21ph Privacy Policy

1. About This Privacy Policy

This Privacy Policy ("Policy") applies to all personal information collected by 21ph through the 21ph.vip website, its sub-pages, and any related digital services operated under the 21ph brand ("the Platform"). The Policy describes our practices as a data controller in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations.

By accessing or using the 21ph Platform, creating an account, making a deposit, or participating in any promotional programme offered by 21ph, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal information as described herein.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming policy, which together govern your use of the 21ph Platform.

2. Personal Data We Collect

21ph collects personal data through the following channels: account registration, KYC verification, payment processing, platform usage, and customer support interactions. The categories of data we collect are described below.

2.1 Data You Provide Voluntarily

You provide some data voluntarily during the registration process and when contacting customer support. This includes your chosen username, mobile number, and any correspondence you initiate with the 21ph support team.

2.2 Data Collected Automatically

When you access the 21ph Platform, certain technical information is collected automatically by our servers and analytics systems, including your IP address, the type and version of browser you are using, your device operating system, pages visited, time spent on each section, and your general geographic location (city/province level, derived from IP address).

3. How We Use Your Personal Data

21ph uses personal data collected from players for the following purposes:

• Account Management: Creating, maintaining, and securing your 21ph account, including authentication and password recovery;
• KYC & Regulatory Compliance: Verifying your identity and age (21+) in accordance with PAGCOR licensing requirements and the Anti-Money Laundering Act (Republic Act No. 9160, as amended);
• Payment Processing: Processing deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other accepted payment methods;
• Game Provision: Delivering casino games, live dealer content, bingo, and slot games to your account and recording game outcomes and transaction history;
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent transactions, account compromise, bonus abuse, and other prohibited conduct;
• Responsible Gaming: Monitoring account activity for indicators of problem gambling behaviour; delivering responsible gaming tools such as deposit limits and self-exclusion; and fulfilling our obligations under PAGCOR's responsible gaming standards;
• Customer Support: Responding to enquiries, resolving disputes, and providing technical assistance to players in Manila, Cebu, Davao, and across the Philippines;
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to your registered mobile number — only where you have not opted out of such communications;
• Legal Obligations: Complying with PAGCOR regulatory requirements, AMLC reporting obligations, court orders, and any other applicable Philippine legal obligations.

4. Legal Basis for Processing

21ph processes personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you under the 21ph Terms & Conditions — including account management, game delivery, and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR's licensing conditions, AMLC reporting requirements, and other applicable Philippine law;
• Legitimate Interests: Processing necessary for 21ph's legitimate business interests, including fraud prevention, platform security, and service improvement — where such interests are not overridden by your rights and freedoms;
• Consent: Processing based on your explicit consent, including marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Sharing Your Personal Data

21ph does not sell or rent personal data to third parties. We share personal data only in the following limited circumstances:

5.1 Payment Service Providers

To process deposits and withdrawals, 21ph shares necessary financial transaction data with payment service providers including GCash (G-Xchange Inc.), Maya (Voyager Innovations Inc.), BPI, BDO, Metrobank, and other accepted payment channels. Each provider processes your data under their own privacy policies and applicable Philippine financial regulations.

5.2 Game Content Providers

21ph's game library is powered by third-party game studios (including Pragmatic Play, PG Soft, Evolution, and others). These providers receive limited technical data (such as a hashed player identifier and game session data) necessary to deliver game content. Game providers do not receive your full identity or financial data.

5.3 Regulatory Authorities

21ph is required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government authorities where required by law, court order, or regulatory directive.

5.4 Professional Advisers

We may share personal data with lawyers, accountants, auditors, or other professional advisers where necessary for legal, compliance, or audit purposes. All such parties are bound by confidentiality obligations.

5.5 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 21ph's assets, player personal data may be transferred to the successor entity. 21ph will notify affected players of any such transfer via the registered mobile number before personal data is transferred and subjected to a different privacy policy.

6. Data Retention

21ph retains personal data for the periods necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods imposed by Philippine law:

• KYC and identity documents: Retained for a minimum of five (5) years following account closure, as required by PAGCOR's AML rules;
• Financial transaction records: Retained for a minimum of five (5) years following the transaction date, as required by the Anti-Money Laundering Act;
• Account and gameplay records: Retained for the duration of the active account relationship plus three (3) years following account closure;
• Customer support communications: Retained for two (2) years following resolution of the relevant support interaction;
• Marketing consent records: Retained for the duration of the account relationship or until consent is withdrawn, whichever is earlier.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 21ph's data disposal procedures.

7. Cookies & Tracking Technologies

7.1 Types of Cookies Used

21ph uses the following categories of cookies and similar tracking technologies on the Platform:

• Strictly Necessary Cookies: Required for the Platform to function — including session authentication, security tokens, and load balancing. These cannot be disabled without breaking core platform functionality;
• Functional Cookies: Remember your preferences such as language settings and game lobby filters;
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate and use the Platform, used to improve user experience;
• Security Cookies: Used to detect fraud, protect against bot activity, and prevent unauthorised account access.

7.2 Cookie Management

You may control non-essential cookies through your browser settings. Note that disabling certain cookies may impair the functionality of some Platform features. 21ph does not use third-party advertising cookies or cross-site tracking for advertising purposes.

8. Security Measures

21ph implements industry-standard technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, and destruction:

• All data in transit is encrypted using TLS 1.2 or higher;
• Passwords are stored using one-way cryptographic hashing with salting;
• Payment card and e-wallet data is processed by PCI-DSS compliant payment processors — 21ph does not store full payment credentials;
• Access to personal data is restricted to authorised 21ph staff on a need-to-know basis;
• Two-factor authentication (2FA) is available to all players and mandatory for all 21ph internal staff accounts;
• Regular security audits and penetration testing are conducted on platform infrastructure;
• A data breach response plan is maintained and tested in accordance with NPC reporting requirements under RA 10173.

9. Your Data Protection Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 21ph:

• Right to be Informed: You have the right to be informed about how your personal data is collected and processed — as described in this Policy;
• Right of Access: You may request a copy of the personal data 21ph holds about you;
• Right to Rectification: You may request correction of inaccurate or incomplete personal data;
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to Object: You may object to the processing of your personal data for marketing purposes at any time;
• Right to Data Portability: You may request a copy of personal data you have provided to 21ph in a structured, commonly used format;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (privacy.gov.ph) if you believe your data rights have been violated.

To exercise any of the above rights, please contact 21ph's Data Protection Officer at [email protected]. We will respond to all verified data rights requests within fifteen (15) business days.

10. Minors

If you are a parent or guardian and believe your child has registered on 21ph, please contact us immediately at [email protected] with the relevant account details and we will take immediate action to close the account and delete all associated data.

11. Updates to This Privacy Policy

21ph reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or Platform features. The date of the most recent update is displayed at the top of this page.

Where material changes are made to this Policy, 21ph will notify registered players via SMS to their registered Philippine mobile number. Your continued use of the 21ph Platform following notification of any policy update constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how 21ph protects your personal information.

12. Contact Our Data Protection Officer

For any questions, concerns, or requests regarding this Privacy Policy or the personal data 21ph holds about you, please contact our Data Protection Officer:

For complaints regarding data privacy violations, you may also contact the National Privacy Commission of the Philippines. 21ph cooperates fully with all NPC investigations.