Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by 91phk Casino ("we," "us," "our," "the Company") through our website located at https://91phk.cam, mobile applications, and any other digital platforms or services we operate (collectively, the "Platform"). This Privacy Policy covers information collected from users located in the Philippines and other jurisdictions where our services are available. We are committed to complying with applicable data protection laws, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

As a responsible online gaming operator serving the Filipino market, 91phk Casino recognizes the importance of protecting the personal information entrusted to us by our players. We implement industry-standard security measures, limit data collection to what is necessary for providing our services, and maintain transparency about our data practices. This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of the Platform and form part of your agreement with 91phk Casino.

2. Information We Collect

2.1 Information You Provide Directly

When you register for an account with 91phk Casino, we collect personal information that you voluntarily provide, including but not limited to:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification details (Philippine driver's license, passport, UMID, PhilSys ID, etc.)
• Contact Information: Email address, mobile phone number, residential address (street, barangay, city/municipality, province, postal code)
• Account Credentials: Username, password (stored in encrypted/hashed form), and security questions/answers
• Financial Information: Payment method details including GCash mobile number, Maya account information, bank account details (account number, bank name, account holder name), cryptocurrency wallet addresses, and transaction history
• Verification Documents: Copies of government-issued identification, proof of address documents (utility bills, bank statements), selfie photos for identity verification, and payment method verification documentation
• Communication Records: Content of messages sent to customer support, chat transcripts, email correspondence, and feedback or survey responses

2.2 Information Collected Automatically

When you access or use the 91phk Casino Platform, we automatically collect certain technical and usage information, including:

• Device Information: Device type (smartphone, tablet, desktop computer), operating system and version (iOS, Android, Windows, macOS), browser type and version, screen resolution, device identifiers (IMEI, advertising ID where permitted)
• Connection Information: IP address, internet service provider, connection type (WiFi, mobile data), approximate geographic location derived from IP address (city/region level, not precise GPS coordinates)
• Usage Data: Pages viewed, games played, bet amounts and outcomes, session duration, navigation patterns, features used, buttons clicked, timestamps of activities
• Performance Data: Page load times, errors encountered, crash reports, application performance metrics
• Referral Information: Website or source that referred you to 91phk Casino, marketing campaign parameters

2.3 Information from Third-Party Sources

In certain circumstances, we may receive information about you from third-party sources, including:

• Payment Processors: Transaction confirmation, payment status, fraud risk assessments from GCash, Maya, banks, and other payment service providers
• Identity Verification Services: Results of background checks, identity authentication, sanctions screening, and fraud prevention checks
• Marketing Partners: Information about your interactions with marketing campaigns or affiliate websites (where you have consented to such sharing)
• Social Media: If you choose to link your social media accounts, we may receive basic profile information in accordance with your privacy settings on those platforms

3. How We Use Your Information

91phk Casino uses the personal information we collect for the following purposes:

3.1 Account Management and Service Provision

• Creating and maintaining your gaming account
• Verifying your identity and age (21+ requirement) to comply with Philippine gambling regulations
• Processing deposits, withdrawals, and other financial transactions
• Providing access to games, betting markets, and other Platform features
• Maintaining accurate transaction records and account history
• Enabling you to participate in promotions, bonuses, and loyalty programs
• Calculating and awarding VIP tier benefits based on your gaming activity

3.2 Customer Support and Communication

• Responding to your inquiries, complaints, and support requests
• Sending transactional notifications (deposit confirmations, withdrawal updates, account alerts)
• Providing important service announcements and policy updates
• Conducting customer satisfaction surveys and collecting feedback
• Resolving disputes and investigating complaints

3.3 Security, Fraud Prevention, and Compliance

• Detecting and preventing fraud, money laundering, and other illegal activities
• Identifying multiple accounts or bonus abuse attempts
• Monitoring for suspicious betting patterns or collusion
• Complying with Philippine Anti-Money Laundering Act (AMLA) requirements
• Responding to legal requests from law enforcement or regulatory authorities
• Enforcing our Terms & Conditions and protecting our rights and property
• Maintaining platform security and protecting against cyber attacks

3.4 Marketing and Promotional Activities

• Sending promotional offers, bonus notifications, and special event announcements (where you have consented)
• Personalizing game recommendations and promotions based on your preferences
• Conducting marketing analytics to understand player preferences and improve campaigns
• Displaying targeted advertisements on our Platform or through third-party advertising networks (where permitted)

3.5 Platform Improvement and Analytics

• Analyzing usage patterns to improve user experience and platform functionality
• Testing new features and optimizing existing ones
• Conducting research and statistical analysis (using aggregated, anonymized data)
• Optimizing mobile app performance and fixing technical issues
• Understanding which games and features are most popular with Filipino players

3.6 Responsible Gaming

• Monitoring gambling behavior for signs of problem gambling
• Enforcing deposit limits, loss limits, and session time reminders you have set
• Implementing self-exclusion requests and cooling-off periods
• Providing access to responsible gaming resources and support

4. Legal Basis for Processing Personal Data

Under the Philippine Data Privacy Act and international data protection principles, we process your personal information based on the following legal grounds:

4.1 Contractual Necessity

Processing is necessary to perform our contract with you (the Terms & Conditions you agreed to when registering). This includes account creation, transaction processing, game provision, and customer support.

4.2 Legal Obligation

Processing is required to comply with Philippine laws and regulations, including age verification requirements, anti-money laundering obligations, tax reporting duties, and responding to lawful requests from authorities.

4.3 Legitimate Interests

Processing is necessary for our legitimate business interests, including fraud prevention, platform security, improving our services, and marketing (where not overridden by your privacy rights). We balance these interests against your privacy rights.

4.4 Consent

For certain processing activities, such as marketing communications and optional analytics, we rely on your explicit consent. You can withdraw consent at any time by contacting us or using the unsubscribe mechanism provided.

5. Information Sharing and Disclosure

91phk Casino does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information in the following limited circumstances:

5.1 Service Providers

We share information with trusted third-party service providers who perform services on our behalf, including:

• Payment Processors: GCash, Maya, banks, and other financial institutions to process deposits and withdrawals
• Game Providers: Pragmatic Play, JILI Gaming, PG Soft, Evolution Gaming, and other suppliers to enable gameplay
• Identity Verification Services: Third-party KYC/AML providers to verify identity and screen for fraud
• Cloud Hosting Services: Infrastructure providers that host our servers and databases
• Customer Support Tools: Live chat software and ticketing systems
• Analytics Providers: Services that help us understand platform usage and performance
• Email Service Providers: Platforms used to send transactional and marketing emails

All service providers are bound by confidentiality agreements and are only permitted to use your information for the specific purposes we authorize.

5.2 Legal Requirements and Protection

We may disclose your information when required by law or when we believe disclosure is necessary to:

• Comply with court orders, subpoenas, or other legal processes
• Respond to lawful requests from law enforcement or regulatory authorities
• Enforce our Terms & Conditions and protect our rights, property, or safety
• Protect the rights, property, or safety of our users or the public
• Investigate and prevent fraud, money laundering, or other illegal activities
• Comply with Philippine Anti-Money Laundering Council (AMLC) reporting requirements

5.3 Business Transfers

If 91phk Casino is involved in a merger, acquisition, asset sale, bankruptcy, or other business transaction, your information may be transferred to the acquiring entity as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

5.4 With Your Consent

We may share your information with third parties when you have provided explicit consent for such sharing, such as when participating in co-branded promotions or linking third-party services to your account.

6. Data Security Measures

91phk Casino implements comprehensive technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

6.1 Technical Security Controls

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL/TLS encryption, the same technology used by banks
• Secure Storage: Personal information stored in our databases is encrypted at rest using industry-standard encryption algorithms
• Password Protection: Your password is hashed and salted using strong cryptographic functions; we never store passwords in plain text
• Firewalls and Intrusion Detection: Our systems are protected by firewalls and monitored 24/7 for suspicious activity
• Regular Security Audits: We conduct regular vulnerability assessments and penetration testing
• Secure Development Practices: Our software development follows security best practices including code reviews and security testing

6.2 Access Controls and Monitoring

• Access to personal information is restricted to authorized employees who need the information to perform their job functions
• All access to systems containing personal data is logged and monitored
• Employees undergo background checks and sign confidentiality agreements
• Multi-factor authentication is required for administrative access to sensitive systems
• We implement the principle of least privilege, granting minimum necessary access rights

6.3 Limitations of Security

While we implement strong security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your information. You also play a role in security by maintaining the confidentiality of your password, using unique passwords not shared with other websites, enabling two-factor authentication, and promptly notifying us of any unauthorized account access.

7. Data Retention and Storage

7.1 Retention Periods

91phk Casino retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law:

• Active Accounts: Account information is retained for the duration of your account activity plus seven (7) years after account closure to comply with legal obligations
• Transaction Records: Financial transaction records are retained for seven (7) years as required by Philippine anti-money laundering regulations
• Identity Verification Documents: KYC documents are retained for seven (7) years after account closure for regulatory compliance
• Gaming History: Bet and game records are retained for seven (7) years to support dispute resolution and regulatory audits
• Communications: Customer support records are typically retained for three (3) years
• Marketing Consent: Marketing preferences are retained until you withdraw consent or your account is closed

7.2 Data Storage Location

Your personal information is stored on secure servers located in jurisdictions with adequate data protection laws. We may transfer and store your information outside the Philippines where our service providers operate secure data centers. All international transfers comply with applicable data protection requirements and are protected by appropriate safeguards.

7.3 Data Deletion

When personal information is no longer needed for the purposes for which it was collected and legal retention periods have expired, we securely delete or anonymize the information. Deletion methods include overwriting data, physical destruction of storage media, and removal from all backups and archives.

8. Your Privacy Rights

Under the Philippine Data Privacy Act, you have certain rights regarding your personal information held by 91phk Casino:

8.1 Right to Access

You have the right to request a copy of the personal information we hold about you. You can access much of this information directly through your account dashboard. For additional information, contact our customer support team with your request.

8.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly through your account settings. For information you cannot change yourself (such as name or date of birth), contact us with supporting documentation.

8.3 Right to Erasure

You have the right to request deletion of your personal information in certain circumstances. However, this right is subject to legal retention requirements. We must retain certain information for seven years to comply with Philippine anti-money laundering and gaming regulations. After applicable retention periods expire, we will delete your information upon request.

8.4 Right to Object and Restriction

You have the right to object to processing of your personal information for direct marketing purposes. You can opt out of marketing emails by clicking the unsubscribe link in any marketing message or adjusting your communication preferences in your account settings. You may also request restriction of processing in certain circumstances.

8.5 Right to Data Portability

You have the right to receive personal information you provided to us in a structured, commonly used, machine-readable format, and to transmit that information to another controller where technically feasible.

8.6 Right to Withdraw Consent

Where we process your information based on consent, you have the right to withdraw that consent at any time. This does not affect the lawfulness of processing based on consent before withdrawal. You can withdraw marketing consent using unsubscribe links or by contacting us.

8.7 Right to Lodge a Complaint

You have the right to lodge a complaint with the Philippine National Privacy Commission if you believe we have violated your privacy rights. However, we encourage you to contact us first so we can address your concerns directly.

8.8 Exercising Your Rights

To exercise any of these rights, please contact our Data Protection Officer using the contact information provided in Section 14 of this Privacy Policy. We will respond to your request within thirty (30) days as required by Philippine law. We may need to verify your identity before processing certain requests to protect your personal information from unauthorized access.

9. Cookies and Tracking Technologies

91phk Casino uses cookies and similar tracking technologies to enhance your experience on our Platform, analyze usage patterns, and deliver personalized content. A cookie is a small text file stored on your device that helps us recognize you and remember your preferences.

