91piso Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") describes how 91piso ("91piso", "we", "us", "our") collects, uses, stores, shares, and protects personal information provided by users ("Player", "you") of the 91piso online gaming platform accessible at 91piso.net and any associated services.

1.2 By registering for a 91piso Account or using the Platform in any way, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, you must not register for or use the Platform.

1.3 This Policy is incorporated by reference into the 91piso Terms and Conditions. In the event of any conflict between this Policy and the Terms and Conditions, the Terms and Conditions shall prevail unless this Policy explicitly states otherwise.

1.4 This Policy applies to all data collected through the 91piso website, mobile browser experience, and any other electronic interface through which you access 91piso services.

2. Data Controller

2.1 91piso operates as the data controller for personal information collected through the Platform. As data controller, 91piso determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

2.2 For any data privacy enquiries or to exercise your data subject rights under the Data Privacy Act, please contact 91piso using the contact details provided in Section 13 of this Policy.

3. Personal Data We Collect

3.1 91piso collects personal data in several ways: directly from you when you register or use the Platform, automatically through your use of the Platform, and from third-party sources such as payment processors during transaction verification.

3.2 91piso does not collect sensitive personal information (as defined under the Data Privacy Act of 2012) unless strictly required by regulatory obligations such as enhanced KYC procedures. Where sensitive personal information is collected, explicit consent will be obtained and the data will be protected under the highest security standards applied by 91piso.

4. How 91piso Uses Your Personal Data

4.1 91piso processes your personal data for the following purposes:

• Account creation and management: To register your Account, verify your identity, and maintain your Account in good standing throughout your relationship with 91piso.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, and Philippine bank partners; to detect and prevent fraudulent transactions; and to maintain accurate transaction records.
• Regulatory compliance: To fulfil obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws and regulations.
• Customer support: To respond to your enquiries, resolve disputes, and maintain records of communications for quality assurance and compliance purposes.
• Platform security: To detect and prevent unauthorised account access, fraudulent activity, collusion, and abuse of promotional systems.
• Responsible gaming: To monitor player activity for indicators of problem gambling and to administer self-exclusion, deposit limit, and cooling-off requests.
• Platform improvement: To analyse usage patterns and inform product development decisions. Analytical processing uses aggregated or anonymised data wherever feasible.
• Marketing communications: To send promotional offers and platform updates to Players who have consented to receive marketing communications. Players may opt out at any time via Account settings or by contacting support.

5. Legal Basis for Processing

5.1 91piso processes your personal data under the following legal bases as applicable under the Data Privacy Act of 2012:

• Contract performance: Processing necessary to perform the agreement between you and 91piso under the Terms and Conditions — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AMLA reporting obligations, tax requirements, and other applicable Philippine legal obligations.
• Legitimate interests: Processing necessary for 91piso's legitimate interests in operating a secure, fair, and commercially viable platform — including fraud prevention, security monitoring, and analytics — where those interests are not overridden by your privacy interests.
• Consent: Processing based on your explicit consent, including marketing communications and optional data collection not required for core Platform functionality. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

6.1 91piso does not sell, rent, or trade your personal data to third parties for commercial purposes.

6.2 91piso may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash (G-Xchange Inc.), PayMaya (Maya Bank), and Philippine banking partners (BPI, BDO, Metrobank) as necessary to process deposits and withdrawals.
• Game technology providers: Licensed game studios and RNG certification bodies who supply or audit the games available on the Platform. These providers receive only the minimal technical data necessary for game delivery and compliance auditing.
• KYC and identity verification providers: Third-party identity verification services engaged to support the KYC process where 91piso's internal team requires technical assistance.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where disclosure is required by law, regulation, or lawful order.
• Professional advisors: Legal counsel, auditors, and insurers operating under professional confidentiality obligations.

6.3 Any third-party service providers engaged by 91piso are required by contract to process personal data only for the purposes specified by 91piso and to maintain security standards consistent with this Policy.

