Privacy Policy

This Privacy Policy ("Policy") is issued by 22phl ("Company," "we," "us," or "our") and applies to all personal data collected through the 22phl online gaming platform available at https://22phl.app ("Platform"), including all associated mobile-optimized interfaces, customer support channels, and promotional communications.

22phl is committed to protecting the privacy and personal data of all users ("you," "your," or "Player") in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC).

By accessing or using the 22phl Platform, registering an account, or submitting any personal information to us, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein.

22phl collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of data we collect are described below:

2.1 Data You Provide Directly

• Registration Data: Full legal name, date of birth, gender, nationality, residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, Makati), email address, and mobile number.
• Identity Verification (KYC) Documents: Government-issued photo ID (Philippine passport, driver's license, SSS/UMID card, or PhilSys National ID), proof of address, and proof of payment method ownership.
• Financial Data: Payment method details (e.g., GCash account number, PayMaya account, BPI, BDO, or Metrobank account information), deposit and withdrawal history, and transaction records.
• Communications: Messages sent to our support team via live chat or email, including any attachments or documents you provide.
• Responsible Gaming Data: Self-exclusion requests, deposit limit settings, and any information you provide when seeking responsible gaming assistance.

2.2 Data Collected Automatically

• Device & 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 patterns, search queries within the Platform, and feature interactions.
• Location Data: General geographic location derived from your IP address (country and region level). We do not collect precise GPS location data.
• Cookies & Tracking Technologies: Data collected via cookies, web beacons, and similar technologies as described in Section 6.

2.3 Data Collection Summary

22phl uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 22phl player account, including processing your registration, verifying your identity, and enabling you to log in securely.
• Service Delivery: To provide you with access to all games, features, and services available on the Platform, including slots, bingo, live casino, and sports betting.
• Payment Processing: To process deposits and withdrawals via your chosen payment method (GCash, PayMaya, BPI, BDO, Metrobank, etc.) and to maintain accurate financial records.
• Identity Verification & KYC: To verify your identity and age (21+) in compliance with PAGCOR regulations and anti-money laundering (AML) requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal conduct.
• Regulatory Compliance: To comply with our obligations under Philippine law, PAGCOR licensing requirements, the Data Privacy Act, and any other applicable regulations.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor gaming behavior for signs of problem gambling, enforce self-exclusion requests, and apply deposit limits or other responsible gaming tools you have activated.
• Marketing & Promotions: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent or where we have a legitimate interest to do so. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the 22phl Platform.

Under the Philippine Data Privacy Act of 2012, 22phl processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 22phl — specifically, to operate your player account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including PAGCOR licensing conditions, AML obligations, and tax reporting requirements.
• Legitimate Interests: Processing is necessary for 22phl's legitimate business interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

22phl does not sell your personal data. We may share your data with the following categories of recipients only where necessary and under appropriate safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers require certain data to process your transactions securely. These providers are bound by their own privacy policies and applicable financial regulations.
• KYC & Identity Verification Providers: Third-party identity verification services that assist us in confirming your identity and age in compliance with PAGCOR and AML requirements.
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or regulatory mandate.
• Fraud Prevention & Security Services: Specialized providers that help us detect and prevent fraudulent activity, unauthorized access, and other security threats.
• IT & Infrastructure Providers: Cloud hosting, data storage, and technical infrastructure providers who process data on our behalf under strict data processing agreements.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors who require access to data in connection with their services to 22phl, subject to professional confidentiality obligations.

All third parties with whom 22phl shares personal data are required to handle it in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific service they provide to us.

22phl uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyze usage patterns. The types of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, game display options, and responsible gaming tool configurations. Disabling these may affect your experience.
• Analytics Cookies: Help us understand how players use the Platform — which games are most popular, where users encounter difficulties, and how navigation flows can be improved. Data collected is aggregated and anonymized where possible.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of our campaigns. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may impact the functionality of the 22phl Platform. For more information on managing cookies, refer to your browser's help documentation.

22phl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest, including financial records and identity documents, is encrypted using industry-standard algorithms.
• Access Controls: Access to personal data is restricted to authorized 22phl personnel and service providers on a strict need-to-know basis. All access is logged and regularly audited.
• Secure Infrastructure: The Platform is hosted on secure, regularly patched server infrastructure with firewalls, intrusion detection systems, and DDoS protection.
• Two-Factor Authentication: Players are encouraged to enable two-factor authentication (2FA) on their accounts for an additional layer of security.
• Regular Security Audits: 22phl conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities.
• Staff Training: All 22phl employees who handle personal data receive regular training on data protection obligations and security best practices.

While 22phl takes all reasonable steps to protect your data, no system is completely immune to security risks. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

22phl retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with any individual. Where data must be retained for legal reasons beyond the standard period, it will be stored securely and access will be restricted.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 22phl:

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. We will respond to all valid requests within 30 days of receipt. In complex cases, this period may be extended by a further 30 days, and we will notify you accordingly.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

The 22phl Platform is strictly intended for adults aged 21 years and above in accordance with Philippine law and PAGCOR regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the data, and take appropriate action in accordance with our Terms and Conditions and applicable law.

22phl primarily processes and stores personal data within the Philippines. In certain circumstances, your data may be transferred to or accessed from servers or service providers located outside the Philippines — for example, where we use internationally based cloud infrastructure or third-party technology providers.

Where such transfers occur, 22phl ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the NPC.
• Implementing contractual clauses that require overseas recipients to protect your data to the same standard required under Philippine law.
• Conducting due diligence on all international service providers to verify their data protection practices before engaging their services.

By using the 22phl Platform, you acknowledge and consent to the transfer of your personal data as described in this section, subject to the safeguards outlined above.

The 22phl Platform may contain references to third-party services such as payment providers. These third parties operate their own privacy policies, which are independent of this Policy. 22phl is not responsible for the privacy practices of any third-party service.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the 22phl Platform, particularly your chosen payment provider (e.g., GCash, PayMaya, BPI, BDO, or Metrobank).

22phl reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. When material changes are made, we will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect, where reasonably practicable.

The most current version of this Policy will always be available on this page, with the effective date clearly indicated at the top. Your continued use of the 22phl Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

If you do not agree with any updated Policy, you must stop using the Platform and may request account closure in accordance with our Terms and Conditions.

22phl has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and the Philippine Data Privacy Act. If you have any questions, concerns, or requests regarding your personal data or this Policy, please contact us:

• Data Protection Officer: dpo@22phl.app
• General Support: support@22phl.app
• Live Chat: Available 24/7 via the chat widget on the Platform.
• Response Time: We aim to acknowledge all data-related requests within 72 hours and resolve them within 30 days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.