91piso Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") describes how 91piso ("the Platform," "we," "us," or "our"), operator of the online gaming platform at 91piso.club, collects, processes, stores, and discloses personal information relating to registered users, prospective users, and visitors to the 91piso website ("Data Subjects" or "you").

This Policy applies to all personal data processed by 91piso in connection with the provision of the Platform, including account registration, identity verification, payment processing, customer support, and marketing communications where applicable.

By registering an account on 91piso or by continuing to use the Platform after this Policy has been posted, you acknowledge that you have read and understood how your personal data is processed as described herein. If you do not agree to this Policy, you must not use the 91piso platform.

This Policy should be read in conjunction with 91piso's Terms & Conditions.

2. Data Controller

91piso is the data controller responsible for your personal information. As data controller, 91piso determines the purposes and means by which your personal data is processed. A designated Data Protection Officer (DPO) is responsible for overseeing compliance with this Policy and applicable data protection law.

For all data privacy matters, you may contact our DPO at: [email protected]

3. Personal Data We Collect

91piso collects the following categories of personal data, depending on your interaction with the Platform:

• Identity Data: Full legal name, date of birth, nationality, and copies of government-issued identification documents (e.g., Philippine PhilSys ID, UMID, driver's licence, passport) submitted during KYC verification.
• Contact Data: Email address, mobile phone number (Philippine), and residential address.
• Financial Data: Payment method details used for deposits and withdrawals, including GCash-registered mobile numbers, Maya account references, bank account details, and USDT wallet addresses. Full payment card or account numbers are not stored by 91piso.
• Account & Activity Data: Username, login history, session duration, game play records, betting history, deposit and withdrawal transactions, bonus claims, and support ticket records.
• Technical Data: IP address, browser type and version, device type and operating system, referring URL, and cookies data collected during your use of the Platform.
• Communications Data: Content of communications submitted to 91piso's support team via live chat or email, including any attachments or documents you provide.

4. How We Collect Your Data

91piso collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, setting responsible gaming preferences, or contacting customer support.
• Automated technical collection: Device and usage data collected automatically when you access the 91piso website, including through cookies, server logs, and similar technologies.
• Third-party providers: Identity verification and fraud detection data received from licensed KYC service providers. Payment confirmation data received from GCash, Maya, BPI, BDO, and other payment processors. AML screening data from compliance screening services.

5. Legal Basis for Processing

91piso processes your personal data on the following legal bases under Republic Act No. 10173 (Data Privacy Act of 2012):

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you have accepted, including operating your account, processing transactions, and providing customer support.
• Legal obligation: Processing required to comply with Philippine regulatory requirements, including anti-money laundering (AML) obligations under Republic Act No. 9160 (Anti-Money Laundering Act), tax reporting obligations, and regulatory reporting to relevant authorities.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming enforcement, and internal analytics to improve the Platform, where such interests are not overridden by your data protection rights.
• Consent: Where we rely on your consent as the legal basis for a specific processing activity (such as marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Personal Data

91piso uses your personal data for the following purposes:

• To register and maintain your 91piso account and provide access to the Platform
• To verify your identity and age in compliance with KYC and AML regulatory requirements
• To process deposits and withdrawals to and from your account
• To provide customer support and respond to your inquiries or complaints
• To detect, investigate, and prevent fraud, money laundering, or other prohibited activities
• To enforce 91piso's responsible gaming tools including deposit limits, self-exclusion, and age verification
• To comply with applicable Philippine laws, regulations, and court orders
• To improve the Platform's functionality, security, and user experience based on anonymised usage analytics
• To send you account-related notifications (transaction confirmations, security alerts, account updates)
• To send promotional communications, where you have consented and not subsequently opted out

7. Data Sharing & Disclosure

91piso does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We disclose your data only in the following circumstances:

• Payment processors: GCash, Maya, BPI, BDO, and USDT payment infrastructure providers receive transaction data necessary to process your deposits and withdrawals.
• KYC and identity verification providers: Licensed third-party identity verification services receive your identity documents and biometric data solely for the purpose of completing your KYC verification.
• AML and fraud screening providers: Compliance screening services receive limited personal data to perform sanctions screening and fraud risk assessments.
• Regulatory and law enforcement authorities: 91piso will disclose personal data to the Anti-Money Laundering Council (AMLC), National Privacy Commission (NPC), or other competent Philippine authorities where required by law or court order.
• Professional advisers: Lawyers, auditors, and insurers engaged by 91piso may access personal data on a strictly confidential, need-to-know basis.

