22ph1 Privacy Policy — How We Handle Your Personal Data

Who We Are — Data Controller

22ph1 operates the online gaming platform at 22ph1.best. For the purposes of Philippine data protection law, 22ph1 acts as the personal information controller for the data collected through this platform.

When we refer to "22ph1", "we", "us", or "our" in this Privacy Policy, we mean the entity responsible for operating 22ph1.best and processing player data in connection with that operation. Contact details for data-related enquiries are in Section 14 of this Policy.

Personal Data We Collect

22ph1 collects personal data through several channels: the registration form, identity verification, payment processing, and your ongoing use of the platform. Here is a breakdown of the categories of data we collect and why:

Registration Data

When you create a 22ph1 account, we collect your full legal name, date of birth, email address, mobile number, and country of residence. This information is required to open and maintain your account.

Identity Verification Data

Before processing withdrawals — and at any point where compliance requires it — 22ph1 may collect copies of government-issued photo identification, proof of address, and documentation confirming ownership of your payment method. This supports Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations.

Financial and Transaction Data

We collect records of all deposits, withdrawals, and in-game transactions on your 22ph1 account. This includes amounts, timestamps, payment method identifiers (such as the last four digits of a card or a GCash account reference), and transaction outcomes.

Gaming Activity Data

22ph1 logs game session data, bet history, win and loss records, sports betting markets accessed, and time spent on the platform. This is used for account management, responsible gaming monitoring, dispute resolution, and platform improvement.

Device and Technical Data

When you access 22ph1, we automatically collect your IP address, device type, operating system, browser type, session timestamps, and referring URLs. This supports security, fraud prevention, and platform compatibility monitoring.

Communications Data

If you contact 22ph1 support, we retain a record of the communication — including the content of emails, chat transcripts, and any documents shared — for quality assurance and dispute resolution purposes.

How 22ph1 Uses Your Personal Data

22ph1 only uses your personal data for the purposes described below. We do not use your data in ways that go beyond what is necessary for these purposes:

22ph1 does not use your personal data for automated profiling that produces significant legal effects, nor do we send unsolicited third-party marketing communications using your data.

Legal Basis for Processing

Under the Philippine Data Privacy Act, 22ph1 must have a lawful basis for each type of data processing. The bases we rely on are:

• Contractual necessity: Processing required to create your 22ph1 account, operate your account, and process your transactions — this processing is necessary to fulfil the contract between you and 22ph1.
• Legal obligation: Processing required to comply with AML regulations, gaming licence conditions, tax reporting, and other applicable Philippine legal requirements.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and platform improvement — where 22ph1's interests in maintaining a safe and functional platform do not override your privacy rights.
• Consent: For specific optional communications or data uses where consent is sought separately — you may withdraw consent at any time without affecting the legality of prior processing.

Who 22ph1 Shares Your Data With

22ph1 does not sell personal data. We share data only with the categories of recipients listed below, and only to the extent necessary:

Payment Processors

To process deposits and withdrawals, 22ph1 shares relevant transaction data with Philippine payment processors — GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, and card payment networks. These processors handle your financial data under their own privacy policies and applicable financial regulations.

Identity Verification Providers

KYC and identity verification may be supported by third-party verification services. These providers process the documents and data you submit for verification purposes only and are bound by confidentiality obligations.

Game Content Providers

22ph1 uses third-party game providers — including JILI and live casino platform providers — whose software runs within the 22ph1 platform. Game session data may be processed by these providers to operate their games. Only the data necessary for game operation is shared.

Regulatory and Legal Authorities

22ph1 is required to share player data with Philippine gaming regulators, tax authorities, law enforcement, or courts when legally compelled to do so. We do not voluntarily disclose data to government bodies beyond what is legally required.

Fraud Prevention Services

To protect the platform and all users from fraud and money laundering, 22ph1 may use third-party fraud detection tools that process device data, IP addresses, and transaction patterns. These tools operate under data processing agreements that restrict their use of your data.

