93ph Privacy Policy

This Privacy Policy is issued by 93ph, the operator of the online gaming platform accessible at 93ph.club. For the purposes of Republic Act 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, 93ph acts as the Personal Information Controller (PIC) with respect to the personal data of its registered users, site visitors, and other individuals whose data is processed through the platform.

As a PAGCOR-regulated online gaming operator serving Filipino players across the Philippines — including Metro Manila, Cebu, Davao, the Visayas, Mindanao, and all other regions — 93ph's data processing activities are conducted within Philippine jurisdiction and governed by Philippine law.

This Policy should be read in conjunction with the 93ph Terms & Conditions, which govern your use of the platform, and the Responsible Gaming Policy. By using 93ph, you acknowledge that you have read and understood this Privacy Policy.

93ph collects different categories of personal data depending on how you interact with the platform. The following table summarizes the categories and specific data points collected:

93ph does not collect or process sensitive personal information as defined under RA 10173 (including racial or ethnic origin, political opinions, religious beliefs, health records, or sexual orientation) unless specifically required for a regulatory compliance purpose and with your explicit consent.

93ph collects personal data through the following channels and methods:

• Direct submission at registration: When you create a 93ph account, you directly provide identity, contact, and account data through the registration form;
• KYC document submission: You submit identity documents and selfie photographs through the secure KYC verification portal within your account settings;
• Payment transactions: When you initiate a deposit or withdrawal via GCash, PayMaya, or bank transfer, financial data is collected through the payment processing flow;
• Automated platform interaction: Technical data (IP address, device information, session logs, geolocation) is automatically collected as you browse and interact with the 93ph platform;
• Customer support communications: When you contact 93ph support via live chat or email, your communications and the details you provide are recorded;
• Cookies and similar tracking technologies: As described in Section 7 of this Policy, certain data is collected automatically through cookies and browser storage mechanisms;
• Third-party verification services: During KYC processing, identity data may be cross-referenced against government databases or third-party identity verification providers operating under appropriate data processing agreements.

Under the Data Privacy Act of 2012 and its Implementing Rules, 93ph must have a lawful basis for each category of personal data processing. The following legal bases apply to 93ph's data processing activities:

• Contractual necessity: Processing required to fulfil 93ph's obligations under the user agreement — including account management, payment processing, and game delivery — is lawful as necessary for the performance of the contract between you and 93ph;
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), AMLC reporting requirements, tax obligations, and court orders is conducted on the basis of legal obligation;
• Legitimate interests: Processing for fraud prevention, security monitoring, platform improvement, and abuse detection is conducted on the basis of 93ph's legitimate interests, balanced against your privacy rights;
• Consent: Marketing communications and non-essential cookies are processed only where you have provided explicit, informed, and freely given consent at the point of collection. Consent may be withdrawn at any time without prejudice to the lawfulness of prior processing;
• Vital interests: In exceptional circumstances involving responsible gaming interventions or player safety, processing may be conducted to protect a vital interest of the data subject.

93ph uses the personal data we collect for the following specified, explicit, and legitimate purposes:

• Account creation and management: Registering your account, authenticating your identity at login, managing your profile settings, and maintaining your account history;
• KYC and identity verification: Verifying your identity and age (21+ as required by PAGCOR), conducting enhanced due diligence where required, and maintaining KYC records as mandated by regulation;
• Payment processing: Processing deposits via GCash, PayMaya, and bank transfer, executing withdrawal requests, and maintaining accurate financial records;
• Game delivery and platform operation: Delivering the games and services you use, recording game sessions and outcomes as required by PAGCOR, and maintaining platform integrity;
• Regulatory and legal compliance: Fulfilling PAGCOR reporting obligations, AMLC covered and suspicious transaction reporting, responding to lawful requests from Philippine government authorities, and maintaining records required by law;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling indicators, enforcing deposit limits and self-exclusion requests, and administering PAGCOR's responsible gaming framework;
• Fraud and security: Detecting and preventing unauthorized account access, payment fraud, multi-accounting, bonus abuse, and other prohibited conduct;
• Customer support: Responding to your queries, resolving disputes, and maintaining support records;
• Platform improvement: Analyzing aggregated usage data to improve user experience, optimize game library selection, and develop new features;
• Marketing (consent-based only): Sending promotional offers, bonus notifications, and other marketing communications where you have explicitly opted in.