All third-party processors engaged by 91piso are bound by contractual data processing agreements requiring them to process personal data only for specified purposes and to maintain appropriate security standards.

8. International Data Transfers

Some of 91piso's service providers operate outside the Philippines. Where personal data is transferred to jurisdictions outside the Philippines, 91piso ensures that appropriate safeguards are in place to protect your data in accordance with RA 10173, including standard contractual clauses, adequacy assessments, or other mechanisms recognised under Philippine data protection law.

9. Data Security

91piso implements technical and organisational security measures proportionate to the risks presented by the processing of your personal data:

• All data transmitted between your device and 91piso servers is encrypted using TLS (Transport Layer Security).
• Sensitive personal data and financial data are encrypted at rest using industry-standard encryption.
• Access to personal data within 91piso is strictly limited to authorised personnel with a legitimate operational need.
• Platform systems are subject to regular security vulnerability assessments and penetration testing.
• 91piso maintains an incident response procedure for detecting, reporting, and managing personal data breaches in accordance with NPC requirements.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach affecting your personal data, 91piso will notify you and the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, where required by RA 10173.

10. Data Retention

91piso retains your personal data for the periods necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of 5 years following account closure, to comply with AML record-keeping obligations under RA 9160.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction.
• Support communications: Retained for 3 years following resolution of the relevant inquiry or complaint.
• Technical log data: Retained for up to 12 months for security and fraud prevention purposes.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised so that it can no longer be associated with you.

11. Cookies & Tracking Technologies

91piso uses the following categories of cookies on its website:

• Strictly necessary cookies: Essential to the operation of the Platform. These enable secure login sessions, maintain your authenticated state, and support core platform security functions. These cookies cannot be disabled without impairing Platform functionality.
• Analytics cookies (anonymised): Used to collect anonymised data about how visitors use the 91piso platform (pages visited, session duration, device type). This data is used solely to improve the Platform's performance and user experience. No personally identifiable information is collected through analytics cookies.

91piso does not use advertising cookies, behavioural tracking cookies, or third-party social media tracking pixels. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use the Platform.

12. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by 91piso:

• Right to be informed: The right to be informed that your personal data is being processed and the basis for such processing.
• Right of access: The right to obtain a copy of the personal data 91piso holds about you and information about how it is processed.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected without delay.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to applicable legal retention obligations.
• Right to restrict processing: The right to request that processing of your data be suspended in certain circumstances.
• Right to data portability: The right to receive your personal data in a structured, commonly used format for the purpose of transferring it to another platform, where technically feasible.
• Right to object: The right to object to processing based on legitimate interests or direct marketing, at any time.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw consent at any time without affecting prior lawful processing.

To exercise any of these rights, submit a written request to [email protected]. 91piso will respond to all valid data rights requests within 15 business days. Identity verification may be required before processing your request. Where a request is denied, 91piso will provide written reasons.

If you are unsatisfied with 91piso's handling of your personal data, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).

13. Children's Privacy

The 91piso platform is strictly for individuals who are 21 years of age or older. 91piso does not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from a person under the minimum age requirement, that account will be immediately closed and all associated personal data will be deleted from our systems.

14. Changes to This Privacy Policy

91piso reserves the right to update this Privacy Policy at any time. Where changes are material, we will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect. The "Last Updated" date at the top of this Policy will be revised accordingly.

Continued use of the 91piso platform following the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree to the revised Policy, you must cease using the Platform and close your account.

15. Contact & Data Protection Officer

For all privacy-related inquiries, data subject rights requests, or complaints, please contact 91piso's Data Protection Officer:

Email: [email protected]

Please include "Privacy Request" in your subject line and provide sufficient information to verify your identity. Formal data privacy requests are processed within 15 business days. General support inquiries are responded to within 24 hours.