91phk Privacy Policy

91phk ("the Platform", "we", "us", "our") operates an online casino and sports betting platform accessible at 91phk.net, serving Filipino players across the Philippines — from Metro Manila and Cebu to Davao, Quezon City, Makati, and beyond. 91phk is the data controller responsible for the personal data of players and visitors who access the platform.

This Privacy Policy applies to all personal data collected and processed by 91phk in connection with your use of the website, mobile interface, gaming services, payment facilities, promotional programs, customer support channels, and any other features or content made available through the platform.

This policy should be read in conjunction with 91phk's Terms & Conditions and Responsible Gaming policy, both of which are incorporated by reference.

91phk collects only the personal data that is necessary to operate the platform, comply with legal obligations, and deliver a secure and personalised gaming experience. The categories of data we collect include the following:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data (other than photo ID for KYC purposes), or health data, except where strictly required by law or where you have given explicit consent.

91phk collects your personal data through the following channels:

• Direct submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated collection: Technical and usage data collected automatically when you access the platform, including through cookies, server logs, and analytics tools. See Section 7 for full details on our cookie practices.
• Third-party sources: Identity verification data received from KYC/AML service providers; transaction data received from payment processors such as GCash, Maya, BPI, BDO, and other supported payment methods; fraud prevention data received from risk management partners.
• Publicly available sources: Publicly accessible databases used to verify identity or check sanctions lists in accordance with our AML obligations.

91phk uses your personal data for the following purposes:

• Account management: Creating and maintaining your 91phk player account, verifying your identity, and enabling you to access games and services on the platform.
• Payment processing: Processing your deposits and withdrawals through GCash, Maya, GrabPay, InstaPay, PesoNet, BPI, BDO, Metrobank, 7-Eleven CLiQQ, USDT TRC20, Coins.ph, and QR Ph.
• Legal and regulatory compliance: Fulfilling our obligations under Philippine anti-money-laundering laws, KYC requirements, age verification rules, and any other applicable regulations governing online gaming in the Philippines.
• Security and fraud prevention: Detecting, investigating, and preventing fraudulent activity, account takeovers, bonus abuse, collusion, and other prohibited conduct on the platform.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behaviour and to administer self-exclusion, deposit limits, cooling-off periods, and other responsible gaming tools.
• Customer support: Responding to your enquiries, resolving disputes, processing complaints, and providing technical assistance.
• Platform improvement: Analysing aggregated usage data to improve game selection, site performance, user interface, and overall player experience.
• Marketing communications: Sending you information about promotions, bonuses, new games, and platform updates — but only where you have opted in or where we have a legitimate interest and you have not opted out. You can manage your marketing preferences at any time from your account settings or by contacting support.

Under the Philippine Data Privacy Act of 2012 (RA 10173), 91phk processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and 91phk — for example, processing your deposit, crediting winnings, and verifying your identity before a withdrawal.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations, KYC requirements, age verification mandates, and regulatory reporting duties.
• Legitimate interests: Processing carried out for 91phk's legitimate business interests, such as fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of prior processing.

Where we rely on legitimate interests as the legal basis for processing, we carry out a balancing assessment to ensure that our interests do not unfairly override your privacy rights. You have the right to object to processing based on legitimate interests at any time by contacting our Data Protection Officer (see Section 14).

91phk does not sell, rent, or trade your personal data to any third party. We may share your data with carefully selected third parties only in the following circumstances and only to the extent necessary:

• Payment processors: GCash, Maya, GrabPay, BPI, BDO, Metrobank, InstaPay, PesoNet, and other payment service providers — for the sole purpose of processing your deposits and withdrawals.
• Game providers: Third-party game studios and aggregators (such as Jili, PG Soft, and Pragmatic Play) — limited to the session data required to operate game rounds and calculate outcomes. Game providers do not receive your financial or identity data.
• KYC and AML service providers: Identity verification and anti-money-laundering screening services used to fulfil our regulatory obligations. These providers are bound by strict confidentiality and data protection agreements.
• Fraud prevention and security partners: Risk management platforms used to detect and prevent fraud, collusion, and money laundering on the platform.
• Regulatory authorities and law enforcement: The National Privacy Commission (NPC), PAGCOR, the Anti-Money Laundering Council (AMLC), law enforcement agencies, or courts — where required by applicable Philippine law, court order, or regulatory request.
• Professional advisors: Lawyers, accountants, auditors, and insurers — subject to binding confidentiality obligations — where necessary for legitimate legal or business purposes.

91phk uses cookies and similar tracking technologies to operate the platform, remember your preferences, maintain your login session, and collect aggregated analytics data that helps us improve the user experience for all Filipino players.

