Privacy Policy – 91 Club
Welcome to 91 Club’s Privacy Policy. At 91 Club, we are deeply committed to protecting your privacy and ensuring transparency in how we handle your personal information. This Privacy Policy outlines the practices we follow regarding the collection, use, disclosure, storage, and safeguarding of your data when you use our website, mobile application, and services. We believe that your trust is essential, and we handle your information with the utmost care and responsibility.
By accessing and using 91 Club, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with any aspect of this policy, please refrain from using our services.
Information We Collect
Personal Information
When you register with 91 Club or use our services, we may collect the following types of personal information:
- Name and Contact Information: Full name, email address, and phone number provided during registration
- Address and Identification: Residential address, postal code, and identification documents (PAN, Aadhaar) for verification and KYC compliance
- Payment Information: Bank account details, UPI IDs, digital wallet information, and transaction history for deposits and withdrawals
- Age Verification Data: Date of birth and age confirmation for regulatory compliance (users must be 18+)
- Government Identification: Government-issued ID documents for identity verification and anti-money laundering (AML) compliance
Device and Technical Information
We automatically collect certain information about your device and usage patterns:
- Device Identifiers: IP address, device type, operating system, browser type, and unique device identifiers
- Device Information: Hardware model, mobile network information, and device settings
- Geolocation Data: Approximate location based on IP address to ensure compliance with regional regulations
Usage and Behavioral Data
To improve our services and personalise your experience, we collect the following:
- Gameplay Data: Games played, time spent on each game, betting patterns, and results
- Navigation Data: Pages visited, features accessed, time spent on the platform, and clicks
- Transaction Data: Deposit amounts, withdrawal requests, bonus claims, and transaction timestamps
- Analytics Data: User interactions, session duration, and engagement patterns
Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance your experience:
- Session Cookies: Enable login functionality and maintain your session across the platform
- Preference Cookies: Remember your settings, language preferences, and account customizations
- Analytics Cookies: Track website performance and user behavior for improvement purposes
- Third-Party Cookies: Used by advertising partners for analytics and marketing (only with consent)
You can manage cookie preferences through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent.
Communication Data
When you contact us or communicate through the platform, we collect:
- Messages, emails, and chat transcripts sent to customer support
- Complaint and feedback submissions
- Responses to surveys and questionnaires
Information from Third Parties
In limited circumstances, we may receive information from:
- Payment processors and financial institutions for transaction verification
- Identity verification services for KYC and regulatory compliance
- Fraud detection agencies for security purposes
How We Use Your Information
Provision and Improvement of Services
- Provide, operate, and maintain our gaming platform and services
- Process your registration, account setup, and profile management
- Facilitate deposits, withdrawals, and financial transactions
- Deliver customer support and respond to enquiries.
- Improve, personalize, and expand our website and app features
- Conduct analytics to understand user behavior and preferences
Compliance and Legal Obligations
- Verify your identity and age (18+ requirement)
- Comply with anti-money laundering (AML) and Know Your Customer (KYC) regulations
- Adhere to Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
- Comply with the Digital Personal Data Protection Act (DPDPA), 2023
- Respond to legal requests from regulatory authorities
- Maintain records for tax and financial regulatory compliance
Security and Fraud Prevention
- Detect, prevent, and address fraudulent transactions and unauthorized access
- Verify account ownership and legitimacy
- Monitor for suspicious activity and gaming patterns
- Protect against hacking, malware, and security breaches
- Enforce our terms of service and legal agreements
Communication and Marketing
- Send you transactional emails (registration, password reset, withdrawal confirmation)
- Notify you about account updates, security alerts, and important policy changes
- Provide customer support and resolve issues
- Send promotional offers and bonuses (only with your consent)
- Conduct surveys to gather feedback
Personalization and Experience Enhancement
- Customize your gaming experience based on preferences and history
- Recommend games and features aligned with your interests
- Provide targeted bonuses and promotions relevant to your profile
- Improve website functionality and user interface
Legal Basis for Data Processing
Consent
We process your personal data based on your explicit, informed, and unconditional consent obtained during registration. You can withdraw consent at any time, though this may affect your ability to use certain features.
Contractual Necessity
Processing your data is necessary to fulfil our service agreement with you, including account creation, payment processing, and customer support.
Legal Obligation
We process data to comply with legal requirements under Indian laws, including the Information Technology Act, 2000, and regulatory mandates.
Legitimate Interest
We process data for security, fraud prevention, and platform improvement, balancing our interests with your privacy rights.
Data Sharing and Disclosure
Third-Party Service Providers
91 Club may share your information with trusted third-party service providers who assist in providing our services:
- Payment Processors: UPI providers, Paytm, bank transfer services, and digital wallet companies for transaction processing
- Identity Verification Services: Third-party KYC providers for age and identity verification
- Security and Fraud Prevention Companies: Providers specializing in fraud detection and account security
- Hosting and Infrastructure Providers: Cloud service providers hosting our platform
- Analytics Providers: Google Analytics and similar tools for understanding user behavior
These service providers are contractually bound to use your data only for the purposes specified and to maintain strict confidentiality.
Legal Compliance and Regulatory Requests
We may disclose your information when:
- Required by law, court order, or regulatory authority
- Responding to legal proceedings or subpoenas
- Enforcing our terms of service and protecting our rights
- Preventing fraud or protecting public safety
Business Transfers
In the event of a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that business transaction. We will provide notice of any such change and any choices you may have regarding your information.
Non-Sale of Personal Data
91 Club does NOT sell your personal data to third parties for marketing purposes. We do not trade or lease your information to unrelated companies. Any data sharing is strictly limited to service provision, legal compliance, and security purposes.
Data Security and Protection
Security Infrastructure
91 Club employs advanced security measures to protect your personal data:
- SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using industry-standard SSL/TLS protocols
- Firewalls: Multi-layered firewalls protect our servers from unauthorized access and cyber attacks
- Data Encryption: Personal and financial data is encrypted both in transit and at rest
- Access Controls: Strict access controls limit employee access to sensitive data
Security Audits and Compliance
- Regular Security Audits: We conduct periodic third-party security audits to identify vulnerabilities
- Compliance Updates: Our systems are regularly updated to comply with the latest security standards
- Penetration Testing: We perform penetration testing to simulate attacks and strengthen defenses
- Incident Response Plan: We maintain protocols for responding to any security breaches
Limitations of Security
While we implement robust security measures, no system is 100% secure. Data transmission over the internet or electronic storage always carries inherent risks. We cannot guarantee absolute security, and you acknowledge these risks when using our platform.
Data Retention Period
Retention Policy
We retain your personal data only for as long as necessary to fulfil the purposes described in this policy:
- Active Account Data: While your account is active, we retain all gameplay, transaction, and verification data
- Legal Compliance: We retain data as required by tax laws, financial regulations, and anti-money laundering requirements (typically 7 years)
- Dispute Resolution: Data related to disputes and complaints is retained for the duration of legal proceedings
- Fraud Investigation: Data involved in fraud cases is retained for investigation and prosecution purposes
Data Deletion
Once data is no longer required:
- Personally identifiable information is securely deleted or anonymised.
- You may request data deletion (subject to legal retention requirements) via 91clubgamesapp@gmail.com
- We will confirm deletion within 30 days
Your Privacy Rights and Choices
Right to Access
You have the right to request and access all personal data we hold about you. Submit requests to 91clubgamesapp@gmail.com with “Data Access Request” in the subject line. We will provide your data in a portable, machine-readable format within 30 days.
Right to Rectification
If your personal data is inaccurate or incomplete, you have the right to request corrections. Update your information directly through your account settings or contact support for assistance.
Right to Erasure (Right to Be Forgotten)
You can request deletion of your personal data, subject to:
- Legal and regulatory retention requirements
- Ongoing disputes or investigations
- Active contractual obligations
To request erasure, contact 91clubgamesapp@gmail.com with details of the information you wish deleted.
Right to Restrict Processing
You can request that we limit how we use your data while we resolve disputes or clarify your wishes. During restriction periods, we will retain your data but limit its processing.
Right to Object
You have the right to object to:
- Processing based on legitimate interests
- Direct marketing and promotional communications
- Automated decision-making and profiling
To object, email 91clubgamesapp@gmail.com with “Objection to Processing” in the subject line.
Data Portability
You can request your data in a structured, commonly used, machine-readable format to transfer to another service provider. Submit portability requests to support with “Data Portability Request”. We will comply within 30 days.
Withdraw Consent
You can withdraw consent to data processing at any time. However, withdrawal doesn’t affect the lawfulness of processing before withdrawal or affect services that don’t require consent.
Children and Minors’ Data Protection
Age Restriction
91 Club is exclusively available to individuals 18 years of age or older. We do not knowingly collect data from minors.
Special Protections for Minors
If we become aware that data from a minor has been collected:
- We will immediately delete such information
- We will notify parents/guardians of the breach
- Appropriate action will be taken to prevent future violations
Parental Consent Requirements
If a minor’s data is discovered, we require parental/guardian consent for any processing. Parents can verify their minor’s information and request deletion via 91clubgamesapp@gmail.com.
Behavioral Monitoring Restrictions
- Behavioral monitoring or profiling of minors
- Targeted advertising aimed at minors
- Data processing that could harm a minor’s well-being
International Data Transfers
Data Transfer Practices
91 Club primarily operates within India, but data may be stored on servers in India or other compliant jurisdictions. We ensure all transfers comply with Indian data protection laws.
