91pht Privacy Policy

1. Personal Data We Collect

1.1  In order to provide its services, comply with regulatory requirements, and maintain the security and integrity of the 91pht platform, we collect the following categories of personal data:

1.1.1 Identity Data

• Full legal name as it appears on government-issued identification;
• Date of birth and age verification documentation;
• Government-issued identification numbers (e.g., Philippine passport number, SSS number, UMID number, driver's licence number);
• Selfie or photograph for identity verification purposes.

1.1.2 Contact Data

• Philippine mobile number;
• Email address;
• Residential address (province, city, barangay).

1.1.3 Financial Data

• GCash account number or registered mobile number;
• PayMaya account details;
• Philippine bank account details (BPI, BDO, Metrobank, or other supported institutions) where bank transfer is used;
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used;
• Source of funds documentation where required under Anti-Money Laundering Act (AMLA) compliance procedures.

1.1.4 Gaming Activity Data

• Game titles played, session durations, wager amounts, and game outcomes;
• Bonus claims and promotion participation history;
• Responsible gaming settings and self-exclusion records.

1.1.5 Technical Data

• IP address and approximate geolocation at the time of login;
• Device type, operating system, and browser type;
• Session timestamps and login history.

2. How We Collect Your Personal Data

2.1  Direct Collection: The majority of personal data collected by 91pht is provided directly by you — during account registration, KYC verification submissions, payment method setup, customer support interactions, and responsible gaming self-assessments.

2.2  Automated Collection: When you access the 91pht platform, certain technical data is collected automatically through cookies, server logs, and similar tracking technologies. This includes your IP address, device information, browser type, and session activity. See Section 7 for our full Cookies Policy.

2.3  Third-Party Sources: 91pht may receive supplementary personal data from third-party identity verification providers, payment processors, and fraud prevention services engaged to support our KYC and AML compliance obligations. Data received from such sources is treated with the same level of protection as data collected directly.

3. How We Use Your Personal Data

3.1  91pht processes your personal data for the following specific purposes:

• Account Management: Creating, maintaining, and managing your 91pht player account, including authentication and security;
• Payment Processing: Facilitating deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers;
• Regulatory Compliance: Fulfilling PAGCOR licensing obligations, Anti-Money Laundering Act requirements, and age verification mandates;
• Customer Support: Responding to player inquiries, complaints, and account recovery requests;
• Responsible Gaming: Monitoring gaming patterns for indicators of problem gambling and administering self-exclusion and deposit limit tools;
• Fraud Prevention: Detecting and preventing fraudulent activity, bonus abuse, money laundering, and unauthorized account access;
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve game selection, platform performance, and user experience;
• Marketing Communications: Sending promotional offers and bonus notifications to players who have opted in — subject to your communication preferences, which may be updated at any time.

3.2  91pht will not use your personal data for any purpose that is incompatible with the purposes described in Section 3.1 without first notifying you and obtaining your consent where required by applicable law.

4. Disclosure and Sharing of Personal Data

4.1  91pht does not sell, rent, or trade your personal data to third parties for independent commercial purposes. Personal data may be disclosed to the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors to facilitate deposit and withdrawal transactions;
• Identity Verification Services: Third-party KYC and document verification providers engaged to support our age and identity verification obligations;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities where disclosure is required by law, court order, or regulatory directive;
• Technology Partners: Cloud hosting, cybersecurity, and platform infrastructure providers operating under contractual data protection obligations;
• Game Content Providers: Game studios and aggregators (in anonymized or aggregated form only, not identifying individual players) for technical integration and RNG auditing purposes.

4.2  All third-party service providers with whom 91pht shares personal data are required to process that data only in accordance with 91pht's instructions and this Policy, and may not use it for their own independent purposes. 91pht maintains data processing agreements with all such providers.

4.3  In the event of a corporate restructuring, merger, acquisition, or sale of 91pht's business assets, player data may be transferred to the acquiring entity, subject to the same level of data protection described in this Policy. Players will be notified of any such transfer in advance where practicable.

5. Data Retention

5.1  91pht retains personal data for the period necessary to fulfill the purposes described in this Policy and to comply with applicable legal and regulatory obligations. The following retention periods apply as a general guide:

• Active account data is retained for the duration of the account's active status plus a minimum of five (5) years following account closure, in compliance with the Anti-Money Laundering Act;
• KYC verification documents are retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later;
• Transaction records are retained for a minimum of five (5) years as required under PAGCOR's record-keeping requirements;
• Customer support correspondence is retained for three (3) years from the date of the interaction;
• Technical and session log data is retained for up to twelve (12) months for security monitoring and fraud detection purposes.

5.2  Following the expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 91pht's data disposal procedures.

6. Data Security

6.1  91pht implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 91pht platform;
• Encrypted storage for sensitive personal and financial data at rest;
• Multi-factor authentication for administrative access to systems containing player data;
• Regular third-party security audits and penetration testing;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Incident response procedures for detecting, containing, and notifying affected players of data breaches in accordance with NPC (National Privacy Commission) notification requirements.

6.2  While 91pht employs industry-standard security practices, no data transmission over the internet or electronic storage system can be guaranteed to be completely secure. Players are responsible for maintaining the security of their own account credentials and should contact 91pht support immediately if they suspect unauthorized account access.

7. Cookies and Tracking Technologies

7.1  The 91pht platform uses cookies — small text files stored on your device — and similar tracking technologies to support platform functionality, security, and performance analysis. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function correctly, including session authentication, security tokens, and load balancing. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, game lobby filters, and responsible gaming tool configurations.
• Analytics Cookies: Collect aggregated, anonymized data about how players interact with the platform to support performance improvements. No personally identifiable information is transmitted.

7.2  You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair the functionality of the 91pht platform, including the ability to log in and access your account.

8. Your Data Privacy Rights

8.1  Under the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its implementing rules, you have the following rights with respect to your personal data held by 91pht: