Privacy Policy


Last changed: 28.02.2024, Version 4.0.0

This Privacy Policy sets out how 91 Club will manage your personal data, which will be collected as a result of your use of our services and the website or any other pages under 91 Club brand including any electrical device or app that are owned and/or operated by us. 91 Club is committed to ensuring that the personal data we collect about you is protected and is used, stored and disclosed in accordance with the applicable regulation. For your information, your personal data will be collected by:

Raw Entertainment B.V., a company duly incorporated under the laws of Curaçao with Company number 157205, and registered office at Fransche Bloemweg 4, Curaçao.


By accessing or registering an account at the website, you consent for Raw Entertainment B.V. to collect, use, process and disclose your personal information with third party providers and other entities of Raw Entertainment B.V. group, as long as such information is crucial / essential for the provision of the services that you using on the website.


When using our services we collect the following data:

a) Personal Data: Full Name, Date of Birth, Country of Citizenship, Permanent Address, Identification Document, Utility Bill, Phone Number and Email Address.

b) Usage Data: Location Data, Device Information, IP Address, Submitted Preferences, browser type and browser version.

c) Public Data: Social media profile you might use on our platform such as Facebook, Twitter, TikTok and Instagram.

During the use of the services, you might be requested to provide additional personal information. In such event you will be informed of the purpose of such collection and the collected information will be treated in accordance with the terms set on this Policy.


We collect your personal that through the following means:

a) Registration on the website;

b) Use of the website and our services;

c) Communications with Support Team;

d) Use of Cookies (please view our Cookies Policy for further information);

e) Participation on campaigns and promotions;

f) Through third parties that you have authorised to share your personal information with us.

If you do not provide us with the personal data we request, we may be unable to process your registration and provide you with our services or respond to your enquiries or complaints.


We collect your personal data only through lawful means and in respect for the applicable regulation, for the following purpose:

a) Register and operate your account;

b) Provide services to you;

c) Improve and enhance your experience in the website;

d) Conduct marketing campaigns and promotions;

e) Send you marketing communications and that we think may be of interesting to you;

f) Perform marketing research and data analysis (demographic profiling, statistical analysis, etc) to improve our services;

g) Provide your support and clarify you questions, doubts or comments;

h) Identify you (Know Your Customer);

i) Establish, exercise or defend against any legal claims.

j) Comply with legal requirements and requests;

If you have any doubts regarding the purpose of the collection of any personal data, please contact our Support Team.


We will store your data in accordance with the applicable regulation and the purpose that the same was collected for. This means that depending on the purpose or which the that was collected the time that will store your personal data will change. For example, for compliance with anti-money laundering regulation, we need to store your data for 10 years after you close your account.


We acknowledge through collecting and processing your personal information for the purposes of providing services to you, we are bound by the applicable data protection regulation. Accordingly, will take all reasonable steps to ensure that your personal information is stored in a secure environment which is accessed only by authorised persons. We store the personal information we receive as described in this Privacy Policy for as long as you use our services or as necessary to fulfill the purposes for which it was collected.


If you have given your consent, we will use your personal data to inform you about our products, services, campaigns, promotions and other 91 Club activities that might benefit you. If you no longer wish to receive marketing communications, please contact our Support Team or press the “unsubscribe” button on the marketing e-mails.


We might collect Cookies that contain personal information. Such Cookies will be treated in accordance with this Policy. For more information about Cookies, please view our Cookies Policy for further information.


Under this Policy you have the right to:

a) Access – You have the right to request for copies of your personal data that we have stored.

b) Rectify – You have the right to request us to correct any of your personal information you believe is inaccurate or incomplete.

c) Erase – You have the right to request us to erase your personal data, under certain conditions.

d) Restrict – You have the right to request us to restrict the processing of your personal data, as long as it does not makes impossible to continue the provision our services.

e) Object – You have the right to object to the processing of your personal data, as long as it does not makes impossible to continue the provision our services.

f) Portability – You have the right to request us to transfer your personal data that we have collected to another organization, or directly to you, as long as this requests complies with the applicable regulation.

All the rights mentioned above can be exercise through contacting our Support Team. Please note that we may ask you to verify your identity before responding to such requests.


As a worldwide business we might need to transfer your data to other countries in order to provide the services you use on the Website. When transferring your personal data to any country or provider, we will do our best efforts to ensure that the transfer of your personal information to the recipient is compliant with applicable data protection regulation and that the same obligations are imposed on the processor as is imposed on us under the respective Services Agreement.


We do not sell or rent your personal data to third parties. However, we may disclose your personal information to third parties in the following cases:

a) If imposed by law or requested by any government authority;

b) If the provision of the personal information is mandatory for the provision of the services and products that you use on website;

c) To comply with our legal and regulatory duties and responsibilities to the relevant licensing and regulatory authorities as well as all duties and responsibilities owed under any other applicable legislation and to any other applicable regulators in other jurisdictions;

d) To any third parties to which you have provided your consent to do so.

Please note our website and products may contain links that redirect you to third party websites. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.


If you have any questions regarding this policy, please be free to contact us through the following e-mail: [email protected]