22phfun Privacy Policy

22phfun ("we," "us," "our," or the "Operator") is committed to protecting the privacy and personal data of all users ("you," "your," or the "Player") who access and use the 22phfun platform (the "Platform"). This Privacy Policy describes how we collect, use, store, share, and protect your personal information in connection with your use of our online gaming services.

This Privacy Policy applies to all personal data collected through the 22phfun website, mobile applications, customer support channels, and any other services we provide. By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein.

22phfun operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). We are also subject to the data handling requirements of the Philippine Amusement and Gaming Corporation (PAGCOR) as part of our operating license obligations.

22phfun collects personal data that is necessary to provide our services, verify your identity, process transactions, and comply with our legal and regulatory obligations. The categories of personal data we collect include:

2.1 Registration and Account Data

When you create an account on 22phfun, we collect:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Email address
• Mobile phone number
• Username and password (stored in encrypted form)
• Residential address (city, province, country)
• Nationality

2.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and anti-money laundering (AML) requirements, we may collect:

• Government-issued photo ID (Philippine passport, driver's license, or national ID)
• Proof of address documents (utility bills, bank statements)
• Selfie or live photo for identity verification
• Source of funds documentation (for high-value accounts)

2.3 Financial and Transaction Data

• GCash account details (mobile number linked to GCash)
• PayMaya account details
• Bank account information (bank name, account number) for BPI, BDO, Metrobank, UnionBank, and other Philippine banks
• Deposit and withdrawal history
• Transaction amounts in Philippine Peso (PHP)

2.4 Gaming and Behavioral Data

• Game history, bet amounts, and outcomes
• Session duration and frequency of play
• Bonus and promotion usage
• Responsible gaming settings and self-exclusion requests

2.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Cookies and similar tracking technologies (see Section 6)
• Log data including access times, pages viewed, and errors encountered

2.6 Communications Data

• Customer support chat transcripts and email correspondence
• Survey responses and feedback submissions
• Marketing communication preferences

22phfun uses your personal data only for legitimate purposes directly related to the operation of our Platform and our legal obligations. We do not use your data for purposes that are incompatible with those stated in this Privacy Policy. Specifically, we use your personal data for the following purposes:

3.1 Account Management and Service Delivery

• Creating and managing your 22phfun player account
• Verifying your identity and age (21+ requirement under Philippine law)
• Processing deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers
• Providing access to games including Bingo, Slots, Super Keno, Aviator, and other casino games
• Delivering customer support and resolving disputes

3.2 Regulatory Compliance

• Complying with PAGCOR licensing requirements and reporting obligations
• Fulfilling anti-money laundering (AML) and counter-terrorism financing (CTF) obligations
• Responding to lawful requests from Philippine government authorities and law enforcement
• Maintaining records as required by Philippine financial regulations

3.3 Security and Fraud Prevention

• Detecting and preventing fraudulent activity, bonus abuse, and multi-accounting
• Monitoring for suspicious betting patterns or unusual account activity
• Protecting the integrity of our games and the fairness of play for all users
• Investigating and responding to security incidents

3.4 Responsible Gaming

• Monitoring gaming behavior to identify potential problem gambling indicators
• Enforcing self-exclusion requests and deposit limits set by players
• Sending responsible gaming reminders and session time alerts
• Complying with PAGCOR's responsible gaming program requirements

3.5 Platform Improvement and Analytics

• Analyzing usage patterns to improve the Platform's features and user experience
• Conducting internal research and performance analytics
• Testing new features and game offerings

3.6 Marketing Communications

With your consent, we may use your email address and mobile number to send you promotional offers, bonus notifications, and updates about new games or features on 22phfun. You can opt out of marketing communications at any time by updating your account preferences or contacting customer support.

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

• Contractual Necessity: Processing is necessary to perform the contract between you and 22phfun — specifically, to provide you with access to our gaming platform, process your transactions, and manage your account.
• Legal Obligation: Processing is required to comply with our legal and regulatory obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security monitoring, and platform improvement, provided these interests are not overridden by your privacy rights.
• Consent: For marketing communications and certain optional data processing activities, we rely on your freely given, specific, and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

22phfun does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data only in the following limited circumstances:

5.1 Service Providers and Processors

We engage trusted third-party service providers who process personal data on our behalf to help us operate the Platform. These include:

• Payment processors: GCash (Mynt), PayMaya (Voyager Innovations), and Philippine banking partners for processing deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist with document verification and age confirmation.
• Game providers: Licensed third-party game studios whose software powers our casino games. These providers may receive limited technical data necessary to deliver gameplay.
• Cloud and hosting providers: Secure server infrastructure providers who store Platform data under strict data processing agreements.
• Customer support platforms: Tools used to manage live chat and email support interactions.

All third-party service providers are bound by data processing agreements that require them to handle your personal data in accordance with the Data Privacy Act and this Privacy Policy.

5.2 Regulatory and Legal Authorities

We may disclose your personal data to the following authorities when required by law or when we have a good-faith belief that disclosure is necessary:

• Philippine Amusement and Gaming Corporation (PAGCOR)
• Anti-Money Laundering Council (AMLC)
• National Privacy Commission (NPC)
• Philippine National Police (PNP) or National Bureau of Investigation (NBI) pursuant to a valid legal order
• Courts of competent jurisdiction in the Philippines

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of our assets, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and the applicable privacy policy that will govern your data going forward.

