90apiso Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") applies to all personal information collected by 90apiso ("the Company," "we," "us," "our") through the 90apiso online gaming platform accessible at 90apiso.app, including any associated applications, tools, and services.

1.2 90apiso is committed to protecting the privacy of all registered players, visitors, and users of its platform in accordance with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173), its implementing rules and regulations, and applicable PAGCOR compliance requirements.

1.3 By registering an account on 90apiso or by continuing to use the platform after this Policy has been made available, you acknowledge that you have read, understood, and consent to the data practices described herein. If you do not agree to this Policy, please discontinue use of the 90apiso platform and contact support to close your account.

1.4 This Policy should be read alongside the 90apiso Terms & Conditions and Responsible Gaming Policy, both of which contain additional provisions relevant to your use of the platform.

2. Data Controller Information

2.1 The data controller responsible for your personal information is 90apiso, operating the online gaming platform at 90apiso.app under applicable PAGCOR regulatory licensing for the Philippine market.

2.2 For all data privacy-related inquiries, requests, and complaints, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

2.3 90apiso has registered its data processing activities with the National Privacy Commission (NPC) of the Philippines as required under the Data Privacy Act of 2012 and its implementing rules.

3. Personal Data We Collect

3.1 90apiso collects personal information through several channels, including account registration, identity verification, financial transactions, platform usage, and customer support interactions.

3.2 Registration & Identity Data

• Full legal name as it appears on your government-issued Philippine ID;
• Date of birth (required to verify the 21+ age requirement);
• Philippine mobile number and email address;
• Residential address within the Philippines;
• Government-issued ID type and number (UMID, SSS, driver's license, Philippine passport, PhilSys National ID);
• Photograph or scan of your government-issued ID, submitted for KYC verification.

3.3 Financial & Transaction Data

• GCash mobile number and transaction reference numbers;
• PayMaya (Maya) account details used for deposits and withdrawals;
• Bank account details for BPI, BDO, or Metrobank withdrawals;
• USDT TRC20 wallet address (for crypto transactions);
• Complete transaction history including deposit amounts, withdrawal amounts, dates, and payment methods;
• Bonus and promotional credit history.

3.4 Platform Usage & Technical Data

• IP address and geolocation data at the time of login and gameplay;
• Device type, operating system, and browser version;
• Session data including login times, session duration, and logout events;
• Full game history including all bets placed, game results, and amounts wagered;
• Clickstream data and pages visited within the 90apiso platform.

3.5 Support & Communication Data

• Records of all customer support interactions via live chat and email;
• Complaint and dispute records;
• Responsible gaming self-exclusion requests and limit-setting history;
• Marketing preferences and communication opt-in/opt-out status.

4. How We Use Your Personal Data

4.1 90apiso processes personal data strictly for the following purposes:

• Account management: Creating, maintaining, and securing your 90apiso account;
• Identity verification (KYC): Confirming your identity and age (21+) as required by PAGCOR regulations and anti-money laundering laws;
• Payment processing: Facilitating deposits and withdrawals via GCash, PayMaya, bank transfer, and crypto channels;
• Fraud and security: Detecting, investigating, and preventing fraud, unauthorized account access, and money laundering;
• Regulatory compliance: Meeting obligations under PAGCOR licensing, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act;
• Customer support: Responding to your inquiries, resolving disputes, and providing technical assistance;
• Responsible gaming: Administering self-exclusion, deposit limits, and session controls at your request or in fulfillment of our duty of care obligations;
• Platform improvement: Analyzing aggregated usage data (anonymized where possible) to improve the 90apiso platform experience for Filipino players;
• Communications: Sending transactional notifications (deposit confirmations, withdrawal status, security alerts) and, where you have consented, promotional communications about 90apiso offers.

4.2 90apiso does not use your personal data for automated decision-making that produces legal effects without human oversight. Our fraud and security assessments involve human review of flagged cases.

5. Legal Basis for Processing

5.1 Under the Data Privacy Act of 2012, 90apiso processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill the 90apiso Terms & Conditions agreement you entered when registering — including account management, payment processing, and game history records;
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations, AMLA reporting requirements, KYC obligations, and NPC registration;
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your privacy rights;
• Consent: Processing for optional communications (promotional emails, SMS notifications) where you have explicitly opted in. You may withdraw consent at any time through your account settings.

6. Sharing Your Personal Data

6.1 90apiso does not sell, rent, or trade your personal data to third-party advertisers, data brokers, or marketing companies.

6.2 Your data may be shared with the following categories of third parties, strictly on a need-to-know basis and subject to confidentiality agreements:

• Payment processors: GCash (GXI), PayMaya (Maya Philippines), BPI, BDO, Metrobank, and other payment infrastructure providers — to process your transactions;
• Game software providers: Licensed game studios and live casino operators whose games are available on the 90apiso platform — limited to the data needed for game integrity and dispute resolution;
• Identity verification services: Third-party KYC and AML screening providers engaged to verify player identity documents;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, as required by law;
• IT and security providers: Cloud hosting, cybersecurity, and platform infrastructure providers operating under data processing agreements.

6.3 All third parties with whom 90apiso shares personal data are required by contract to: process data only for the specified purpose, implement appropriate technical and organizational security measures, and not further share the data without 90apiso's prior written authorization.

7. Data Retention

7.1 90apiso retains personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to mandatory retention periods under Philippine law.

7.2 The following retention periods apply:

• Account and KYC records: For the duration of your account plus 5 years following account closure, as required by PAGCOR and AMLA regulations;
• Financial transaction records: 5 years from the date of the transaction, in compliance with AMLA record-keeping requirements;
• Game history and session logs: 12 months from the date of each session;
• Customer support records: 3 years from the date of the interaction;
• Marketing consent records: Until consent is withdrawn, plus 1 year thereafter for compliance records.

7.3 Upon expiry of the applicable retention period, personal data is securely deleted or anonymized using industry-standard data destruction methods.

8. Data Security Measures

8.1 90apiso implements technical and organizational security measures designed to protect your personal data from unauthorized access, disclosure, alteration, and destruction, including:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 90apiso platform;
• Encryption of sensitive data at rest, including financial account details and identity documents;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security vulnerability assessments and penetration testing of platform infrastructure;
• Multi-factor authentication for all administrative access to systems holding player data;
• Incident response procedures compliant with the NPC's mandatory breach notification requirements.

8.2 In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 90apiso will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where required by law.

8.3 Notwithstanding the above measures, no system is entirely immune to security risks. 90apiso encourages all players to use strong, unique passwords, enable 2FA on their 90apiso account, and report any suspicious activity immediately to our support team.

9. Cookies & Tracking Technologies

9.1 The 90apiso platform uses cookies and similar tracking technologies to deliver and improve the platform experience. The following types of cookies are used:

• Essential cookies: Required for the platform to function — session authentication, security tokens, and load balancing. These cannot be disabled without impairing platform functionality;
• Functional cookies: Remembering your preferences such as language settings, game lobby layout, and notification preferences;
• Analytics cookies: Aggregated and anonymized data on how Filipino players navigate the platform, used to identify areas for improvement. 90apiso does not share raw analytics data with third parties;
• Security cookies: Fraud detection and bot prevention mechanisms that analyze interaction patterns to protect your account.

9.2 90apiso does not use third-party advertising cookies or tracking pixels for behavioral advertising. Your 90apiso activity is not shared with advertising networks.

9.3 You may manage cookie preferences through your browser settings. Disabling essential cookies may impair or prevent access to the 90apiso platform.

10. Your Data Privacy Rights

10.1 Under the Data Privacy Act of 2012, all 90apiso players have the following rights with respect to their personal data:

10.2 To exercise any of these rights, submit a written request to 90apiso's Data Protection Officer at the contact details provided in Section 14. 90apiso will respond within 15 business days of receiving a valid request. We may request supporting identification to verify your identity before processing the request.

10.3 If you are not satisfied with 90apiso's response to a data privacy request or complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Minors & Age Policy

11.1 The 90apiso platform is strictly intended for adults aged 21 years and above, in compliance with Philippine gambling regulations. 90apiso does not knowingly collect personal data from persons under 21 years of age.

11.2 If 90apiso discovers that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, any remaining balance forfeited, and all associated personal data deleted from our systems to the extent not required to be retained for regulatory or legal compliance purposes.

11.3 Parents and guardians who believe that a minor has registered on the 90apiso platform should contact our support team immediately. 90apiso takes underage gambling seriously and will act promptly on any verified report of an underage account.

12. Cross-Border Data Transfers

12.1 Some of 90apiso's service providers — including cloud infrastructure, game software providers, and certain payment processors — may be located outside the Republic of the Philippines. Where personal data is transferred to a foreign jurisdiction, 90apiso ensures that:

• The recipient country provides an adequate level of protection for personal data, or;
• Appropriate safeguards are in place through contractual clauses that comply with the NPC's standards for cross-border data transfers under the Data Privacy Act;
• The transfer is limited to what is strictly necessary for the specified processing purpose.

12.2 Players may request information about the specific safeguards in place for any cross-border transfer of their personal data by contacting the 90apiso DPO.

13. Policy Updates

13.1 90apiso may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or Philippine legal requirements. Material changes will be communicated to registered players via the email address on file or via notification within the account dashboard, with a minimum of seven (7) days' notice before the updated Policy takes effect.

13.2 The current version of this Policy, including the effective date, is always accessible at 90apiso.app/privacy-policy. Continued use of the 90apiso platform after the effective date of any update constitutes acceptance of the revised Policy.

14. Contact & Data Protection Officer

14.1 For all privacy-related inquiries, data subject access requests, and complaints, please contact the 90apiso Data Protection Officer:

• Email: [email protected] (subject line: "Data Privacy Request")
• Live Chat: Available 24/7 within your 90apiso account dashboard
• Response Time: Within 15 business days for formal written requests
• Languages: Filipino and English

14.2 For unresolved privacy complaints, Filipino players may also contact the National Privacy Commission (NPC) of the Philippines, the independent government body responsible for enforcing the Data Privacy Act of 2012.