93ph does not sell, rent, or trade your personal data to third parties for their independent marketing or commercial purposes. We share personal data with third parties only in the following circumstances and categories:

• Payment service providers: GCash (GXI), PayMaya (Maya Bank), BPI, BDO, Metrobank, and Dragonpay receive the minimum data necessary to process your deposit and withdrawal transactions. These providers operate under their own privacy policies and applicable Philippine financial regulations;
• KYC and identity verification partners: Third-party identity verification services engaged by 93ph receive the KYC documents you submit. These partners operate under strict data processing agreements and are engaged solely for verification purposes;
• Game software providers: Providers including JILI, PG Soft, Pragmatic Play, Evolution Gaming, and others receive anonymized or pseudonymized session data necessary for game delivery and RTP audit purposes. Full identity data is not shared with game providers;
• Regulatory and government authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other competent Philippine government authorities may receive your data where 93ph is subject to a legal obligation to disclose;
• Technology and infrastructure providers: Cloud hosting, cybersecurity, analytics, and communications technology providers engaged by 93ph may process data on our behalf as Personal Information Processors (PIP) under contractual data processing agreements that require compliance with RA 10173;
• Business transfers: In the event of a merger, acquisition, or sale of substantially all of 93ph's assets, personal data may be transferred to the acquiring entity subject to equivalent privacy protections. Affected users will be notified in accordance with RA 10173 requirements.

All third parties with whom 93ph shares personal data are required to handle that data securely, use it only for the specified purpose, and comply with applicable Philippine and international data protection standards.

93ph uses cookies and similar browser-based storage technologies to support platform functionality and, where you have consented, to understand how you interact with the platform. The following categories of cookies may be active on 93ph.club:

• Strictly necessary cookies: Required for the platform to function, including session management, login authentication, security tokens, and shopping cart or bet slip functionality. These cannot be disabled without breaking core platform features;
• Functional cookies: Remember your preferences such as language settings, display preferences, and last-visited game categories to improve your experience across sessions;
• Analytics cookies: Collect aggregated, anonymized data about how visitors use the platform — which pages are visited, session duration, click patterns — to help 93ph improve the user experience. These are only active with your consent;
• Marketing cookies: Track whether you have engaged with 93ph promotions and, where consented, support the delivery of relevant promotional communications. These are only active with your explicit consent.

93ph does not use cookies or tracking technologies to collect sensitive personal information or to build profiles sold to external advertising networks.

93ph retains personal data for the minimum period necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by applicable law. The following retention schedule applies as a general guide:

Following the expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification. Anonymized aggregate data may be retained indefinitely for statistical purposes.

93ph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include, but are not limited to:

• Encryption in transit: All data transmitted between your browser and the 93ph platform is encrypted using TLS (Transport Layer Security). The presence of the HTTPS protocol and browser padlock icon confirms active encryption;
• Encryption at rest: Personal data and financial records stored on 93ph servers are encrypted at the storage level using industry-standard encryption algorithms;
• Tokenization of payment data: GCash account references, PayMaya identifiers, and bank account details are stored in tokenized form. Raw payment credentials are never stored in plaintext on 93ph systems;
• Password hashing: Account passwords are stored as salted cryptographic hashes using industry-standard algorithms. 93ph staff cannot read or retrieve your password in plaintext;
• Access controls: Access to personal data held by 93ph is restricted to staff and contractors with a legitimate operational need. Role-based access controls and multi-factor authentication are required for all administrative access;
• Security monitoring: 93ph maintains 24/7 automated monitoring for unauthorized access attempts, unusual activity patterns, and potential security incidents;
• Regular security reviews: The 93ph platform undergoes periodic security assessments and vulnerability testing to identify and remediate potential weaknesses.

Under Republic Act 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by 93ph. You may exercise these rights by submitting a written request to the 93ph Data Protection Officer (DPO) using the contact details in Section 16 of this Policy.

93ph will respond to data rights requests within thirty (30) calendar days of receipt. Complex requests may require additional time, in which case 93ph will notify you of the extended timeline and reason within the initial 30-day period.

The 93ph platform is strictly an adults-only service. PAGCOR regulations require that all players be a minimum of 21 years of age. The platform is not directed at, intended for, or designed to attract persons under 21 years of age.

93ph does not knowingly collect personal data from persons under 21. All new accounts are required to complete KYC verification that includes government-issued photo ID confirming age. If 93ph discovers or is informed that an account was created by a person under 21, the account will be immediately suspended, KYC documents will be deleted, and the net deposited amount will be returned to the payment source. Winnings derived from underage play are forfeited.

Some of the technology service providers engaged by 93ph — including cloud infrastructure providers and certain game software platforms — may process or store data in jurisdictions outside the Philippines. Where personal data is transferred outside the Philippines, 93ph ensures that appropriate safeguards are in place to protect the data in accordance with RA 10173 and NPC guidance on cross-border data transfers.

These safeguards may include contractual data processing agreements incorporating standard contractual clauses approved by the National Privacy Commission, verification that the recipient jurisdiction offers an adequate level of data protection, or other mechanisms recognized under applicable Philippine data protection law.

93ph does not transfer personal data to recipients who cannot demonstrate adequate data protection standards consistent with the requirements of RA 10173.

In the event of a personal data breach — meaning any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data processed by 93ph — the following protocol applies:

• Internal containment: The 93ph security team will immediately work to contain the breach, assess its scope, and prevent further unauthorized access;
• Breach assessment: The nature, volume, and sensitivity of the data involved will be assessed, along with the likely consequences for affected individuals;
• NPC notification: Where a breach is likely to give rise to a real risk of serious harm to data subjects, 93ph will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03 and subsequent guidance;
• Individual notification: Where a breach is likely to result in high risk to your rights and freedoms, 93ph will notify you directly via your registered email address without undue delay, providing a description of the breach, the data involved, the likely consequences, and the measures being taken.

93ph maintains an incident response plan and conducts regular breach preparedness reviews. Breach notifications will be communicated clearly and without unnecessary alarm, with specific guidance on any protective steps you should take.

The 93ph platform may display or link to third-party content including game provider interfaces, payment gateways, and embedded tools. These third-party elements operate under their own privacy policies and are independent personal information controllers with respect to the data they collect directly.

93ph is not responsible for the privacy practices of third-party platforms, services, or websites accessible through or integrated with the 93ph platform. We encourage you to review the privacy notices of any third-party services you interact with, including your GCash app, PayMaya account, and bank's online banking portal, as these services collect your data under their own terms.

Where 93ph embeds third-party game content, those game providers may collect technical session data necessary for game delivery. 93ph's contracts with game providers require them to handle such data in compliance with applicable data protection law and prohibit them from using session data for independent marketing purposes.

93ph reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or platform features. The effective date at the top of this page will be updated to reflect the date of the most recent revision.

Where amendments are material — meaning they substantially affect your rights or how your personal data is processed — 93ph will provide advance notice via email to your registered address or through a prominent notification on the platform at least fourteen (14) days before the changes take effect.

Minor amendments (such as typographical corrections, clarifications that do not change the substance of the Policy, or changes required by updated NPC guidance) may be published without individual advance notice. Your continued use of the 93ph platform after an updated Policy takes effect constitutes acceptance of the revised terms. If you do not accept an amendment, you should cease using the platform and contact support regarding account closure.

93ph has designated a Data Protection Officer (DPO) in accordance with Section 21 of RA 10173 and its Implementing Rules. The DPO is responsible for overseeing 93ph's data protection program, ensuring compliance with RA 10173, and serving as the primary point of contact for data subjects exercising their rights and for the National Privacy Commission.

To exercise your data rights, report a privacy concern, request a copy of this Policy in an accessible format, or contact the 93ph DPO for any data protection matter, please use the following contact information: