1Introduction
93ph ("we," "us," or "our") operates the online gaming platform accessible at https://93ph.app (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, including registered players, visitors, and prospective users.
This Privacy Policy describes how 93ph collects, uses, stores, shares, and protects personal data in connection with the operation of the Platform. It applies to all personal data processed by 93ph, whether collected online through the Platform, through our customer support channels, or through any other means of interaction with 93ph.
This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (the "DPA"), and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.
2Personal Data We Collect
2.1 Information You Provide Directly
When you register for a 93ph account or interact with our Platform, we collect the following categories of personal data that you provide to us:
- Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification number (e.g., SSS, PhilHealth, UMID, passport number).
- Contact Data: Philippine mobile number, email address, and residential address (including city, province, and postal code).
- Account Data: Username, password (stored in hashed form), account preferences, and communication preferences.
- Financial Data: GCash number, PayMaya / Maya account details, bank account details (for bank transfer transactions), and transaction history. We do not store full debit card numbers on our servers.
- Verification Documents: Copies of government-issued photo ID, proof of address, and proof of payment method ownership, submitted for identity verification purposes.
- Communications Data: Records of your communications with 93ph customer support, including chat logs, emails, and call recordings where applicable.
2.2 Information Collected Automatically
When you access and use the 93ph Platform, we automatically collect certain technical and behavioral data, including:
- Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
- Usage Data: Pages visited, games played, session duration, click patterns, search queries within the Platform, and features used.
- Location Data: General geographic location derived from your IP address (country and city level). We do not collect precise GPS location data.
- Cookie and Tracking Data: Data collected through cookies, web beacons, and similar tracking technologies as described in Section 9 of this Privacy Policy.
2.3 Information from Third Parties
In certain circumstances, 93ph may receive personal data about you from third parties, including identity verification service providers, payment processors, fraud prevention services, and PAGCOR or other regulatory bodies where required by law.
3How We Collect Your Data
93ph collects your personal data through the following means:
- Direct interactions: When you complete the registration form, submit verification documents, make deposits or withdrawals, contact customer support, or participate in promotions.
- Automated technologies: Through cookies, server logs, and analytics tools as you navigate and use the Platform.
- Third-party sources: From identity verification providers, payment processors, and regulatory bodies as described in Section 2.3.
4Purposes of Processing Your Personal Data
93ph processes your personal data for the following purposes:
- Account Registration and Management: To create and manage your 93ph account, verify your identity and age (21+), and maintain accurate account records.
- Service Delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of 93ph platform features.
- Legal and Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws and regulations.
- Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform.
- Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
- Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
- Marketing and Promotions: To send you information about 93ph promotions, bonuses, and new features, where you have consented to receive such communications. You may opt out at any time.
- Platform Improvement: To analyze usage patterns, conduct research, and improve the performance, features, and user experience of the 93ph Platform.
5Legal Basis for Processing
Under the Data Privacy Act of 2012, 93ph processes your personal data on the following legal bases:
- Contractual Necessity: Processing is necessary to perform the contract between you and 93ph (i.e., to provide the gaming services you have registered for).
- Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself.
- Legitimate Interests: Processing is necessary for 93ph's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and interests.
- Consent: For certain processing activities, such as marketing communications, 93ph relies on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
6Sharing Your Personal Data
6.1 Third-Party Service Providers
93ph may share your personal data with carefully selected third-party service providers who assist us in operating the Platform. These include identity verification providers, payment processors (such as GCash and PayMaya / Maya), cloud hosting providers, customer support platforms, and analytics services. All third-party service providers are contractually required to process your data only on 93ph's instructions and in compliance with the Data Privacy Act.
6.2 Regulatory and Law Enforcement Authorities
93ph may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and other government authorities where required or permitted by Philippine law. This includes mandatory reporting obligations under the Anti-Money Laundering Act.
6.3 No Sale of Personal Data
93ph does not sell, rent, or trade your personal data to any third party for their own commercial or marketing purposes. Period.
7Data Retention
93ph retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:
- Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements.
- Financial and Transaction Data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
- Identity Verification Documents: Retained for the duration of your account and for five (5) years following account closure.
- Customer Support Records: Retained for three (3) years from the date of the interaction.
- Marketing Consent Records: Retained until you withdraw your consent, plus a reasonable period thereafter for compliance purposes.
When personal data is no longer required, 93ph will securely delete or anonymize it in accordance with our data disposal procedures.
8Data Security
93ph implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:
- SSL/TLS encryption for all data transmitted between your device and the 93ph Platform;
- Encryption of sensitive data at rest, including financial data and identity documents;
- Strict access controls ensuring that only authorized 93ph personnel can access personal data, on a need-to-know basis;
- Regular security assessments and penetration testing of the Platform;
- Multi-factor authentication requirements for account access;
- Secure, redundant data storage infrastructure hosted within compliant data centers.
8.1 Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 93ph will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required by the Data Privacy Act. Affected individuals will be notified without undue delay where the breach is likely to result in a high risk to their rights.
9Cookies and Tracking Technologies
9.1 What Are Cookies
Cookies are small text files placed on your device when you visit the 93ph Platform. They help us recognize your device, remember your preferences, and understand how you use our Platform. We also use similar technologies such as web beacons and local storage.
9.2 Types of Cookies We Use
- Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
- Functional Cookies: Remember your preferences such as language settings and game display options to provide a more personalized experience.
- Analytics Cookies: Help us understand how players use the Platform — which pages are visited most, where players encounter issues, and how we can improve. Data collected is aggregated and anonymized.
- Marketing Cookies: Used to deliver relevant promotional content about 93ph. These are only set with your consent.
9.3 Managing Cookies
You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the 93ph Platform. Strictly necessary cookies cannot be disabled as they are essential for the Platform to operate.
10Your Data Privacy Rights
Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 93ph:
- Right to be Informed: The right to be informed about how your personal data is collected and processed — which is the purpose of this Privacy Policy.
- Right of Access: The right to request a copy of the personal data 93ph holds about you, along with information about how it is being processed.
- Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
- Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
- Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
- Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
- Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that 93ph has violated your data privacy rights.
11Children's Privacy and Age Restriction
The 93ph Platform is strictly intended for individuals who are at least twenty-one (21) years of age, as required by Philippine gaming law. 93ph does not knowingly collect personal data from individuals under the age of 21.
If 93ph becomes aware that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, delete the personal data, and take appropriate action in accordance with our legal obligations. If you believe that a minor has registered on the 93ph Platform, please contact us immediately at the details provided in Section 13.
12Changes to This Privacy Policy
93ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. The date of the most recent revision is displayed at the top of this page.
When we make material changes to this Privacy Policy, we will notify registered players via email and/or through a prominent notice on the 93ph Platform prior to the changes taking effect. Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.
We encourage you to review this Privacy Policy periodically to stay informed about how 93ph protects your personal data.
13Contact Us and Data Protection Officer
93ph has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our DPO:
Email: [email protected]
General Support: [email protected]
Please include "Data Privacy Request" in the subject line of your email. We will acknowledge your request within five (5) business days and respond fully within thirty (30) days.
You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.
For responsible gaming concerns, please visit the 93ph Responsible Gaming page or include "Responsible Gaming" in your support email subject line.