9.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly, including maintaining your login session, security features, and load balancing
• Functional Cookies: Remember your preferences such as language selection, display settings, and favorite games
• Analytics Cookies: Help us understand how users interact with the Platform by collecting anonymous usage data (pages viewed, time spent, navigation paths)
• Marketing Cookies: Used to deliver relevant advertisements and track campaign effectiveness (only with your consent)

9.2 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. However, disabling cookies may affect your ability to use certain features of the 91phk Platform. You can delete cookies stored on your device at any time through your browser settings.

9.3 Third-Party Tracking

Third-party service providers (such as analytics tools and advertising networks) may also place cookies on your device when you use our Platform. These cookies are governed by the privacy policies of the respective third parties. We do not control third-party cookies and recommend reviewing the privacy policies of our partners.

10. Third-Party Services and Links

The 91phk Casino Platform may contain links to third-party websites, services, or applications (such as payment processors, game providers, or social media platforms). This Privacy Policy does not apply to third-party services, and we are not responsible for their privacy practices. When you click on a link to a third-party website, you leave our Platform and become subject to that third party's privacy policy. We encourage you to read the privacy policies of any third-party services you use.

Game providers integrated into the 91phk Platform (such as Pragmatic Play, JILI Gaming, Evolution Gaming) may collect their own usage data when you play their games. This collection is governed by the game provider's privacy policy, and we recommend reviewing their policies if you have concerns about data collection during gameplay.

11. Children's Privacy

91phk Casino services are strictly intended for individuals who are at least twenty-one (21) years of age. We do not knowingly collect, maintain, or use personal information from anyone under the age of 21. If we become aware that we have inadvertently collected information from a person under 21 years of age, we will immediately delete that information from our systems and close any associated account.

Parents or guardians who believe their child has provided personal information to 91phk Casino should contact us immediately using the information provided in Section 14. We take underage gambling prevention very seriously and implement robust age verification measures, including document verification during the KYC process, to ensure compliance with Philippine law requiring players to be 21+ years old.

12. International Data Transfers

Your personal information may be transferred to and processed in countries other than the Philippines, including locations where our service providers operate data centers. These countries may have different data protection laws than the Philippines. When we transfer your information internationally, we ensure appropriate safeguards are in place to protect your data, including:

• Transferring only to countries recognized as providing adequate data protection
• Implementing standard contractual clauses approved by data protection authorities
• Ensuring service providers commit to protecting your data with security measures equivalent to those required by Philippine law
• Limiting international transfers to what is necessary for service provision

By using 91phk Casino services, you consent to the transfer of your information as described in this Privacy Policy.

13. Changes to Privacy Policy

91phk Casino reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform features. When we make material changes, we will notify you by:

• Sending an email notification to the email address registered on your account
• Displaying a prominent notice on the Platform homepage
• Requiring you to acknowledge the updated Privacy Policy upon your next login

We will provide notice at least seven (7) days before material changes take effect (except where changes are required immediately by law or for security reasons). Your continued use of 91phk Casino services after the effective date of the updated Privacy Policy constitutes acceptance of the changes. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. The "Last Updated" date at the top of this page indicates when the Privacy Policy was most recently revised.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or how 91phk Casino handles your personal information, please contact us:

• Data Protection Inquiries: Contact our customer support team via the live chat feature available 24/7 on the Platform, or send your inquiry to the email address displayed in the website footer
• Privacy Rights Requests: To exercise your privacy rights (access, correction, deletion, objection, etc.), contact our support team with the subject line "Privacy Rights Request" and include your account username and specific request details
• General Support: For account-related questions, technical support, or other non-privacy inquiries, use the live chat feature or email support channels available on the Platform

We aim to respond to all privacy-related inquiries within thirty (30) days as required by Philippine law. For complex requests, we may extend this period by an additional thirty (30) days and will notify you of any such extension.