Privacy Policy

1. Introduction

This Privacy Policy describes how 91pht (referred to as "we," "us," "our," or the "Company") collects, uses, processes, stores, shares, and protects personal information obtained from users (referred to as "you," "your," or "Player") of our online gaming platform accessible at 91pht.cam (the "Platform" or "Website"). We are committed to protecting your privacy and ensuring the security of your personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its implementing rules and regulations, and relevant international data protection standards including the General Data Protection Regulation (GDPR) principles where applicable.

By accessing the 91pht Platform, creating an account, depositing funds, placing bets, or otherwise using our services, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with any aspect of this Privacy Policy, you must immediately discontinue use of the Platform and refrain from providing any personal information to us.

This Privacy Policy applies to all users of the 91pht Platform, including registered players, visitors browsing the Website, and individuals who interact with our customer support services. This Policy should be read in conjunction with our Terms and Conditions, which govern the overall use of the Platform and incorporate this Privacy Policy by reference.

2. Data Controller Information

For the purposes of applicable data protection laws, 91pht acts as the data controller responsible for the collection, processing, and protection of your personal information. As data controller, we determine the purposes and means of processing your personal data and are accountable for compliance with applicable privacy laws and regulations.

Our commitment to data protection includes implementing appropriate technical and organizational measures to ensure the security of personal information, training our staff on privacy and data protection obligations, conducting regular privacy impact assessments, and maintaining transparency about our data processing activities. We have designated internal personnel responsible for overseeing data protection compliance and responding to privacy-related inquiries and requests from users.

3. Information We Collect

91pht collects various categories of personal information necessary to provide gaming services, comply with legal and regulatory obligations, prevent fraud, and improve user experience. The specific types of information we collect include:

4. How We Use Your Information

91pht processes your personal information for specific, legitimate purposes that are necessary for the provision of gaming services, compliance with legal obligations, and protection of our legitimate business interests. The legal bases for processing your personal data and the specific purposes include:

4.1 Contract Performance and Service Provision

We process your personal information to fulfill our contractual obligations to you as outlined in the Terms and Conditions. This includes creating and maintaining your player account, processing deposits and withdrawals, facilitating gameplay across casino games and sports betting markets, crediting winnings to your account balance, administering bonuses and promotions, and providing customer support services. Without this information, we cannot provide gaming services to you.

4.2 Legal and Regulatory Compliance

We are required by Philippine law and PAGCOR regulations to collect and retain certain personal information to verify player identity, confirm age eligibility (minimum 21 years), prevent money laundering and terrorist financing, detect and prevent fraud, maintain transaction records for audit purposes, report suspicious activities to relevant authorities, and comply with tax reporting obligations. These legal obligations take precedence and we cannot offer services to individuals who refuse to provide information necessary for compliance purposes.

4.3 Fraud Prevention and Platform Security

We process personal data to protect the integrity of the Platform and safeguard both the Company and legitimate players from fraudulent activities. This includes monitoring for multiple accounts, detecting collusion between players, identifying stolen payment methods, preventing bonus abuse, analyzing betting patterns for suspicious activity, implementing account security measures such as two-factor authentication, and maintaining secure systems infrastructure.

4.4 Service Improvement and Personalization

Based on legitimate business interests and with your consent where required, we analyze user behavior and preferences to improve the Platform, develop new games and features, personalize game recommendations, optimize user interface and experience, conduct market research and analytics, and measure the effectiveness of marketing campaigns. You may opt out of certain data processing for personalization purposes through your account settings without affecting your ability to use core gaming services.

4.5 Marketing and Promotional Communications

With your explicit consent, we use your contact information to send promotional offers, bonus notifications, new game announcements, VIP program updates, and other marketing communications via email, SMS, push notifications, or in-platform messages. You retain the right to withdraw consent and unsubscribe from marketing communications at any time without affecting your ability to use the Platform for gaming purposes.

4.6 Responsible Gaming Support

We process personal data to fulfill our responsible gaming obligations, including enforcing self-exclusion requests, monitoring for problematic gambling behaviors, implementing deposit and loss limits you have set, providing access to gambling support resources, and complying with mandatory player protection requirements under Philippine gaming regulations.

5. Information Sharing and Disclosure

91pht does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your personal data with carefully selected third parties under specific circumstances and with appropriate safeguards in place:

5.1 Service Providers and Business Partners

We engage third-party service providers to perform functions on our behalf, including payment processing companies (GCash, PayMaya, banks, cryptocurrency processors), game providers and software developers, customer support platform providers, identity verification services, cloud hosting and data storage providers, email and SMS communication services, analytics and data processing services, and marketing and advertising partners. These service providers have access to personal information only to the extent necessary to perform their specific functions and are contractually obligated to maintain confidentiality and security of your data.

