22phsky Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 22phsky ("22phsky," "we," "us," or "our") collects, uses, discloses, and safeguards the personal information of individuals ("you" or "Player") who access or use the 22phsky online gaming platform available at https://22phsky.org (the "Platform").

22phsky is committed to protecting the privacy and personal data of all Filipino players in accordance 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). By registering an account or using the Platform, you consent to the collection and use of your personal information as described in this Policy.

This Policy applies to all personal information collected through the Platform, including information provided during registration, account verification, deposits, withdrawals, customer support interactions, and general use of 22phsky services.

2. Information We Collect

22phsky collects the following categories of personal information:

• Registration Information: Full legal name, date of birth, gender, nationality, Philippine mobile number, and email address provided when you create a 22phsky account.
• Identity Verification Documents: Government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license), proof of address, and selfie verification images collected for KYC compliance and age verification purposes.
• Financial Information: GCash mobile number, PayMaya account reference, bank account name and number (BPI, BDO, Metrobank), and transaction history on the Platform. Full payment credentials are processed by your payment provider and are not stored on 22phsky servers.
• Gaming Activity Data: Game history, wager amounts, win/loss records, session duration, and responsible gaming tool usage (deposit limits, self-exclusion requests).
• Technical and Device Data: IP address, device type, operating system, browser type, mobile network operator, and geolocation data (city/region level) collected automatically when you access the Platform.
• Communications Data: Records of your interactions with 22phsky customer support, including live chat transcripts, email correspondence, and support ticket history.
• Cookies and Usage Data: Session cookies, preference cookies, and analytics data as described in Section 6 of this Policy.

3. How We Use Your Information

22phsky uses your personal information for the following purposes:

• Account Management: To create, verify, and maintain your 22phsky player account, including processing your registration and authenticating your identity at login.
• Age and Identity Verification: To verify that you meet the minimum age requirement of 21 years and to comply with KYC obligations under applicable regulations.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and to maintain accurate financial records of all transactions.
• Gaming Services: To provide access to all games and betting markets on the Platform, to calculate and credit winnings, and to apply bonus and promotional entitlements.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, to enforce self-exclusion requests, and to apply deposit and session limits set by the player.
• Legal and Regulatory Compliance: To comply with PAGCOR regulatory requirements, anti-money laundering (AML) obligations, and any lawful requests from Philippine government authorities.
• Platform Improvement: To analyze usage patterns, identify technical issues, and improve the performance, security, and user experience of the 22phsky Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates via email or SMS, where you have provided consent. You may opt out of marketing communications at any time.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform the contract between you and 22phsky (i.e., to provide the gaming services you have registered for).
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including KYC, AML, and PAGCOR regulatory requirements.
• Legitimate Interests: Processing is necessary for 22phsky's legitimate interests in operating a secure, fair, and compliant gaming platform, provided such interests are not overridden by your privacy rights.
• Consent: For marketing communications and non-essential cookies, processing is based on your explicit consent, which you may withdraw at any time.

5. Sharing of Personal Information

22phsky does not sell, rent, or trade your personal information to third-party marketers or data brokers. We may share your personal information with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Service Providers: GCash (Mynt), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank, for the purpose of processing deposits and withdrawals.
• Identity Verification Partners: Third-party KYC service providers engaged to assist with document verification and age confirmation, subject to strict data processing agreements.
• Technology and Infrastructure Providers: Cloud hosting, cybersecurity, and platform technology vendors who process data on our behalf under binding data processing agreements.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Legal and Professional Advisors: Lawyers, auditors, and compliance consultants engaged by 22phsky, subject to professional confidentiality obligations.

All third-party service providers engaged by 22phsky are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with 22phsky's instructions and applicable Philippine data protection law.

6. Cookies and Tracking Technologies

22phsky uses cookies and similar technologies (including local storage and session tokens) on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function correctly, including maintaining your login session, remembering your language preferences, and ensuring platform security. These cookies cannot be disabled.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, including pages visited, session duration, and navigation paths. This data helps us improve the Platform experience.
• Preference Cookies: Used to remember your settings and preferences on the Platform, such as your preferred game category or display settings.

22phsky does not use third-party advertising cookies or cross-site tracking technologies. You may manage cookie preferences through your browser settings; however, disabling essential cookies may affect the functionality of the Platform.

7. Data Retention

22phsky retains your personal information for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account registration and KYC data is retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Marketing consent records are retained for the duration of your account and for one (1) year following opt-out.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 22phsky's data disposal procedures.

8. Data Security

22phsky implements a comprehensive set of technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• AES-256 encryption for data at rest and TLS 1.3 for data in transit.
• Multi-factor authentication (MFA) for administrative access to systems containing personal data.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity firms.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• 24/7 security monitoring and intrusion detection systems.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 22phsky will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular 16-03.

9. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal information held by 22phsky:

• Right to be Informed: The right to be informed of how your personal data is collected, used, and processed, as described in this Policy.
• Right of Access: The right to request a copy of the personal information 22phsky holds about you.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal information in your 22phsky account.
• Right to Erasure: The right to request deletion of your personal data, subject to 22phsky's legal and regulatory retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact 22phsky's Data Privacy Officer at the email address provided in Section 12 of this Policy. We will respond to all verified data subject requests within fifteen (15) business days.

10. Children's Privacy and Age Restriction

The 22phsky Platform is strictly intended for individuals who are 21 years of age or older. 22phsky does not knowingly collect personal information from any person under the age of 21. If we become aware that personal data has been collected from an underage individual, we will immediately close the associated account, delete the personal data, and forfeit any associated balances in accordance with our Terms and Conditions.

If you believe that a minor has registered on the 22phsky Platform, please contact our support team immediately at the email address provided in Section 12 so that we can take prompt corrective action.

11. Changes to This Privacy Policy

22phsky reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The date of the most recent revision will be indicated at the top of this page. Where changes are material, 22phsky will notify registered players via email or an in-platform notification prior to the changes taking effect.

Your continued use of the 22phsky Platform following the posting of any amendments to this Policy constitutes your acknowledgment of the updated terms. We encourage you to review this Policy periodically to stay informed about how we protect your personal information.

12. Contact and Data Privacy Officer

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

Data Privacy Officer – 22phsky
Email: [email protected]

All data subject requests and privacy-related inquiries will be acknowledged within five (5) business days and resolved within fifteen (15) business days of receipt of a complete and verified request. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC).