Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") governs the collection, processing, storage, use, and disclosure of personal information by 93gl ("Company", "we", "us", "our") in connection with your use of our website located at https://93gl.cam and all related services, applications, and features (collectively, the "Service"). This Policy applies to all users, visitors, and players ("you", "User", "Player") who access or interact with our platform.

93gl is committed to protecting the privacy and security of your personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and all applicable Philippine data protection regulations. By accessing our website, creating an account, or using our services, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy.

This Policy should be read in conjunction with our Terms and Conditions, which govern your use of the 93gl Service. If you do not agree with the terms of this Privacy Policy, you must immediately discontinue use of our platform and refrain from providing any personal information to 93gl.

2. Information We Collect

2.1 Personal Information You Provide

When you register for a 93gl account, 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 (passport number, driver's license number, or national ID number).
• Contact Information: Email address, mobile phone number, residential address, and postal code.
• Financial Information: Bank account details, GCash account information, Maya account information, payment card details (card number, expiration date, CVV), transaction history, deposit and withdrawal records.
• Verification Documents: Copies of government-issued photo identification, utility bills, bank statements, or other documents submitted for identity verification and age confirmation purposes.
• Account Credentials: Username, password, security questions and answers, and two-factor authentication settings.
• Communication Records: Content of messages sent through our customer support channels, live chat transcripts, email correspondence, and feedback submissions.

2.2 Information Automatically Collected

When you access and use the 93gl platform, we automatically collect certain technical and usage information through cookies, web beacons, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), mobile network information.
• Usage Data: Pages visited, features accessed, games played, time spent on platform, click patterns, navigation paths, referral sources.
• Location Data: IP address, geographic location derived from IP address, time zone settings.
• Gaming Activity: Betting patterns, game preferences, win/loss records, bonus claims, wagering history, session duration.
• Technical Data: Log files, error reports, system diagnostics, performance metrics, API interactions.

2.3 Information from Third-Party Sources

93gl may receive information about you from third-party sources including payment processors (GCash, Maya, banks), identity verification services, fraud prevention agencies, credit reference agencies, and publicly available databases. This information helps us verify your identity, prevent fraud, and comply with legal obligations including anti-money laundering (AML) and know-your-customer (KYC) requirements.

3. How We Use Your Information

93gl processes your personal information for the following legitimate purposes:

3.1 Account Management and Service Provision

• Create, maintain, and manage your 93gl player account.
• Verify your identity, age, and eligibility to use our gaming services.
• Process deposits, withdrawals, and other financial transactions.
• Provide access to games, betting markets, and platform features.
• Track gaming activity, balances, and transaction history.
• Manage bonuses, promotions, and loyalty program participation.

3.2 Legal and Regulatory Compliance

• Comply with Philippine gaming regulations and licensing requirements.
• Fulfill anti-money laundering (AML) and know-your-customer (KYC) obligations.
• Prevent underage gambling and verify age eligibility (21+ requirement).
• Detect, investigate, and prevent fraud, money laundering, and other illegal activities.
• Respond to legal processes, court orders, and requests from law enforcement or regulatory authorities.
• Maintain records as required by law and regulatory guidelines.

3.3 Security and Fraud Prevention

• Monitor accounts for suspicious activity, unusual betting patterns, or Terms violations.
• Detect and prevent unauthorized account access, identity theft, and payment fraud.
• Implement security measures including two-factor authentication and encryption protocols.
• Investigate complaints, disputes, and Terms violations.
• Protect the integrity of our platform and ensure fair play for all users.

3.4 Customer Support and Communications

• Respond to inquiries, support requests, and feedback through live chat, email, or phone.
• Send transactional notifications regarding deposits, withdrawals, bonuses, and account activity.
• Provide important updates about platform changes, service interruptions, or Terms modifications.
• Deliver promotional communications about new games, special offers, and events (with your consent).

3.5 Platform Improvement and Analytics

• Analyze usage patterns to improve platform functionality, user experience, and game selection.
• Conduct research and statistical analysis to understand player preferences and behavior.
• Test new features, games, and technologies before full deployment.
• Optimize platform performance for Philippine internet infrastructure (Globe, Smart, PLDT).