5.2 Legal and Regulatory Authorities

We disclose personal information to regulatory bodies, law enforcement agencies, courts, and other governmental authorities when required by law, in response to valid legal process (subpoenas, court orders, regulatory requests), to investigate or prevent fraud or criminal activity, to enforce our Terms and Conditions, to protect our rights and property, or to ensure player safety and responsible gaming compliance. We may also report suspicious transactions to the Anti-Money Laundering Council (AMLC) as required by Philippine law.

5.3 Business Transfers

In the event of a merger, acquisition, corporate reorganization, sale of assets, or bankruptcy proceedings involving 91pht, your personal information may be transferred to the acquiring or successor entity. We will notify affected users of any such transfer and any choices you may have regarding your personal information in such circumstances.

5.4 With Your Consent

We may share your personal information with third parties when you have provided explicit consent for such sharing. You retain the right to withdraw such consent at any time by contacting our customer support team.

6. Data Security Measures

91pht implements comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security infrastructure includes:

6.1 Technical Security Controls

All data transmitted between your device and our servers is encrypted using industry-standard SSL/TLS 256-bit encryption protocols. Personal information stored in our databases is encrypted at rest using advanced encryption standards. We maintain secure server infrastructure with firewalls, intrusion detection systems, and regular security audits. Access to personal data is restricted to authorized personnel only through role-based access controls and strong authentication mechanisms including two-factor authentication for administrative access.

6.2 Organizational Security Measures

We conduct regular employee training on data protection obligations and security best practices. All staff with access to personal information are bound by confidentiality agreements. We perform background checks on employees in sensitive positions. Regular security audits and vulnerability assessments are conducted by internal teams and independent third-party security experts. We maintain incident response procedures to quickly identify and mitigate any potential data breaches.

6.3 Payment Security

We comply with Payment Card Industry Data Security Standard (PCI DSS) requirements where applicable. Payment information is processed through secure, encrypted channels. We do not store complete credit card numbers or cryptocurrency private keys on our servers. All financial transactions are monitored for suspicious activity using advanced fraud detection systems.

7. Data Retention and Storage

91pht retains your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory retention requirements, and resolve disputes or enforce our agreements. Specific retention periods include:

7.1 Active Account Data

While your account remains active, we retain all personal information, transaction history, and gaming records necessary to provide services and comply with ongoing regulatory obligations.

7.2 Closed Account Data

Following voluntary account closure or termination, we retain personal information and transaction records for a minimum of five (5) years to comply with Philippine anti-money laundering regulations, tax laws, and potential legal claims. Identity verification documents may be retained for up to seven (7) years as required by financial services regulations.

7.3 Marketing Communications

If you opt out of marketing communications, we will retain only the minimum information necessary to honor your opt-out request and prevent future unwanted communications.

7.4 Data Deletion

Upon expiration of applicable retention periods and absent any legal obligation to retain data longer, we securely delete or anonymize personal information using industry-standard data destruction methods. Anonymized data that cannot be linked back to individual users may be retained indefinitely for statistical and research purposes.

9. Cookies and Tracking Technologies

The 91pht Platform uses cookies and similar tracking technologies to enhance user experience, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device that enable certain platform functionality and allow us to recognize your device on subsequent visits.

9.1 Types of Cookies We Use

Essential Cookies: Necessary for basic platform functionality including login authentication, session management, and security features. These cannot be disabled without affecting platform operations.

Performance Cookies: Collect information about how users interact with the Platform, including pages visited, time spent, and navigation patterns. This data helps us improve platform performance and user experience.

Functional Cookies: Enable enhanced functionality such as remembering your preferences, language settings, and personalized content display.

Marketing Cookies: Used to deliver relevant advertisements and track the effectiveness of marketing campaigns. These cookies may be set by our advertising partners and require your consent.

9.2 Managing Cookie Preferences

You can control cookie settings through your browser configuration. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies may prevent you from using certain platform features. You can adjust your marketing cookie preferences through our cookie consent management tool accessible from the Platform footer.

10. Third-Party Services

The 91pht Platform may contain links to third-party websites, services, or applications not operated by us. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of any third-party services before providing personal information to them. This Privacy Policy applies only to information collected by 91pht through our Platform.

11. Children's Privacy

The 91pht Platform is not intended for use by individuals under twenty-one (21) years of age. We do not knowingly collect personal information from minors. If we become aware that a user is underage, we will immediately terminate their account and delete all associated personal information in accordance with applicable law. Parents or guardians who believe their child has provided personal information to 91pht should contact us immediately at [email protected].

12. Changes to This Privacy Policy

91pht reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Material changes will be communicated to registered users via email notification sent to your registered email address or through prominent notice displayed on the Platform. The updated Privacy Policy will include a revised "Last Updated" date at the top of the document. Your continued use of the Platform following notification of changes constitutes acceptance of the modified Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us through the following channels:

Email: [email protected]
Live Chat: Available 24/7 through your player account dashboard
Customer Support: Accessible via Viber and in-platform messaging

For formal data protection inquiries or to exercise your privacy rights, please clearly indicate "Privacy Request" in your communication subject line. We will respond to all legitimate privacy requests within thirty (30) days of receipt.