Privacy Policy — 22phfun Casino

1. Introduction

22phfun ("we," "us," "our") is committed to protecting the privacy and personal data of every player who registers on or uses the 22phfun online casino platform, accessible at 22phfun.app. This Privacy Policy ("Policy") describes how 22phfun collects, uses, stores, shares, and protects your personal information in connection with your use of the platform and all associated services.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines. It should be read together with the 22phfun Terms & Conditions and the Responsible Gaming Policy.

If you have any questions about how 22phfun handles your personal data, please contact our Data Protection Officer using the details provided in Section 15 of this Policy.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, the personal information controller responsible for your data is 22phfun, operating the platform at 22phfun.app and serving registered players in the Republic of the Philippines.

22phfun has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with the DPA and this Policy. The DPO's contact details are set out in Section 15. All data subject requests, privacy complaints, and data breach notifications should be directed to the DPO in the first instance.

3. Personal Data We Collect

22phfun collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include:

22phfun does not collect sensitive personal information as defined under Section 3(l) of the DPA (such as health data, political affiliations, or biometric data) unless specifically required by law or regulatory directive and with your explicit consent.

4. How We Collect Your Data

22phfun collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and interact with the 22phfun platform, including through cookies, web beacons, server logs, and similar tracking technologies (see Section 8).
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment transaction data from GCash, Maya/PayMaya, and partner banks. All third-party data sources are contractually bound to handle your data in accordance with the DPA.
• Publicly available sources: In limited circumstances, 22phfun may verify information against publicly available government databases or records as part of its regulatory compliance obligations.

5. Legal Basis for Processing

22phfun processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between you and 22phfun — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including the Anti-Money Laundering Act (RA 9160), PAGCOR regulatory requirements, and the Data Privacy Act itself.
• Legitimate interests: Processing is necessary for 22phfun's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and non-essential cookies, 22phfun relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. How We Use Your Personal Data

22phfun uses the personal data it collects for the following purposes:

• Account management: Creating and maintaining your 22phfun account, verifying your identity and age (21+ requirement), and managing your account settings and preferences.
• Transaction processing: Processing deposits via GCash, Maya/PayMaya, and Philippine bank transfers; processing withdrawal requests; maintaining accurate financial records.
• Regulatory compliance: Fulfilling KYC and AML obligations under Philippine law; reporting suspicious transactions to the Anti-Money Laundering Council (AMLC) where required; responding to lawful requests from PAGCOR and other regulatory authorities.
• Responsible gaming: Monitoring gameplay patterns to identify signs of problem gambling; enforcing deposit limits, session limits, and self-exclusion requests; complying with PAGCOR's responsible gaming framework.
• Customer support: Responding to your enquiries, resolving disputes, and providing technical assistance.
• Platform security and fraud prevention: Detecting and preventing unauthorised account access, bonus abuse, collusion, and other fraudulent or prohibited activities.
• Service improvement: Analysing aggregated usage data to improve platform performance, game offerings, and user experience.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You can opt out at any time.

7. Data Sharing & Disclosure

22phfun does not sell, rent, or trade your personal data to third-party marketers. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC and identity verification providers: Third-party service providers that assist 22phfun in verifying player identities and ages in compliance with PAGCOR and AML requirements.
• Payment processors: GCash, Maya/PayMaya, and partner Philippine banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals.
• Fraud prevention and AML screening services: Compliance technology providers that help 22phfun detect and prevent money laundering, fraud, and other prohibited activities.
• Game content providers: Licensed game studios and live dealer platform providers whose games are offered on 22phfun. These providers may receive limited technical data necessary to deliver their games.
• IT and cloud infrastructure providers: Hosting, database, and security service providers that support the operation of the 22phfun platform. All such providers are contractually bound to process data only on 22phfun's instructions.
• Regulatory and law enforcement authorities: PAGCOR, the AMLC, the National Privacy Commission, and other competent Philippine government authorities, where disclosure is required by law, court order, or regulatory direction.
• Professional advisers: Lawyers, auditors, and accountants, where necessary for the conduct of 22phfun's business and subject to professional confidentiality obligations.

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

8. Cookies & Tracking Technologies

22phfun uses cookies and similar tracking technologies to operate and improve the platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that keep you logged in to your 22phfun account and security cookies that protect against cross-site request forgery. These cookies cannot be disabled without affecting platform functionality.
• Performance and analytics cookies: Used to collect aggregated, anonymised data about how players use the 22phfun platform, which pages are visited most frequently, and where errors occur. This data helps us improve platform performance and user experience.
• Functional cookies: Used to remember your preferences, such as your preferred language, display settings, and responsible gaming limits, so you do not need to re-enter them on each visit.
• Marketing cookies: Used only with your consent to deliver relevant promotional content and to measure the effectiveness of 22phfun's marketing campaigns. You may opt out of marketing cookies at any time through your browser settings.

You can manage or disable non-essential cookies through your browser's cookie settings. Please note that disabling certain cookies may affect the functionality of the 22phfun platform. For more information on managing cookies in popular browsers, refer to your browser's help documentation.

9. Data Retention

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

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR regulatory requirements and AML obligations under RA 9160.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and its implementing regulations.
• Customer support communications: Retained for two (2) years from the date of the last communication, or longer if the communication relates to an unresolved dispute or regulatory matter.
• Technical and usage data: Retained for up to twelve (12) months from collection, after which it is anonymised or deleted.
• Marketing preference data: Retained until you withdraw consent or request deletion, subject to any legal retention requirements.

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

10. Data Security

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

• Encryption: All data transmitted between your device and the 22phfun platform is encrypted using 256-bit SSL/TLS technology. Sensitive data stored in our systems is encrypted at rest.
• Access controls: Access to personal data is restricted to authorised 22phfun personnel and service providers on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-factor authentication: 22phfun supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorised access.
• Regular security audits: 22phfun conducts regular internal and third-party security assessments, penetration testing, and vulnerability scans to identify and remediate security risks.
• Incident response: 22phfun maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, 22phfun will notify the National Privacy Commission and affected players within the timeframes prescribed by the DPA.

While 22phfun takes all reasonable steps to protect your personal data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the security of your 22phfun login credentials and for notifying us immediately if you suspect any unauthorised access to your account.

11. Your Data Subject Rights

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

• Right to be informed: The right to be informed of how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data 22phfun holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held by 22phfun.
• Right to erasure: 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 22phfun's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 22phfun has processed your personal data in violation of the DPA.

To exercise any of these rights, please contact the 22phfun Data Protection Officer using the details in Section 15. 22phfun will respond to all data subject requests within thirty (30) days of receipt, in accordance with the DPA's implementing rules.

12. Children's Privacy and Age Restriction

The 22phfun platform is strictly intended for adults aged 21 years and older, in accordance with PAGCOR's minimum age requirements for casino-style gambling in the Philippines. 22phfun does not knowingly collect personal data from individuals under the age of 21.

If 22phfun discovers or has reason to believe that a registered account belongs to a person under 21 years of age, the account will be suspended immediately, all pending transactions will be cancelled, and any deposited funds will be returned to the originating payment method following verification. The matter may also be reported to the relevant authorities.

If you are a parent or guardian and believe that your child has registered on 22phfun, please contact our support team immediately so that the account can be closed and any data deleted in accordance with this Policy.

13. Cross-Border Data Transfers

In the course of providing its services, 22phfun may transfer your personal data to service providers or partners located outside the Republic of the Philippines — for example, game content providers or cloud infrastructure providers operating in other jurisdictions.

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

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission.
• Entering into data processing agreements with overseas recipients that incorporate standard contractual clauses approved by the NPC.
• Conducting transfer impact assessments where required to ensure that your rights under the DPA are not undermined by the transfer.

You may request further information about the safeguards applicable to any specific cross-border transfer by contacting the DPO.

14. Amendments to This Policy

22phfun 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. When material changes are made, 22phfun will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect.

The most current version of this Policy will always be available at 22phfun.app/privacy-policy. The "Last updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the 22phfun platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 22phfun, please contact our Data Protection Officer:

• Data Protection Officer: 22phfun DPO
• Email: [email protected]
• General Support: [email protected]
• Response time: We aim to acknowledge all privacy enquiries within 3 business days and to provide a full response within 30 days.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with 22phfun's response to your privacy concern. Information on how to file a complaint with the NPC is available through official Philippine government channels.

For responsible gaming concerns, please visit the Responsible Gaming page. For general platform terms, please refer to the Terms & Conditions.