Cookies and Tracking Technologies

22ph1 uses cookies and similar tracking technologies on the platform. A cookie is a small text file stored on your device when you visit a website. Here is how we use them:

• Essential cookies: Required for the platform to function — session management, login state, and security tokens. These cannot be disabled without breaking platform functionality.
• Performance cookies: Collect anonymised data about how pages are used and where errors occur, helping us improve the 22ph1 platform.
• Functional cookies: Remember your preferences — such as language or display settings — to personalise your experience on return visits.
• Security cookies: Support fraud detection by tracking unusual session behaviour, device fingerprinting, and suspicious login patterns.

22ph1 does not use third-party advertising cookies or permit advertising networks to place tracking cookies on this platform. You can manage cookie preferences through your browser settings, though disabling essential cookies will affect platform functionality.

How Long We Keep Your Data

22ph1 retains personal data for as long as it is needed for the purpose it was collected, or as required by law. The general retention periods are:

• Active account data: Retained for the duration of your active 22ph1 account plus a minimum of five years after closure, to comply with AML and financial record-keeping requirements under Philippine law.
• KYC and verification documents: Retained for a minimum of five years after the end of the customer relationship, as required by AML regulations.
• Transaction records: Retained for a minimum of five years, consistent with financial record-keeping obligations.
• Customer support communications: Retained for three years following resolution of the relevant matter, unless a longer period is required for an ongoing dispute.
• Device and technical logs: Typically retained for 12 months, or longer if relevant to an active investigation.

After the applicable retention period, personal data is securely deleted or anonymised so it can no longer be linked to you.

How We Protect Your Data

22ph1 implements technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, and loss. These measures include:

• Encryption of data in transit using TLS
• Encrypted storage of sensitive account data
• Hashed password storage — plain-text passwords are never retained
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Monitoring and logging of access to systems holding personal data
• Regular security assessments of platform infrastructure

No online system can guarantee absolute security. If you believe your 22ph1 account has been compromised, change your password immediately and contact support at support@22ph1.best. We will investigate and respond as quickly as possible.

Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding the personal data 22ph1 holds about you:

To exercise any of these rights, submit a written request to support@22ph1.best with the subject line "Data Privacy Request". Include your full name and registered email address. 22ph1 will respond within 30 days. Some requests may require identity verification before we can process them.

Children's Privacy

22ph1 is strictly an adult platform. The minimum age for registration is 21 years old. We do not knowingly collect personal data from anyone under this age.

If we become aware that an account was registered by someone under 21, we will close the account immediately and delete all associated personal data, subject to any legal obligations to retain it for fraud or AML investigation purposes.

If you believe a minor has registered on 22ph1, please contact support@22ph1.best immediately with the relevant details.

Cross-Border Data Transfers

Some of the third-party service providers used by 22ph1 — including game content providers, fraud detection tools, and platform infrastructure providers — may process data in locations outside the Philippines. When this occurs, 22ph1 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine data protection law.

These safeguards may include contractual data processing agreements, adherence to recognised data protection frameworks, or other measures appropriate to the nature of the transfer. 22ph1 does not transfer your data to jurisdictions that have inadequate data protection standards without appropriate contractual protections in place.

Third-Party Links and Game Providers

The 22ph1 platform integrates games and tools from third-party providers. While these are embedded within the 22ph1 interface, each provider operates under its own data processing practices. 22ph1 is not responsible for the privacy practices of third-party game content providers beyond the data processing agreements we hold with them.

The 22ph1 platform does not include links to external third-party websites for general browsing. Any data you provide directly to a third party outside the 22ph1 platform is governed by that party's own privacy policy.

Updates to This Privacy Policy

22ph1 reviews this Privacy Policy periodically and may update it to reflect changes in our data practices, platform features, or applicable law. When material changes are made, we will notify registered players by email or through a platform notice before the changes take effect.

The updated Privacy Policy will be published at 22ph1.best/privacy-policy with a revised "Last updated" date. Your continued use of the platform after the effective date of any update constitutes your acceptance of the revised Policy.

If you disagree with changes to this Policy, you may request account closure before the changes take effect by contacting support@22ph1.best.

Contact Us and Data Protection Officer

For all questions, requests, or concerns relating to your personal data at 22ph1, contact us through the following:

• Email: support@22ph1.best
• Subject line for data requests: "Data Privacy Request"
• Response time: Within 30 calendar days of receiving a verified request

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC) — the Philippine data protection authority responsible for overseeing compliance with RA 10173.
• Details on the NPC complaints process are published on the NPC's official government website.