pha account.
91pha may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or platform features. When we make material changes, we will notify registered players via email and display a prominent notice on the 91pha platform at least 7 days before changes take effect.
The "Last Updated" date shown at the top of this policy always reflects the current version. Minor clarifications or corrections that do not affect your rights or the substance of our data practices may be made without advance notice.
We encourage you to review this policy periodically. Continued use of the 91pha platform after the effective date of any update constitutes your acknowledgement of the revised policy.
For any question, concern, or request relating to this Privacy Policy or the handling of your personal data by 91pha, please contact our Data Protection Officer:
- Email: support@91pha.app
- Subject line for data rights requests: "Data Rights Request"
- Subject line for privacy complaints: "Privacy Complaint"
- Response time: Acknowledgement within 3 business days; full response within 10 business days.
If you are not satisfied with our response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent government body responsible for enforcing the Data Privacy Act and protecting the data rights of Filipino citizens.