PH 22 Privacy Policy

1. Introduction

ph 22 ("ph 22," "we," "us," or "our") is committed to protecting the privacy and personal data of all users who access or use the ph 22 online gaming platform at https://ph-22.app (the "Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

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

By registering an account, accessing the ph 22 Platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, please discontinue use of the Platform immediately.

2. Personal Data We Collect

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

2.1 Identity and Contact Information

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify the 21+ age requirement)
• Residential address (including barangay, city/municipality, province)
• Email address
• Mobile number
• Nationality and citizenship

2.2 Identity Verification Documents

• Copies of government-issued IDs (e.g., PhilSys ID, passport, driver's license, UMID, SSS ID, voter's ID)
• Selfie or live photo for facial verification purposes
• Proof of address documents where required

2.3 Financial Information

• GCash account number or PayMaya account details
• Bank account details (BPI, BDO, Metrobank, or other supported banks) for withdrawal processing
• Transaction history, including deposits, withdrawals, and gaming activity
• Source of funds declarations where required by anti-money laundering regulations

2.4 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Login timestamps and session duration
• Pages visited, games played, and features used on the Platform
• Cookies and similar tracking technologies (see Section 7)

2.5 Communications Data

• Records of your communications with ph 22 customer support
• Feedback, complaints, and survey responses
• Marketing preferences and opt-in/opt-out records

3. How We Collect Your Data

ph 22 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from GCash, PayMaya, and banking partners.
• Regulatory sources: Information received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other regulatory bodies in connection with compliance obligations.

4. How We Use Your Personal Data

ph 22 processes your personal data for the following purposes:

• Account management: To register, verify, and maintain your ph 22 account, including processing your ph 22 login credentials securely.
• Age and identity verification: To confirm that you meet the 21+ age requirement and to comply with KYC obligations under PAGCOR regulations.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Legal and regulatory compliance: To comply with the Data Privacy Act, Anti-Money Laundering Act, PAGCOR licensing requirements, and other applicable Philippine laws.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and unauthorized access to the Platform.
• Customer support: To respond to your inquiries, complaints, and support requests.
• Responsible gaming: To monitor gaming activity and implement responsible gaming tools such as deposit limits and self-exclusion where requested or required.
• Marketing communications: To send you promotional offers, bonuses, and updates about ph 22, subject to your marketing preferences and applicable opt-in requirements.
• Platform improvement: To analyze usage patterns and improve the ph 22 Platform's features, performance, and user experience.

5. Legal Basis for Processing

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

• Consent: Where you have given explicit consent to the processing of your personal data, such as for marketing communications.
• Contractual necessity: Where processing is necessary to perform our obligations under the Terms & Conditions, including account management and payment processing.
• Legal obligation: Where processing is required to comply with applicable laws and regulations, including PAGCOR licensing conditions, AML obligations, and NPC requirements.
• Legitimate interests: Where processing is necessary for ph 22's legitimate interests, such as fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights.

6. Data Sharing and Disclosure

ph 22 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers to facilitate deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist with identity verification and age confirmation.
• Game providers: Certified third-party game developers whose games are hosted on the ph 22 Platform, to the extent necessary for game operation.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government agencies where required by law.
• Law enforcement: Philippine law enforcement agencies where disclosure is required by court order, subpoena, or applicable law.
• Fraud prevention partners: Third-party fraud detection and prevention services to protect the integrity of the Platform.
• Professional advisors: Legal counsel, auditors, and other professional advisors bound by confidentiality obligations.

7. Cookies and Tracking Technologies

ph 22 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session, and analyze usage patterns. The types of cookies we use include:

• Essential cookies: Necessary for the Platform to function, including session management and security features. These cannot be disabled.
• Analytics cookies: Used to understand how players interact with the ph 22 Platform, helping us improve performance and user experience.
• Preference cookies: Used to remember your settings and preferences, such as language and display options.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns, subject to your consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ph 22 Platform.

8. Data Retention

ph 22 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR and AML regulations.
• Transaction records: Retained for a minimum of five (5) years in accordance with anti-money laundering requirements.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.

Upon expiry of the applicable retention period, ph 22 will securely delete or anonymize your personal data in accordance with NPC guidelines.

9. Data Security

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

• Encryption of data in transit using industry-standard TLS/SSL protocols
• Encryption of sensitive data at rest
• Access controls limiting data access to authorized personnel on a need-to-know basis
• Regular security assessments and vulnerability testing
• Staff training on data privacy and security obligations
• Incident response procedures for data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph 22 will notify the National Privacy Commission and affected data subjects in accordance with the requirements of the Data Privacy Act and NPC Circular No. 16-03.

10. Your Data Privacy Rights

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

• Right to be informed: The right to know what personal data ph 22 collects and how it is processed.
• Right of access: The right to request a copy of the personal data ph 22 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 legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the contact details provided in Section 14. ph 22 will respond to your request within thirty (30) days in accordance with NPC guidelines.

11. Children's Privacy

The ph 22 Platform is strictly intended for individuals aged 21 years and above. ph 22 does not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from an underage individual, we will immediately delete such data and close the associated account.

If you are a parent or guardian and believe that your child has provided personal data to ph 22, please contact us immediately at [email protected] so that we can take appropriate action.

12. Cross-Border Data Transfers

ph 22 may transfer your personal data to third-party service providers located outside the Philippines, including game providers and technology partners. Any such cross-border transfer will be conducted in accordance with the Data Privacy Act and NPC regulations, including the implementation of appropriate safeguards such as contractual data protection clauses to ensure your data receives an equivalent level of protection.

13. Updates to This Privacy Policy

ph 22 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. The updated Policy will be posted on the Platform with a revised effective date. We encourage you to review this Policy periodically.

For material changes, ph 22 will provide notice via email to your registered address or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the ph 22 Platform following the posting of an updated Privacy Policy constitutes your acceptance of the changes.

14. Contact Our Data Protection Officer

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

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines at privacy.gov.ph if you believe your data privacy rights have not been adequately addressed by ph 22.