Cross-Border Transfer Restrictions
Under the Digital Personal Data Protection Act, 2023:
- We only transfer data to countries approved by the Indian government
- Transfers are subject to equivalent data protection safeguards
- We maintain updated transfer agreements
Cookies and Tracking Technologies
Types of Cookies
91 Club uses the following types of cookies:
- Necessary Cookies: Enable core platform functionality, login, and security
- Performance Cookies: Analyze how users interact with the platform for improvement
- Preference Cookies: Remember user settings and language preferences
- Targeting/Marketing Cookies: Used for personalized promotions (only with consent)
Cookie Management
You can control cookies through:
- Browser Settings: Most browsers allow you to refuse cookies or delete existing ones
- Cookie Consent Tool: Adjust cookie preferences through our consent management platform on first visit
- Opt-Out Links: Unsubscribe from marketing cookies through preference centre.
Note: Disabling necessary cookies may affect platform functionality.
Tracking Technologies
- Pixel Tags: Track email opens and link clicks
- Web Beacons: Monitor page visits and user engagement
- Analytics Scripts: Google Analytics and similar tools
Third-Party Links and External Services
Third-Party Websites
91 Club may contain links to third-party websites and services. We are NOT responsible for the privacy practices of external websites. This Privacy Policy applies only to 91 Club. We recommend reviewing privacy policies of external sites before sharing information.
Third-Party Service Integration
When you interact with third-party services (payment gateways, identity verification):
- Their privacy policies govern their data handling practices
- We verify they maintain comparable security and privacy standards
- You consent to their terms when accessing their services
Do Not Track Requests
Some browsers include Do Not Track (DNT) features. We honor DNT signals where applicable, though we currently don’t alter our tracking practices based on DNT headers. Users can opt-out through cookie preferences or browser settings.
Changes to Privacy Policy
Policy Updates
91 Club may update this Privacy Policy periodically to reflect regulatory changes, platform updates, or operational improvements. Significant changes will be communicated via email or prominent platform notification.
Continued Use as Acceptance
Your continued use of 91 Club after policy updates constitutes your acceptance of the revised terms. If you disagree with changes, you should discontinue use of the platform.
Effective Date
- Current Policy Effective Date: November 09, 2025
- Last Updated: November 09, 2025
Contact Information and Data Protection Officer
Privacy Inquiries
For questions or concerns about this Privacy Policy, data handling practices, or to exercise privacy rights:
Email: 91clubgamesapp@gmail.com
Subject Line: “Privacy Policy Inquiry” or “Data Request”
Response Time: 24-48 business hours
Live Chat Support
Access privacy support 24/7 through the app or website live chat feature.
Complaint Resolution
If you’re unsatisfied with our data practices, you can:
- Submit a formal complaint to our Data Protection Officer via email
- Escalate to the Ministry of Electronics and Information Technology, Government of India
- File a complaint under the Digital Personal Data Protection Act, 2023
Compliance with Applicable Laws
- Information Technology Act, 2000
- Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
- Digital Personal Data Protection Act (DPDPA), 2023
- Sensitive Personal Data or Information (SPDI) Rules, 2011
- Reserve Bank of India (RBI) guidelines on payment security
- Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance requirements
Glossary of Terms
- Personal Data: Information that can identify you directly or indirectly (name, email, IP address, etc.)
- Data Fiduciary: An entity deciding the purpose and means of personal data processing (91 Club)
- Data Processor: An entity processing data on behalf of the Data Fiduciary (service providers)
- Consent: Your free, specific, informed, unconditional agreement to data processing
- Processing: Any operation on data including collection, storage, use, deletion
FAQs – Privacy Policy & Data Protection
How Does 91 Club Protect My Personal Data?
91 Club uses military-grade SSL/TLS encryption, firewalls, access controls, and regular security audits to protect your data. All personal and financial information is encrypted both in transit and at rest to ensure maximum security.
Will 91 Club Sell My Personal Information to Third Parties?
How Long Does 91 Club Retain My Personal Data?
We retain your data only as long as necessary—active account data is kept during your membership, legal compliance data for 7 years per regulations, and dispute-related data during investigations. You can request data deletion subject to legal retention requirements.
What Privacy Rights Do I Have Under Indian Law?
You have the right to access, rectify, erase, restrict processing, object, and port your data under the Digital Personal Data Protection Act, 2023. Submit requests to 91clubgamesapp@gmail.com, and we’ll respond within 30 days.
Is My Data Safe From Hackers and Cyber Attacks?
While 91 Club employs advanced security measures, including encryption, firewalls, and penetration testing, no system is 100% secure. We maintain incident response protocols and conduct regular audits to minimise risks and respond quickly to any breaches.
Conclusion
At 91 Club, we believe that transparency, security, and respect for your privacy are fundamental to building trust. This Privacy Policy reflects our commitment to protecting your personal information while providing you with engaging gaming experiences.
We continuously review and strengthen our data protection practices to meet evolving regulatory standards and user expectations. Your privacy rights are important to us, and we remain accountable for how we handle your data.
Thank you for trusting 91 Club with your personal information. If you have any questions or concerns about our privacy practices, please don’t hesitate to contact us.