7. Cookies and Tracking Technologies

7.1 91piso uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies: Required for core Platform functionality including session management, authentication, and security. These cannot be disabled without impairing your ability to use the Platform.
• Analytical cookies: Used to understand how Players navigate the Platform — which pages are visited most, how long sessions last, and where players encounter difficulties. Data collected is aggregated and anonymised where possible.
• Preference cookies: Used to remember your Platform settings and personalisation choices between sessions.

7.2 You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the core 91piso Platform, but may affect some personalisation and analytical features.

7.3 91piso does not use third-party advertising cookies or share tracking data with advertising networks.

8. Data Retention

8.1 91piso retains your personal data for as long as your Account remains active and for such additional periods as are required by law or regulation. The primary data retention periods applicable to 91piso Player data are:

• Account and identity data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, as required under PAGCOR licensing conditions and AMLA record-keeping obligations.
• Transaction records: Retained for a minimum of five (5) years following the transaction date in compliance with AMLA and tax regulations.
• Support communications: Retained for three (3) years following the closure of the support interaction or Account, whichever is later.
• Technical and usage data: Retained in identifiable form for up to twenty-four (24) months; thereafter anonymised for aggregated analytical purposes.

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

9. Security Measures

9.1 91piso implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 91piso's servers.
• Encrypted storage of passwords using strong one-way hashing algorithms; 91piso does not store plain-text passwords.
• Two-factor authentication (2FA) available for all Player accounts.
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis.
• Regular security audits and penetration testing of Platform infrastructure.
• Active monitoring for anomalous login activity and data access patterns.

9.2 In the event of a personal data breach that poses a risk to your rights and freedoms, 91piso will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach and will notify affected Players without undue delay, in accordance with the Data Privacy Act of 2012.

10. Your Data Subject Rights

10.1 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 be informed of how your personal data is being collected and processed — this Policy fulfils that obligation.
• Right of access: You have the right to request a copy of the personal data 91piso holds about you.
• Right to rectification: You have the right to request correction of inaccurate or incomplete personal data.
• Right to erasure: You have the right to request deletion of your personal data where retention is no longer necessary for the original purpose and no overriding legal obligation requires continued retention.
• Right to object: You have the right to object to processing of your personal data for marketing purposes at any time.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

10.2 To exercise any of the above rights, please contact 91piso using the details in Section 13. 91piso will respond to data subject requests within fifteen (15) calendar days of receipt, in accordance with NPC guidelines.

11. Children and Minors

11.1 The 91piso Platform is strictly for individuals aged 21 years and above. 91piso does not knowingly collect personal data from individuals below the age of 21. Age verification is embedded in the registration and KYC process to enforce this restriction.

11.2 If 91piso becomes aware that personal data has been collected from an individual below the age of 21, the relevant Account will be closed immediately, all associated funds will be dealt with in accordance with applicable regulations, and the personal data will be deleted as soon as practicable and in compliance with any mandatory retention obligations.

11.3 If you believe that a minor has registered on 91piso, please contact the support team immediately using the contact details in Section 13.

12. Changes to This Privacy Policy

12.1 91piso reserves the right to update this Privacy Policy at any time to reflect changes in law, regulatory requirements, Platform functionality, or data processing practices. The "Last Updated" date at the top of this Policy indicates when it was most recently revised.

12.2 Where changes are material — meaning they affect your rights or the manner in which 91piso processes your personal data in a significant way — 91piso will provide advance notice to registered Players via their registered email address and/or a prominent notice on the Platform before the changes take effect.

12.3 Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy. If you do not accept the revised Policy, you must cease using the Platform and may request account closure.

13. Contact and Data Privacy Enquiries

For any questions, concerns, or requests relating to this Privacy Policy or to exercise your data subject rights under the Data Privacy Act of 2012, please contact 91piso's Data Privacy team:

• Email: [email protected]
• Live Chat: Available 24/7 within your logged-in 91piso Account
• Response Time: 91piso will acknowledge data privacy requests within 72 hours and provide a substantive response within 15 calendar days.

If you are not satisfied with 91piso's response to a data privacy concern, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC).