Privacy Policy
91piso Platform

1.1 91piso ("the Platform," "we," "us," or "our") is an online gaming platform accessible at 91piso.app, operated to serve Filipino players across the Philippines with casino games, sports betting, bingo, and related entertainment services.

1.2 This Privacy Policy describes how 91piso collects, uses, stores, discloses, and protects the personal data of individuals ("User," "Player," or "you") who access or use the Platform, including visitors who have not yet registered.

1.3 91piso is committed to processing personal data in a lawful, fair, and transparent manner, consistent with the principles of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "the DPA") and the implementing rules and regulations issued by the National Privacy Commission (NPC).

1.4 This Policy should be read in conjunction with 91piso's Terms & Conditions, which together govern your relationship with the Platform. In the event of any conflict between this Policy and the Terms & Conditions on data privacy matters, this Privacy Policy shall prevail.

2.1 For the purposes of the Philippine Data Privacy Act, 91piso acts as the Personal Information Controller (PIC) with respect to all personal data collected through the 91piso.app platform.

2.2 As a Personal Information Controller, 91piso determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the DPA, its implementing rules, and applicable NPC issuances.

2.3 Where 91piso engages third-party service providers (such as payment processors and game software providers) who process personal data on our behalf and under our documented instructions, such parties act as Personal Information Processors (PIPs) and are contractually bound to process your data only in accordance with 91piso's instructions and the DPA.

91piso collects personal data across several categories depending on how you interact with the Platform:

3.1 Registration and Identity Data

• Full legal name (as it appears on government-issued identification)
• Date of birth (for age verification — 21+ requirement)
• Email address
• Philippine mobile number
• Username and encrypted account password
• Residential address (required for KYC)
• Nationality

3.2 Identity Verification (KYC) Data

• Scanned or photographed government-issued identification (e.g., PhilSys National ID, Driver's License, Passport, UMID, SSS ID, Voter's ID)
• Selfie or liveness verification image (for biometric matching)
• Proof of address documents (where required)
• Source-of-funds declarations (for large transactions)

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (GCash mobile number, Maya account details, bank account information — full card or account numbers are never stored by 91piso directly)
• Transaction amounts, dates, and reference numbers
• Account balance history

3.4 Gaming Activity Data

• Games played, bet amounts, and game outcomes
• Active bonuses and wagering progress
• Session durations and gaming frequency
• Responsible gaming limit settings and self-exclusion requests

3.5 Technical and Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser
• Session timestamps and login history
• Referring URL and navigation data within the Platform

3.6 Communications Data

• Live chat transcripts and support ticket records
• Email and SMS correspondence with 91piso
• Feedback and complaint records

4.1 Directly from you. The majority of personal data 91piso holds is provided directly by you during account registration, KYC verification, deposit and withdrawal requests, support interactions, and voluntary communications with the Platform.

4.2 Automatically through your use of the Platform. When you visit 91piso.app or use any Platform feature, technical data such as your IP address, device type, browser version, and session activity data is collected automatically through server logs and cookies.

4.3 From third-party identity verification services. 91piso may use accredited third-party KYC and identity verification service providers to validate the authenticity of government-issued identification documents submitted during the KYC process.

4.4 From payment processors. Payment service providers (such as GCash / GXI Inc., Maya / Paymaya Philippines Inc., and participating banks) may share transaction confirmation data with 91piso as part of the payment processing workflow.

4.5 From game software providers. Licensed game providers may share session and gaming outcome data with 91piso for the purposes of accurate account crediting, dispute resolution, and game fairness auditing.

91piso processes personal data on the following legal bases under Section 12 and Section 13 of the Philippine Data Privacy Act:

6.1 Account administration. To create, maintain, and manage your 91piso account, process your deposits and withdrawals, apply bonuses, and provide access to all Platform features.

6.2 Identity verification and KYC compliance. To verify your identity, confirm that you meet the minimum age requirement of 21 years, and comply with Philippine anti-money laundering obligations under the Anti-Money Laundering Act (AMLA) and its amendments.

6.3 Security and fraud prevention. To detect, investigate, and prevent unauthorized account access, identity fraud, payment fraud, money laundering, and other prohibited activities on the Platform.

6.4 PAGCOR and regulatory compliance. To fulfill reporting obligations to PAGCOR and other competent Philippine authorities as required under applicable gaming regulations.

6.5 Responsible gaming. To enforce deposit limits, loss limits, session timers, and self-exclusion periods set by players or required by regulatory mandate; to identify behavioral indicators of problem gambling; and to communicate responsible gaming support information.

6.6 Customer support. To respond to inquiries, process complaints, and resolve disputes submitted via live chat, email, or other support channels.

6.7 Marketing communications. To send you promotional offers, bonus notifications, and news about 91piso — but only where you have provided explicit consent to receive such communications. You may withdraw consent at any time via your Account Preferences or by contacting support.

6.8 Platform improvement. To analyze aggregated usage patterns, identify technical issues, improve game performance, and enhance the overall player experience on 91piso.

6.9 Legal claims. To establish, exercise, or defend legal claims involving 91piso, whether in judicial, administrative, or out-of-court proceedings.

7.1 91piso uses cookies and similar tracking technologies (including session tokens, local storage, and web beacons) to operate and improve the Platform.

7.2 Essential cookies are strictly necessary for the Platform to function — they maintain your login session, remember your preferences, and enable secure transactions. These cookies cannot be disabled without disrupting Platform functionality.

7.3 Analytical cookies allow 91piso to understand how players navigate and use the Platform. This data is used in aggregate form to identify performance issues and improve the user experience. Analytical cookies are enabled by default but may be disabled in your browser settings.

7.4 Security cookies are used to detect and prevent fraudulent login attempts, bot activity, and unauthorized access. These cookies are essential for account security.

7.5 By continuing to use the 91piso Platform after being notified of cookie usage, you consent to the placement of non-essential cookies. You can manage cookie preferences through your browser settings at any time. Note that disabling certain cookies may impact Platform performance or game loading.

8.1 Payment processors. 91piso shares transaction data with payment service providers (GCash, Maya, BPI, BDO, Metrobank, and others) strictly as necessary to process deposits and withdrawals. These providers operate under their own privacy policies and are regulated by the Bangko Sentral ng Pilipinas (BSP).

8.2 Game software providers. Licensed game studios and aggregators receive session data necessary to deliver and record game results. These providers are bound by data processing agreements and are prohibited from using player data for purposes beyond game delivery and fairness auditing.

8.3 KYC and identity verification partners. Accredited third-party identity verification services receive copies of KYC documents solely for the purpose of verifying their authenticity. These services operate under strict data protection and confidentiality obligations.

8.4 Regulatory and law enforcement authorities. 91piso will disclose personal data to PAGCOR, the AMLC (Anti-Money Laundering Council), the NPC, or any other competent Philippine government authority when required to do so by law, court order, regulatory mandate, or legitimate investigation.

8.5 Professional advisers. 91piso may share data with legal counsel, auditors, or consultants where strictly necessary for the performance of their professional services, subject to professional confidentiality obligations.

8.6 Corporate transactions. In the event of a merger, acquisition, or sale of all or substantially all of 91piso's assets, player data may be transferred as part of that transaction. Players will be notified of any material change in data controllership.

9.1 91piso retains personal data only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law.

9.2 Active accounts. Personal data associated with an active 91piso account is retained for the duration of the account's existence and for a period of at least five (5) years following permanent account closure, in compliance with AMLA record-keeping requirements.

9.3 KYC documents. Identity verification documents are retained for the period required by PAGCOR regulations and applicable AMLA provisions — currently a minimum of five (5) years from the date of the last transaction or account closure, whichever is later.

9.4 Transaction records. Financial transaction records are retained for a minimum of five (5) years as required under the AMLA and BSP regulations.

9.5 Support records. Customer support correspondence is retained for three (3) years from the date of the last interaction, or longer where retention is necessary for the resolution of outstanding disputes or legal proceedings.

9.6 Where retention beyond the above periods is required by a court order, regulatory direction, or ongoing legal proceedings, data will be retained until such requirements are satisfied.

10.1 91piso implements technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures are proportionate to the sensitivity of the data processed and the risks identified.

10.2 Technical measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 91piso's servers;
• Encrypted storage of passwords using industry-standard hashing algorithms;
• Two-Factor Authentication (2FA) available to all registered users;
• Intrusion detection and prevention systems;
• Access controls limiting data access to authorized 91piso personnel on a need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure.

10.3 Organizational measures include:

• Staff privacy and data protection training;
• Data processing agreements with all third-party processors;
• Internal data governance policies and incident response procedures;
• Appointment of a Data Protection Officer responsible for DPA compliance.

10.4 In the event of a personal data breach that is likely to give rise to a real risk of 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 players without undue delay, as required under Section 20(f) of the DPA.

As a data subject under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by 91piso:

11.1 To exercise any of the above rights, please contact 91piso's Data Protection Officer using the contact details in Section 13. We will respond to verifiable requests within fifteen (15) days from receipt, or within such other period as required by applicable NPC regulations.

11.2 Requests to exercise privacy rights must be submitted by the registered account holder and may require identity verification to protect against unauthorized requests. We may ask you to provide additional information to verify your identity before processing your request.

11.3 Certain rights are subject to legal limitations. For example, the right to erasure cannot override 91piso's legal obligation to retain KYC and transaction records under AMLA regulations.

12.1 The 91piso platform is strictly intended for adults aged twenty-one (21) years and older. 91piso does not knowingly collect personal data from individuals under 21 years of age.

12.2 If 91piso becomes aware that personal data has been submitted by an individual under the age of 21, that data will be promptly deleted and the associated account suspended. Age verification is a mandatory step in the KYC process specifically to prevent underage access.

12.3 Parents and legal guardians are encouraged to employ parental control software and monitor their household's internet usage to prevent minors from accessing gambling platforms. If you believe a minor in your household has accessed the 91piso Platform, please contact our support team immediately via live chat or email at the address in Section 13.

For all privacy-related inquiries, requests to exercise data subject rights, or concerns about 91piso's data processing practices, please contact the 91piso Data Protection Officer through the following channels:

91piso will acknowledge all formal privacy requests within three (3) business days and will endeavor to provide a substantive response within fifteen (15) days, or such other period as required by applicable NPC rules. Complex requests may take longer, and we will notify you if an extension is required.

If you are dissatisfied with 91piso's response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC), which is the supervisory authority for data protection in the Philippines.

14.1 91piso may update or amend this Privacy Policy periodically to reflect changes in applicable law, NPC guidance, PAGCOR regulatory requirements, or 91piso's data processing practices.

14.2 The effective date at the top of this document indicates when the current version came into force. The most current version of this Policy is always accessible at 91piso.app/privacy-policy.

14.3 Where material changes are made to this Policy, 91piso will notify registered players by email or by displaying a prominent notice on the Platform prior to the changes taking effect, where reasonably practicable.

14.4 Your continued use of the 91piso Platform after the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. If you do not accept the changes, please cease use of the Platform and contact us to request account closure.