Privacy Policy

1. Introduction and Scope

1.1 22ph.com is committed to protecting the privacy and personal data of all users of the 22ph.com platform, including the website, mobile applications, and all associated services (collectively, the "Platform").

1.2 This Privacy Policy applies to all personal data collected from individuals who:

• Register an account on the 22ph.com Platform
• Access or browse the Platform without registering
• Contact 22ph.com customer support
• Participate in promotions, surveys, or other activities offered by 22ph.com

1.3 This policy is intended to comply with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC").

1.4 By using the 22ph.com Platform, you consent to the collection and processing of your personal data as described in this Privacy Policy. If you do not agree with any part of this policy, you should discontinue use of the Platform.

2. Data Controller Information

2.1 For the purposes of the Data Privacy Act of 2012, 22ph.com acts as the personal information controller in respect of the personal data collected through the Platform.

2.2 If you have any questions about this Privacy Policy or wish to exercise your data subject rights, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this policy.

3. Personal Data We Collect

3.1 22ph.com collects the following categories of personal data from users of the Platform:

3.2 Sensitive Personal Information. In certain circumstances, 22ph.com may collect sensitive personal information as defined under the DPA, including government-issued identification numbers (e.g., SSS, UMID, PhilSys National ID). Such data is collected solely for the purpose of identity verification and is handled with the highest level of care and security.

3.3 You are not required to provide all categories of data to access the Platform, but failure to provide certain mandatory information (such as identity and contact data) may prevent you from completing registration or accessing specific features.

4. How We Collect Your Data

4.1 22ph.com collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the Platform, including cookies, web beacons, log files, and similar tracking technologies that record your IP address, device information, and browsing behavior on the Platform.
• Third-party sources: Data received from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), identity verification service providers, fraud prevention agencies, and analytics providers, where permitted by applicable law.

4.2 22ph.com does not collect personal data from social media platforms or other third-party websites without your explicit consent.

5. How We Use Your Personal Data

5.1 22ph.com uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and manage your 22ph.com account, including verifying your identity and age.
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of services available on the Platform.
• Legal and regulatory compliance: To comply with our obligations under the DPA, AML regulations, and any applicable gaming regulations, including KYC verification and transaction monitoring.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Marketing and promotions: To send you information about 22ph.com promotions, bonuses, and new features, where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the functionality and user experience of the Platform.

5.2 22ph.com will not use your personal data for any purpose that is incompatible with the purposes described in this policy without first obtaining your consent or as otherwise permitted by applicable law.

6. Legal Basis for Processing

6.1 22ph.com processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary for the performance of the contract between you and 22ph.com (i.e., the Terms & Conditions), including account management and payment processing.
• Legal obligation: Where processing is necessary for 22ph.com to comply with a legal obligation, such as KYC/AML requirements or orders from regulatory authorities.
• Legitimate interests: Where processing is necessary for the legitimate interests of 22ph.com, such as fraud prevention, platform security, and improving our services, provided that such interests are not overridden by your rights and interests.

7. Sharing and Disclosure of Data

7.1 22ph.com does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers who assist us in verifying your identity and complying with regulatory requirements.
• Technology and hosting providers: Cloud hosting, data storage, and IT infrastructure providers who process data on our behalf under strict data processing agreements.
• Analytics providers: Service providers that help us understand how users interact with the Platform, in anonymized or aggregated form where possible.
• Regulatory and law enforcement authorities: Where required by law, court order, or the direction of a competent regulatory authority, including the National Privacy Commission, PAGCOR, and the Anti-Money Laundering Council (AMLC).
• Professional advisers: Lawyers, auditors, and other professional advisers where necessary for the conduct of our business.

7.2 All third parties with whom 22ph.com shares personal data are required to handle such data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

7.3 In the event of a merger, acquisition, or sale of all or part of 22ph.com's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy. You will be notified of any such transfer in advance.

8. Cookies and Tracking Technologies

8.1 22ph.com uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The following types of cookies are used:

8.2 You can manage or disable cookies through your browser settings at any time. Please note that disabling strictly necessary cookies may affect the functionality of the Platform and prevent you from accessing certain features, including your account.

8.3 22ph.com does not use cookies to serve third-party advertising or to track your activity on websites outside of the 22ph.com Platform.

9. Data Retention

9.1 22ph.com retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

9.2 As a general guide, 22ph.com applies the following retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and gaming regulatory requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Technical and usage data: Retained for up to twenty-four (24) months, after which it is anonymized or deleted.

9.3 Where personal data is no longer required for any lawful purpose, 22ph.com will securely delete or anonymize it in accordance with our internal data disposal procedures.

10. Data Security

10.1 22ph.com implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 22ph.com Platform
• Encryption of sensitive data at rest, including financial data and government ID information
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis
• Regular security audits, vulnerability assessments, and penetration testing
• Multi-factor authentication requirements for administrative access to systems containing personal data
• Staff training on data protection obligations and security best practices

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 22ph.com will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with the DPA.

10.3 While 22ph.com takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for keeping your 22ph.com login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

11. Your Rights Under Philippine Law

11.1 Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 22ph.com:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed, which is the purpose of this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data that 22ph.com holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: You have the right to 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 have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe that 22ph.com has violated your data privacy rights.

11.2 To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 14. We will respond to your request within thirty (30) days of receipt. In complex cases, we may extend this period by a further thirty (30) days, and will notify you accordingly.

11.3 22ph.com will not charge a fee for processing data subject rights requests unless the request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee or decline to act on the request.

12. Children's Privacy

12.1 The 22ph.com Platform is strictly intended for individuals who are 21 years of age or older. 22ph.com does not knowingly collect personal data from individuals under the age of 21.

12.2 If we become aware that we have inadvertently collected personal data from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact us immediately using the details in Section 14.

13. Changes to This Privacy Policy

13.1 22ph.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. When material changes are made, we will notify registered users via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

13.2 The date of the most recent revision will always be displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how 22ph.com protects your personal data.

13.3 Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you should discontinue use of the Platform and may close your account in accordance with our Terms & Conditions.

14. Contact and Complaints

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the way 22ph.com handles your personal data, please contact our Data Protection Officer:

14.2 If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines: