22ph.com Privacy Policy

1. Introduction

22ph.com ("22ph.com," "we," "us," or "our"), accessible at 22phcom.org, is an online gaming platform operated for users in the Philippines. We are committed to protecting the privacy and personal data of all individuals who access or use the 22ph.com platform ("you" or "data subject").

This Privacy Policy ("Policy") describes how 22ph.com collects, uses, stores, shares, and protects personal data in connection with your use of the platform. It is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission (NPC) of the Philippines.

This Policy applies to all personal data collected through the 22ph.com website, mobile interface, customer support channels, and any other touchpoints through which you interact with 22ph.com. It should be read together with the 22ph.com Terms & Conditions, which govern your use of the platform.

If you do not agree with this Policy, you must not register an account or use the 22ph.com platform.

2. Personal Data We Collect

22ph.com collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name
• Date of birth (for age verification — 21+ requirement)
• Philippine mobile number and/or email address
• Username and encrypted password
• Residential address (for KYC verification)

2.2 Identity Verification (KYC) Data

• Government-issued photo ID (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's license, UMID)
• Proof of address documents
• Selfie or liveness check images (where required for enhanced verification)
• Proof of payment method ownership

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records (amounts, dates, payment method type)
• GCash or Maya account reference numbers (not full account credentials)
• Bank account name and last four digits (for bank transfer verification)
• Bonus and promotional transaction history

2.4 Gaming Activity Data

• Game session records (games played, wagers placed, outcomes, timestamps)
• Responsible gaming tool settings (deposit limits, self-exclusion status)
• Bonus usage and wagering history

2.5 Technical & Device Data

• IP address and approximate geolocation (country/region level)
• Device type, operating system, and browser type
• Session logs and access timestamps
• Cookie identifiers and session tokens

2.6 Communications Data

• Customer support chat transcripts and email correspondence
• Feedback and survey responses (where voluntarily provided)

22ph.com does not collect sensitive personal information (as defined under the DPA, such as health data, political affiliations, or religious beliefs) unless specifically required by law or regulatory obligation.

3. How We Use Your Personal Data

22ph.com uses personal data collected from you for the following purposes:

22ph.com will not use your personal data for any purpose incompatible with those listed above without obtaining your prior consent or as otherwise permitted by applicable law.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act, 22ph.com processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and 22ph.com (e.g., account management, payment processing, game provision).
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the DPA itself (e.g., KYC verification, regulatory reporting).
• Legitimate interests: Processing necessary for 22ph.com's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent (e.g., marketing communications). You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

22ph.com does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• Payment processors: GCash, Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals. These processors are bound by their own privacy policies and applicable financial regulations.
• Identity verification providers: Third-party KYC and age verification services used to verify your identity and age in compliance with PAGCOR requirements.
• Game content providers: Licensed game studios and live dealer operators whose games are available on 22ph.com. These providers may receive session data necessary to deliver game content.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or regulatory obligation.
• IT and security service providers: Cloud hosting, cybersecurity, and platform infrastructure providers operating under strict data processing agreements with 22ph.com.
• Legal and professional advisers: Where necessary for the establishment, exercise, or defence of legal claims.

All third parties with whom 22ph.com shares personal data are required to implement appropriate technical and organisational security measures and to process data only for the specified purpose.

6. Cookies & Tracking Technologies

22ph.com uses cookies and similar tracking technologies to operate and improve the platform. The following categories of cookies are used:

• Strictly necessary cookies: Required for the platform to function. These include session authentication tokens, CSRF protection cookies, and load-balancing cookies. These cannot be disabled without impairing platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies: Used to collect aggregated, anonymised data about how users interact with the platform, to help 22ph.com improve the user experience. No personally identifiable information is transmitted to analytics providers.

22ph.com does not use third-party advertising or retargeting cookies. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your 22ph.com account.

7. Data Retention

22ph.com retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC data: Retained for a minimum of five (5) years from account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA requirements.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of the session.
• Customer support records: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year for compliance documentation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 22ph.com's data disposal procedures.

8. Your Data Subject Rights

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

• Right to be informed: The right to be notified of how your personal data is collected and processed, as set out in this Policy.
• Right of access: The right to request a copy of the personal data 22ph.com holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to 22ph.com's legal retention obligations.
• Right to object: The right to object to the processing of your personal data on grounds of legitimate interest or for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact the 22ph.com Data Protection Officer using the contact details in Section 13. 22ph.com will respond to all data subject requests within fifteen (15) business days of receipt, as required by the DPA.

9. Data Security

22ph.com implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption at rest and in transit: All personal data stored on 22ph.com servers is encrypted using industry-standard AES-256 encryption. All data transmitted between your device and the platform is protected by TLS 1.2 or higher.
• Access controls: Access to personal data is restricted to authorised 22ph.com personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Payment data isolation: 22ph.com does not store full payment credentials on its servers. All payment transactions are handled by PCI-DSS compliant third-party processors.
• Two-factor authentication: 22ph.com supports and encourages the use of two-factor authentication (2FA) for all registered accounts to reduce the risk of unauthorised access.
• Regular security assessments: 22ph.com conducts periodic vulnerability assessments and penetration testing to identify and remediate security risks.
• Incident response: In the event of a personal data breach, 22ph.com will notify affected users and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by NPC Circular 16-03.

While 22ph.com takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying 22ph.com immediately if you suspect any unauthorised access to your account.

10. Children's Privacy

22ph.com is strictly an adult platform. Access is limited to individuals aged 21 years and above, in compliance with PAGCOR regulations applicable in the Philippines. 22ph.com does not knowingly collect personal data from individuals under the age of 21.

If 22ph.com becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, all balances will be withheld pending investigation, and the personal data will be deleted in accordance with applicable law. If you believe that a minor has registered an account on 22ph.com, please contact the Data Protection Officer immediately using the details in Section 13.

11. Cross-Border Data Transfers

22ph.com primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed from servers or service providers located outside the Philippines — for example, where 22ph.com uses internationally hosted cloud infrastructure or game content providers based in other jurisdictions.

Where such transfers occur, 22ph.com ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that impose data protection obligations on the recipient equivalent to those required under the Philippine Data Privacy Act. 22ph.com will not transfer personal data to a jurisdiction that does not provide an adequate level of data protection without implementing such safeguards.

12. Changes to This Privacy Policy

22ph.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, 22ph.com will notify registered users via email or an in-platform notification at least seven (7) days before the revised Policy takes effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the 22ph.com platform after the effective date of any amendment constitutes your acknowledgment of the revised Policy. If you do not agree with the revised Policy, you must cease using the platform and may request account closure by contacting 22ph.com support.

We encourage you to review this Policy periodically to stay informed about how 22ph.com protects your personal data.

13. Contact & Data Protection Officer

22ph.com has appointed a Data Protection Officer (DPO) registered with the National Privacy Commission of the Philippines. If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to raise a data privacy concern, please contact the DPO through the following channels:

• Live Chat: Available 24/7 after logging in to your 22ph.com account. Mark your message as "Data Privacy Request" for priority routing to the DPO team.
• Email: [email protected] (plain text — not a clickable link). Please include your registered username and a description of your request. Response time is within fifteen (15) business days.

If you are not satisfied with 22ph.com's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint is available on the NPC's official website.