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 93gl processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations to provide gaming services under the Terms and Conditions you accepted upon registration.
• Legal Obligation: Processing is required to comply with Philippine laws, gaming regulations, AML/KYC requirements, and other legal obligations imposed on licensed gaming operators.
• Legitimate Interests: Processing serves our legitimate business interests in preventing fraud, ensuring platform security, improving services, and conducting business operations, provided such interests do not override your fundamental rights.
• Consent: For certain optional processing activities such as marketing communications and non-essential cookies, we rely on your explicit consent which may be withdrawn at any time.

5. Information Sharing and Disclosure

5.1 Service Providers and Business Partners

93gl engages trusted third-party service providers to support platform operations. These providers may access your personal information solely for the purposes of performing services on our behalf and are contractually obligated to maintain confidentiality and security. Service providers include:

• Payment Processors: GCash, Maya (PayMaya), banks, and other payment service providers that facilitate deposits and withdrawals.
• Identity Verification Services: Third-party vendors that verify identity documents and conduct age verification checks.
• Game Providers: JILI, Pragmatic Play, Evolution Gaming, and other game suppliers whose content is integrated into our platform.
• Cloud Infrastructure Providers: Hosting services and cloud storage providers that maintain our technical infrastructure.
• Customer Support Tools: Live chat software providers and customer relationship management (CRM) platforms.
• Security and Fraud Prevention: Cybersecurity firms and fraud detection services that help protect our platform and users.

5.2 Legal and Regulatory Authorities

We may disclose your personal information to Philippine government authorities, regulatory bodies, law enforcement agencies, and courts when legally required or necessary to:

• Comply with court orders, subpoenas, or legal processes.
• Respond to requests from gaming regulators or licensing authorities.
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC) as required by law.
• Cooperate with law enforcement investigations of illegal activity.
• Protect our legal rights, property, or safety, or that of our users or the public.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy involving 93gl, your personal information may be transferred to the acquiring entity or successor organization. We will notify you of any such transfer and any choices you may have regarding your information.

5.4 With Your Consent

We may share your information with third parties when you provide explicit consent for such disclosure, such as participating in joint promotions with partners or authorizing information sharing for specific purposes.

5.5 No Sale of Personal Information

93gl does not sell, rent, or trade your personal information to third parties for their marketing purposes. Any data sharing is conducted solely for the operational, legal, and security purposes described in this Policy.

6. Data Security Measures

93gl implements comprehensive technical, physical, and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. Our security practices include:

6.1 Technical Safeguards

• Encryption: All data transmission between your device and our servers uses industry-standard 256-bit SSL/TLS encryption, the same technology employed by major Philippine banks.
• Secure Storage: Personal information is stored on encrypted servers protected by firewalls and intrusion detection systems.
• Access Controls: Multi-factor authentication, role-based access restrictions, and principle of least privilege limit employee access to personal data.
• Security Monitoring: 24/7 monitoring systems detect and respond to potential security incidents in real-time.
• Regular Testing: Penetration testing, vulnerability assessments, and security audits are conducted regularly by independent security firms.

6.2 Organizational Safeguards

• Employee Training: All 93gl staff receive mandatory data privacy and security training.
• Confidentiality Agreements: Employees and contractors sign confidentiality agreements obligating them to protect user information.
• Incident Response: Documented procedures govern our response to data breaches and security incidents.
• Vendor Management: Third-party service providers undergo security assessments and are contractually required to maintain adequate security measures.

6.3 Payment Security

Financial transactions are processed through PCI DSS compliant payment gateways. 93gl does not store complete credit card numbers or CVV codes on our servers. Payment card information is tokenized and processed by certified payment processors that maintain the highest security standards.

7. Data Retention

93gl retains your personal information for as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our Terms. Specific retention periods include:

Data Category	Retention Period	Legal Basis
Account Information	Duration of active account + 5 years after closure	Gaming regulations, AML compliance
Financial Records	7 years from transaction date	Tax laws, financial reporting requirements
Identity Documents	5 years after account closure	KYC/AML regulations
Gaming Activity Logs	5 years from activity date	Gaming regulatory requirements
Marketing Communications	Until consent withdrawn + 30 days	Consent-based processing
Customer Support Records	3 years from last interaction	Quality assurance, dispute resolution

After the applicable retention period expires, personal information is securely deleted or anonymized such that it can no longer identify you. In cases where complete deletion is not technically feasible, we implement measures to prevent further processing and ensure the information remains secure.

