p22ph Privacy Policy

Introduction & Scope

p22ph is committed to protecting the privacy and security of all personal information entrusted to us by Filipino players who register and use the Platform. This Policy sets out in clear terms what data we collect, why we collect it, how we use it, how long we retain it, and the rights you hold over your information under applicable Philippine law.

This Policy applies to all users of p22ph, including registered account holders, visitors to the p22ph.club website who have not yet registered, and individuals who contact our support team. It covers all data processing activities conducted by p22ph in connection with the operation of the Platform, including game activities, financial transactions, customer support interactions, and marketing communications where you have given consent.

This Policy should be read alongside the p22ph Terms & Conditions, which govern your use of the Platform. In the event of any conflict between this Policy and the Terms & Conditions on privacy-related matters, this Policy shall prevail.

Data Controller

For the purposes of the Data Privacy Act of 2012, p22ph is the Personal Information Controller in respect of the personal data of its registered players and website visitors. This means p22ph is responsible for determining the purposes and means by which your personal data is processed.

p22ph has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection law. You may contact the DPO at the support email address listed in Section 15 of this Policy, with the subject line "Data Protection Officer – Privacy Enquiry."

Where p22ph engages third-party service providers to process personal data on its behalf — for example, payment processors, KYC verification services, and customer support platforms — those providers are classified as Personal Information Processors under Philippine law and are bound by contractual data processing agreements that impose obligations equivalent to those under this Policy.

Information We Collect

p22ph collects personal data in the following categories. We collect only the minimum data necessary for each purpose listed.

3.1 Registration Data

When you create a p22ph account, we collect:

• Full name as it appears on your government-issued ID;
• Date of birth (to verify age eligibility of 21+ years);
• Philippine mobile number (+63 format);
• Email address;
• Chosen username;
• Residential address in the Philippines.

3.2 KYC Verification Data

To comply with PAGCOR licensing requirements and Philippine anti-money laundering laws, p22ph collects:

• Copies of government-issued photo identification (PhilSys card, driver's licence, passport, UMID, or other PAGCOR-accepted documents);
• Proof of address documents where required;
• Proof of payment method ownership (e.g., screenshot of GCash account in your name) where verification is requested.

3.3 Transaction and Financial Data

• Deposit amounts, dates, and payment methods;
• Withdrawal requests and associated payment account details;
• Transaction history and balance records;
• GCash reference numbers, Maya transaction IDs, and bank transfer references as applicable.

3.4 Gaming Activity Data

• Game session records (game type, duration, bet amounts, outcomes);
• Wagering history across all p22ph game categories;
• Bonus redemption and wagering requirement completion records;
• Responsible gaming limit settings and any self-exclusion elections.

3.5 Technical and Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser information;
• Session logs including login timestamps and duration;
• Cookie identifiers and session tokens (see Section 9).

3.6 Communications Data

• Support chat transcripts and email correspondence;
• Responses to surveys or feedback forms where you choose to participate;
• Marketing communication preferences and opt-in/opt-out records.

Legal Basis for Processing

p22ph processes your personal data on one or more of the following legal bases as defined under the Data Privacy Act of 2012:

Legal Basis	Processing Activities Covered
Contractual Necessity	Account creation, identity verification, payment processing, game operation, withdrawal handling — activities necessary to perform the services described in the Terms & Conditions.
Legal Obligation	KYC verification, anti-money laundering record-keeping, age verification, and reporting obligations under PAGCOR licensing and Philippine AMLA regulations.
Legitimate Interests	Fraud detection, platform security, abuse prevention, analytical activities to improve the platform, and responsible gaming monitoring. p22ph has conducted legitimate interests assessments for each such activity.
Consent	Marketing communications, non-essential cookies, and any processing activities where p22ph has expressly sought and obtained your specific consent. You may withdraw consent at any time without affecting prior lawful processing.

How We Use Your Data

p22ph uses your personal data for the following specific purposes:

• Account Management: Creating, maintaining, and securing your p22ph account, including authentication and session management;
• Identity and Age Verification: Confirming that you meet the 21+ age requirement and satisfy KYC requirements under Philippine gaming regulations;
• Payment Processing: Facilitating deposits via GCash, Maya, BPI, BDO, and other supported methods; processing withdrawal requests to verified payment methods;
• Game Operation: Delivering game services, recording game outcomes, processing wagers, calculating and crediting winnings;
• Regulatory Compliance: Meeting reporting obligations to PAGCOR and other Philippine regulatory authorities; maintaining records as required by the Anti-Money Laundering Act;
• Fraud Prevention and Security: Detecting and preventing fraudulent activity, money laundering, collusion, and other prohibited conduct described in the Terms & Conditions;
• Responsible Gaming: Monitoring gaming activity to identify at-risk behaviour, applying responsible gaming limits where set by the player, and managing self-exclusion elections;
• Customer Support: Responding to enquiries, complaints, and account issues through live chat and email;
• Platform Improvement: Analysing aggregated and anonymised usage data to identify improvements to the platform, user experience, and game catalogue;
• Marketing (with consent): Sending promotional communications about bonuses, new games, and platform updates to players who have opted in to marketing communications.

p22ph does not use your personal data for purposes incompatible with those listed above without obtaining fresh consent or establishing a new legal basis for processing.

Data Sharing & Disclosure

p22ph shares your personal data with third parties only in the following circumstances and only to the extent necessary for each stated purpose:

6.1 Service Providers

p22ph engages third-party service providers who process personal data on our behalf, including: payment gateway operators, KYC and identity verification platforms, game software providers, customer support technology platforms, cloud infrastructure providers, and fraud detection services. All such providers are bound by contractual data processing agreements that prohibit them from using your data for their own independent purposes.

6.2 Regulatory Authorities

p22ph is required by Philippine law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities in response to lawful orders, regulatory requests, or mandatory reporting requirements. Such disclosures are made strictly in accordance with applicable law and without prior notice to you where the law permits or requires non-disclosure.

6.3 Law Enforcement

Where required by court order, search warrant, or other compulsory legal process issued by a competent Philippine authority, p22ph will disclose the requested personal data. p22ph will, where legally permissible, notify you of such requests before complying.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of p22ph's business, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified via your registered email address of any such transfer and your continued use of the Platform following the transfer constitutes acceptance of the new entity's privacy terms, provided those terms offer equivalent or greater protection than this Policy.

Data Retention

p22ph retains your personal data for the periods set out below, after which data is either deleted or anonymised such that it can no longer be associated with you as an individual:

Data Category	Retention Period	Basis
Account registration data	Duration of account + 5 years after closure	PAGCOR licensing requirement / AMLA
KYC identity documents	Duration of account + 5 years after closure	AMLA record-keeping requirement
Financial transaction records	10 years from transaction date	AMLA Section 9 record retention
Game session records	5 years from session date	PAGCOR audit trail requirement
Support communications	3 years from last interaction	Legitimate interests / dispute resolution
Marketing consent records	Until withdrawal of consent + 2 years	Proof of consent / legal compliance
Technical / device logs	12 months from log creation	Security and fraud monitoring
Self-exclusion records	Duration of exclusion + 10 years	PAGCOR responsible gaming compliance

Where retention for a longer period is required by a specific court order, regulatory directive, or ongoing investigation, p22ph will retain the relevant data until the applicable requirement is satisfied.

Data Security

p22ph implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and p22ph.club is encrypted using TLS (Transport Layer Security) with 256-bit SSL certificates. The padlock icon in your browser confirms an active encrypted connection.
• Encryption at Rest: Sensitive personal data stored in p22ph's databases — including government ID references and payment account information — is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Strict role-based access controls limit internal access to personal data to employees and contractors who have a legitimate need to view it in connection with their specific job function. Access is logged and audited.
• Two-Factor Authentication: Internal systems used by p22ph staff to access player data require multi-factor authentication.
• Intrusion Detection: p22ph employs automated systems to detect and alert on unusual access patterns, potential intrusions, and data exfiltration attempts.
• Vendor Security Reviews: Third-party service providers with access to player data are subject to security assessments prior to engagement and periodic review during the relationship.

Despite these measures, no data transmission over the internet or electronic storage system can be guaranteed as completely secure. p22ph cannot warrant absolute security. In the event of a personal data breach that poses a risk to your rights and freedoms, p22ph will notify the National Privacy Commission and affected players in accordance with the Data Privacy Act's breach notification requirements.

Cookies & Tracking Technologies

p22ph uses cookies and similar technologies (including session tokens and local storage) on the p22ph.club website. Cookies are small text files placed on your device that help the Platform function correctly and allow us to improve your experience.

9.1 Categories of Cookies Used

Category	Purpose	Essential?
Strictly Necessary	Maintaining your login session, preventing session hijacking, storing your language and region preference, processing form inputs securely.	Yes – cannot be disabled without breaking core functionality
Functional	Remembering your preferred game lobby view, last game played, chat window state, and other personalisation settings.	No – optional but improve experience
Analytics	Aggregated, anonymised data on page visits, session durations, and feature usage to help p22ph understand how the Platform is used and identify improvements.	No – consent required
Security	Fraud detection signals including device fingerprint elements, login anomaly detection, and bot identification.	Yes – required for security operations

9.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most browsers allow you to view, delete, and block cookies. Note that disabling strictly necessary cookies will affect your ability to log in and use core platform features. Instructions for managing cookies in common browsers are available in each browser's help documentation.

Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by p22ph. To exercise any of these rights, contact p22ph Support as described in Section 15.