90gili Privacy Policy – How We Protect Your Data

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 90gili ("90gili," "we," "us," or "our") collects, processes, stores, and protects the personal information of individuals ("you," "Player," or "User") who access or use the 90gili online casino and sports betting platform, including all associated websites, mobile-optimised pages, and related services (collectively, the "Platform").

90gili is committed to protecting the privacy and personal data of all Filipino players in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines.

This Policy applies to all personal information collected through the Platform, whether provided directly by you, collected automatically through your use of the Platform, or obtained from third-party sources. It does not apply to third-party websites or services that may be linked from the Platform.

2. Information We Collect

90gili collects personal information that is necessary to provide you with a safe, secure, and personalised gaming experience. The categories of personal information we collect include:

2.1 Information You Provide Directly

• Registration Data: Full name, date of birth, gender, nationality, residential address (including barangay, city, and province), email address, and mobile number;
• Identity Verification (KYC) Documents: Copies of government-issued identification (e.g., Philippine passport, driver's licence, PhilSys National ID, SSS ID, UMID), proof of address documents, and payment method verification;
• Financial Information: GCash account details, PayMaya account details, bank account information (BPI, BDO, Metrobank, UnionBank), and transaction history;
• Communications: Messages, emails, and chat transcripts exchanged with our customer support team;
• Responsible Gaming Information: Deposit limits, self-exclusion requests, and cooling-off period preferences you set on the Platform.

2.2 Information Collected Automatically

• 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-stream data, search queries, and feature interactions;
• Location Data: General geographic location derived from your IP address (e.g., Metro Manila, Cebu, Davao, Quezon City);
• Cookies and Tracking Data: Information collected through cookies, web beacons, and similar tracking technologies as described in Section 6.

2.3 Information from Third Parties

• Identity verification data from KYC service providers;
• Fraud prevention and anti-money laundering screening data from compliance partners;
• Payment confirmation data from GCash, PayMaya, and banking partners.

3. How We Use Your Information

90gili uses the personal information we collect for the following purposes:

• Account Management: To create, verify, and manage your 90gili account, including processing your registration and maintaining your account profile;
• Service Delivery: To provide you with access to casino games, sports betting, live dealer games, and all other features of the 90gili Platform;
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, 7-Eleven, and Cebuana;
• Identity Verification: To verify your identity and age (21+) in compliance with applicable regulations and to prevent fraud;
• Legal Compliance: To comply with anti-money laundering (AML) obligations, PAGCOR regulatory requirements, and other applicable Philippine laws;
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance;
• Responsible Gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may need responsible gaming support;
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, account abuse, and other illegal activities;
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the 90gili Platform;
• Marketing Communications: To send you promotional offers, bonus notifications, and updates about new games or features, where you have consented to receive such communications.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 90gili processes your personal information on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., to provide the 90gili Platform services as described in our Terms & Conditions);
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations and PAGCOR licensing requirements;
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights;
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

5. Sharing of Personal Information

5.1 We Do Not Sell Your Data. 90gili does not sell, rent, or trade your personal information to third-party marketers or data brokers under any circumstances.

5.2 Service Providers. We may share your personal information with trusted third-party service providers who assist us in operating the Platform, including:

• KYC and identity verification providers;
• Payment processors and financial institutions (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank);
• Cloud hosting and data storage providers;
• Customer support platform providers;
• Fraud detection and cybersecurity service providers.

All third-party service providers are contractually required to process your personal information only as instructed by 90gili and to maintain appropriate security measures.

5.3 Regulatory and Legal Disclosure. 90gili may disclose your personal information to government authorities, law enforcement agencies, or regulatory bodies (including PAGCOR and the National Privacy Commission) where required by law, court order, or regulatory directive.

5.4 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of 90gili's assets, your personal information may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

6. Cookies and Tracking Technologies

6.1 What Are Cookies. Cookies are small text files placed on your device when you visit the 90gili Platform. They help us recognise your device, remember your preferences, and improve your overall experience.

6.2 Types of Cookies We Use.

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Performance Cookies: Collect anonymised data about how you use the Platform to help us improve its performance and identify technical issues.
• Functional Cookies: Remember your preferences (e.g., language settings, game history) to provide a more personalised experience.
• Analytics Cookies: Help us understand player behaviour and Platform usage patterns through aggregated, anonymised data.

6.3 Managing Cookies. You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 90gili Platform.

7. Data Retention

90gili retains your personal information for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by applicable law.

• Active Accounts: Personal information is retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years as required by Philippine AML regulations.
• KYC Documents: Identity verification documents are retained for five (5) years following account closure or the last transaction, whichever is later.
• Marketing Data: Where you have consented to marketing communications, we retain your contact details until you withdraw consent or request deletion.

Upon expiry of the applicable retention period, your personal information will be securely deleted or anonymised.

8. Data Security

90gili implements a comprehensive set of technical and organisational security measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and the 90gili Platform is protected using Transport Layer Security (TLS) encryption. Stored personal data is encrypted using AES-256 encryption;
• Access Controls: Access to personal data is restricted to authorised 90gili personnel on a strict need-to-know basis;
• Firewalls and Intrusion Detection: Our servers are protected by enterprise-grade firewalls and real-time intrusion detection systems;
• Regular Security Audits: We conduct regular security assessments and penetration testing to identify and remediate vulnerabilities;
• Incident Response: In the event of a personal data breach, 90gili will notify affected players and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by the DPA.

While we take all reasonable steps to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. You are also responsible for keeping your 90gili login credentials confidential.

9. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal information held by 90gili:

• Right to Be Informed: You have the right to be informed of how your personal data is collected, used, and processed, as described in this Policy;
• Right of Access: You may request a copy of the personal information 90gili holds about you at any time;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal information in your account;
• Right to Erasure: You may request deletion of your personal information where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests;
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the details provided in Section 14. We will respond to all verified requests within thirty (30) days.

10. Children's Privacy

The 90gili Platform is strictly intended for individuals who are at least twenty-one (21) years of age, consistent with Philippine regulations governing casino-style gaming. We do not knowingly collect personal information from individuals under the age of 21.

If we become aware that personal information has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal information, and report the matter to the appropriate authorities. If you believe a minor has registered on the 90gili Platform, please contact us immediately at [email protected].

11. International Data Transfers

90gili primarily stores and processes your personal information within the Philippines. In certain circumstances, your personal data may be transferred to and processed by our service providers located outside the Philippines (for example, cloud infrastructure providers).

Where such transfers occur, 90gili ensures that appropriate safeguards are in place to protect your personal information, including contractual data protection clauses that require the recipient to maintain standards equivalent to those required under the Philippine Data Privacy Act of 2012.

12. Third-Party Links

The 90gili Platform may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to the 90gili Platform and does not cover the privacy practices of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit, as 90gili has no control over and assumes no responsibility for their content or privacy practices.

13. Amendments to This Policy

90gili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. When material changes are made, we will notify registered players via email or a prominent notice on the Platform, and update the "Last Updated" date at the top of this page.

Your continued use of the 90gili Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the updated Policy, you must cease using the Platform and may request account closure by contacting our support team.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact the 90gili Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. For responsible gaming concerns, please visit our Responsible Gaming page.