The types of cookies we use include:

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that keep you logged in during your visit and security cookies that protect your account. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, preferred game lobby view, and responsible gaming reminder intervals.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate and interact with the platform. This data is used solely to improve site performance and game discovery — never to identify individual players for marketing purposes.
• Security and fraud detection cookies: Help identify and block suspicious or fraudulent activity, including bot traffic and account takeover attempts.

You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent the platform from functioning correctly and you will not be able to log in or play. Disabling analytics or functional cookies will not prevent you from using the platform but may affect certain personalisation features.

91phk retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act and related regulations.
• Customer support communications: Retained for three (3) years from the date of the interaction, or longer where a dispute or regulatory investigation is ongoing.
• Marketing preference records: Retained for the duration of your account and for one (1) year following opt-out, to demonstrate compliance with consent requirements.
• Technical and usage logs: Typically retained for twelve (12) months in active systems and up to three (3) years in archived form for security and audit purposes.

Upon the expiry of the applicable retention period, your personal data will be securely deleted or anonymised so that it can no longer be linked to you as an individual. Where full deletion is not immediately practicable due to system architecture, the data will be isolated and protected until secure deletion is possible.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in respect of your personal data held by 91phk:

• Right to be informed: The right to know what personal data 91phk collects about you, the purpose of collection, and how it is used — which is the primary purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data 91phk holds about you. We will respond to access requests within 15 business days.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected. You can update most profile information directly within your 91phk account. For identity data, please contact our support team.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 91phk's legal obligations to retain certain data (see Section 8).
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing. Where you object to marketing, we will stop processing your data for that purpose immediately.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that your personal data has been processed in violation of RA 10173.

The 91phk platform is strictly for individuals aged 21 years and above. This is the minimum legal age for casino-style gambling in the Philippines, and 91phk enforces this requirement without exception.

91phk does not knowingly collect, process, or store personal data belonging to individuals under the age of 21. If we discover or are notified that an account has been registered by or on behalf of a minor, we will immediately close the account, delete all associated personal data to the extent permitted by our legal obligations, and take appropriate steps in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor has registered on the 91phk platform, please contact our support team immediately via the 24/7 live chat facility or by emailing [email protected]. We take child protection extremely seriously and will act on all such reports with urgency.

91phk implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security infrastructure includes:

• TLS encryption for all data in transit between your device and 91phk servers
• Encryption of sensitive data at rest, including financial records and identity documents
• Role-based access controls ensuring that only authorised 91phk personnel can access player data, and only to the extent required by their specific role
• Multi-factor authentication for internal administrative systems
• Continuous monitoring and intrusion detection systems
• Regular penetration testing and vulnerability assessments conducted by independent security specialists
• Secure data deletion protocols applied when data reaches the end of its retention period
• Staff training on data protection obligations and information security best practices

While 91phk takes all reasonable and appropriate measures to protect your personal data, no internet-based platform can guarantee absolute security. You also have a role to play in keeping your account secure: use a strong, unique password for your 91phk account, never share your login credentials, and contact us immediately if you suspect any unauthorised access to your account.

The 91phk platform integrates third-party services including game providers, payment processors, and customer support tools. While 91phk carefully selects and vets all third-party partners, each third party operates under its own privacy policy and data protection framework. 91phk is not responsible for the privacy practices of third-party game providers or payment processors once data is transmitted to them for the purposes of service delivery.

All third-party data processors engaged by 91phk are required to enter into data processing agreements that bind them to processing your data only on 91phk's documented instructions, implementing appropriate security measures, and complying with applicable data protection law. We do not engage third-party processors who cannot demonstrate adequate data protection standards.

The 91phk platform does not contain links to third-party websites for browsing or advertising purposes. Any internal links on the platform lead exclusively to other pages within the 91phk website.

91phk reviews and updates this Privacy Policy periodically to reflect changes in our data practices, legal obligations, platform features, or regulatory requirements. The "Last updated" date at the top of this page indicates when the most recent revision was made.

Where changes to this Privacy Policy are material — for example, where we introduce a new category of data collection or a new purpose for processing — we will provide advance notice to registered players via email to your registered address or via an in-platform notification, at least seven (7) days prior to the changes taking effect where practicable.

For minor or administrative updates — such as clarifications of existing practices, corrections of typographical errors, or updates to contact information — changes may take effect immediately upon publication. Your continued use of the 91phk platform following the publication of any updated Privacy Policy constitutes your acknowledgement of the revised policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 91phk protects your personal data. If you have any questions about any changes made, our support team is available 24/7 via live chat inside your account.

If you have any questions, concerns, or complaints about this Privacy Policy or about how 91phk processes your personal data, please contact our Data Protection Officer (DPO) using the details below. Our team is available 24 hours a day, 7 days a week, including Philippine public holidays.

If you are not satisfied with 91phk's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent regulatory authority responsible for overseeing compliance with RA 10173. The NPC can be reached through its official government portal.