8. Cookies and Tracking Technologies

93gl uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device that help us recognize you on return visits and remember your preferences.

8.1 Types of Cookies We Use

• Essential Cookies: Required for platform functionality including authentication, security, and transaction processing. These cannot be disabled without affecting platform usability.
• Performance Cookies: Collect anonymous usage data to help us understand how players interact with our platform and identify areas for improvement.
• Functionality Cookies: Remember your preferences such as language settings, favorite games, and display options to provide a personalized experience.
• Marketing Cookies: Track your activity across websites to deliver relevant advertisements and measure campaign effectiveness. These require your consent and can be disabled.

8.2 Managing Cookie Preferences

You can manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, though this may impact platform functionality. To learn more about managing cookies, visit your browser's help section. Note that disabling essential cookies may prevent you from accessing certain platform features or completing transactions.

9. Your Privacy Rights

Under the Data Privacy Act of 2012 and related Philippine regulations, you have the following rights regarding your personal information:

9.1 Right to Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of the data we hold about you. Access requests will be fulfilled within thirty (30) days of verification of your identity.

9.2 Right to Rectification

If personal information we hold about you is inaccurate, incomplete, or outdated, you have the right to request correction or updating of such information. Most account information can be updated directly through your 93gl dashboard.

9.3 Right to Erasure

You may request deletion of your personal information in certain circumstances, such as when the data is no longer necessary for the purposes collected or you withdraw consent for processing based on consent. However, we may retain certain information where required by law, for regulatory compliance, or to resolve disputes.

9.4 Right to Object

You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. Marketing communications can be opted out via the unsubscribe link in emails or through account settings.

9.5 Right to Data Portability

You may request a copy of your personal data in a structured, commonly used, and machine-readable format to facilitate transfer to another service provider where technically feasible.

9.6 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal.

9.7 Exercising Your Rights

To exercise any of these rights, contact our Data Protection Officer via email at [email protected] with "Privacy Rights Request" in the subject line. We may request additional information to verify your identity before processing your request. Most requests are fulfilled within thirty (30) days, though complex requests may require up to sixty (60) days with notification of the extension.

10. Children's Privacy

93gl services are strictly intended for individuals aged 21 years and older in compliance with Philippine gambling regulations. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected information from someone under the legal age, we will immediately delete such information and permanently close the associated account.

Parents and guardians are encouraged to monitor their children's internet usage and prevent minors from accessing online gambling platforms. If you believe a minor has provided personal information to 93gl, please contact us immediately at [email protected] so we can take appropriate action.

11. International Data Transfers

Your personal information is primarily processed and stored within the Philippines. However, certain service providers and technical infrastructure may be located in other jurisdictions. When personal data is transferred outside the Philippines, we ensure appropriate safeguards are in place such as standard contractual clauses, adequacy decisions, or other legally recognized transfer mechanisms to protect your information in accordance with Philippine data protection standards.

12. Changes to This Privacy Policy

93gl reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Material changes will be communicated through email notification to registered users or by posting a prominent notice on our website. The "Last Updated" date at the top of this Policy indicates when the most recent revision occurred.

Your continued use of 93gl services following notification of Privacy Policy changes constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically to stay informed about how we protect your personal information.

13. Contact Information and Complaints

If you have questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

93gl Data Protection Officer
Email: [email protected]
Subject Line: Data Privacy Inquiry

We are committed to resolving privacy concerns promptly and will respond to inquiries within seven (7) business days. If you are not satisfied with our response, you have the right to file a complaint with the National Privacy Commission of the Philippines:

National Privacy Commission
5th Floor, Philippine International Convention Center
Vicente Sotto Street, Pasay City 1307, Philippines
Email: [email protected]
Website: www.privacy.gov.ph