5.4 No Cross-Border Transfers Without Safeguards

If any of our service providers are located outside the Philippines, we ensure that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act, including contractual clauses that provide equivalent data protection standards.

22phfun uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. A cookie is a small text file stored on your device when you visit a website.

6.1 Types of Cookies We Use

6.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is set. Please note that disabling essential cookies may affect the functionality of the Platform — for example, you may not be able to stay logged in or access certain features.

To manage cookies, refer to the help documentation for your browser (Chrome, Firefox, Safari, Edge, or others). You can also adjust your cookie preferences through the cookie settings panel available on the 22phfun Platform.

22phfun retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. Our general data retention periods are as follows:

• Account and KYC Data: Retained for the duration of your account and for a minimum of 5 years after account closure, in compliance with PAGCOR regulations and the Anti-Money Laundering Act.
• Transaction Records: Retained for a minimum of 5 years from the date of the transaction, as required by Philippine financial regulations and AMLC reporting obligations.
• Gaming History: Retained for 3 years from the date of each gaming session, or longer if required for dispute resolution or regulatory purposes.
• Customer Support Records: Retained for 2 years from the date of the last interaction, or longer if the matter is subject to ongoing investigation or legal proceedings.
• Marketing Data: Retained until you withdraw your consent or opt out of marketing communications, after which it is deleted or anonymized within 30 days.
• Technical and Log Data: Retained for up to 12 months for security and analytics purposes, after which it is anonymized or deleted.

When personal data is no longer required, we securely delete or anonymize it in accordance with our data disposal procedures. Anonymized data (which cannot be used to identify you) may be retained indefinitely for statistical and research purposes.

22phfun implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using industry-standard SSL/TLS protocols.
• Password Hashing: Your account password is stored using strong cryptographic hashing algorithms. We never store passwords in plain text.
• Two-Factor Authentication (2FA): We offer optional 2FA for your account to add an extra layer of security beyond your password.
• Access Controls: Access to personal data within our organization is restricted on a need-to-know basis. Staff who handle personal data are trained in data protection obligations.
• Secure Infrastructure: Our servers are hosted in secure data centers with physical access controls, firewalls, and intrusion detection systems.
• Regular Security Audits: We conduct periodic security assessments and penetration testing to identify and address vulnerabilities.

While we take all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. You also play an important role in keeping your account secure — please use a strong, unique password and never share your login credentials with anyone.

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

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right to Access: You have the right to request a copy of the personal data we hold about you, including 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. You can update most account information directly through your account settings.
• 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 transmit it 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 (NPC) if you believe your data privacy rights have been violated.

9.1 How to Exercise Your Rights

To exercise any of the rights listed above, please contact our Data Protection Officer (DPO) by sending an email to [email protected] with the subject line "Data Privacy Request." Please include your full name, registered email address, and a description of your request. We will respond to your request within 15 business days.

We may need to verify your identity before processing your request to ensure that we do not disclose personal data to unauthorized parties. In some cases, we may be unable to fulfill your request due to legal obligations (for example, we are required to retain transaction records for a minimum period under PAGCOR and AMLC regulations).

The 22phfun Platform is strictly intended for adults aged 21 years and older, in accordance with the legal gambling age in the Republic of the Philippines. We do not knowingly collect personal data from individuals under the age of 21.

During the registration process, all users are required to confirm that they are at least 21 years of age. We employ age verification procedures, including KYC document checks, to enforce this requirement. If we discover that personal data has been collected from a person under 21 years of age, we will immediately:

• Suspend and permanently close the account.
• Delete all personal data associated with the underage account.
• Void all bets, bonuses, and winnings associated with the account.
• Report the matter to PAGCOR and relevant authorities where required.

Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gambling platforms. If you believe a minor has registered on 22phfun, please contact us immediately at [email protected] so we can take prompt action.

22phfun reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. When we make material changes to this Privacy Policy, we will:

• Update the "Last Updated" date at the top of this page.
• Notify you by email (to the address registered on your account) or by displaying a prominent notice on the Platform.
• Where required by law, obtain your renewed consent to the updated Privacy Policy.

Your continued use of the 22phfun Platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you may close your account by contacting customer support. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

Previous versions of this Privacy Policy are archived and available upon request. If you would like to review a prior version, please contact our Data Protection Officer at [email protected].

If you have any questions, concerns, or requests regarding this Privacy Policy or how 22phfun handles your personal data, please contact our Data Protection Officer (DPO) using the following contact information:

We are committed to responding to all privacy inquiries and data subject requests within 15 business days. For urgent security matters or suspected data breaches, please mark your email as "URGENT" and we will prioritize your request.

You may also contact the National Privacy Commission (NPC) of the Philippines if you have concerns about how your personal data is being handled:

• Website: privacy.gov.ph
• Email: [email protected]
• Hotline: (02) 8234-2228

Thank you for trusting 22phfun with your personal data. We are committed to protecting your privacy and ensuring that your gaming experience is safe, secure, and enjoyable.