Privacy Policy

1. Introduction

20ph ("we," "us," "our," or the "Company") operates an online gaming platform licensed by the Philippine Amusement and Gaming Corporation (PAGCOR). This Privacy Policy governs the collection, processing, storage, and protection of personal data collected from users ("you," "your," or "User") of our website, mobile applications, and related services (collectively, the "Platform").

By accessing or using the 20ph Platform, creating an account, or providing personal information to us, you acknowledge that you have read, understood, and consent to the data processing practices described in this Privacy Policy. If you do not agree with any aspect of this Privacy Policy, you must immediately cease using our services and refrain from providing any personal information.

This Privacy Policy is designed to comply with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, PAGCOR directives, and international data protection standards including the General Data Protection Regulation (GDPR) where applicable to Philippine users.

2. Information We Collect

20ph collects various types of personal data necessary to provide gaming services, ensure regulatory compliance, prevent fraud, and enhance user experience. The categories of information we collect include:

2.1 Account Registration Information

When you create an account with 20ph, we collect personal information including:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers
• Contact Information: Residential address, email address, mobile phone number, and preferred communication methods
• Authentication Credentials: Username, password (stored in encrypted format), and security questions
• Verification Documents: Scanned copies or photographs of Philippine government-issued identification cards (driver's license, passport, UMID, Postal ID), proof of address documents, and selfie photographs

2.2 Financial and Transaction Data

To process deposits, withdrawals, and gaming transactions, we collect:

• Payment Information: Bank account details, GCash or PayMaya account information, cryptocurrency wallet addresses, and payment card information (stored securely through PCI-DSS compliant payment processors)
• Transaction History: Records of deposits, withdrawals, wagers, winnings, bonuses claimed, and account balance changes
• Financial Verification: Source of funds documentation for large transactions or as required by anti-money laundering regulations

2.3 Gaming Activity Data

We collect information about your gaming behavior and preferences:

• Game Play Records: Games played, bet amounts, game outcomes, session duration, and gaming patterns
• Promotional Activity: Bonuses accepted, promotional codes used, and participation in tournaments or special events
• Responsible Gaming Data: Deposit limits set, self-exclusion requests, reality check settings, and gaming session time tracking

2.4 Technical and Usage Information

We automatically collect technical data when you access our Platform:

• Device Information: Device type, operating system, browser type and version, screen resolution, and unique device identifiers
• Network Data: IP address, geographic location (derived from IP), internet service provider, and connection type
• Usage Analytics: Pages visited, time spent on pages, navigation paths, clickstream data, and referral sources
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, and similar tracking technologies (detailed in Section 6)

2.5 Communications and Support

When you contact our customer support or communicate with us:

• Support Tickets: Content of your inquiries, complaints, feedback, and our responses
• Live Chat Transcripts: Conversations with customer support representatives
• Email Correspondence: Messages exchanged between you and 20ph
• Survey Responses: Feedback provided through customer satisfaction surveys or promotional surveys

2.6 Marketing and Preference Data

• Marketing Consent: Your preferences regarding promotional emails, SMS messages, push notifications, and other marketing communications
• Preference Settings: Language preferences, notification settings, and personalization choices

3. How We Use Your Data

20ph processes your personal data for specific, legitimate purposes in accordance with data protection principles. We use your information for the following purposes:

3.1 Account Management and Service Provision

• Creating, maintaining, and authenticating your gaming account
• Processing deposits, withdrawals, and financial transactions
• Providing access to games, features, and services on the Platform
• Managing bonuses, promotions, and loyalty programs
• Responding to customer support inquiries and resolving disputes
• Sending transactional communications (account confirmations, withdrawal notifications, password resets)

3.2 Regulatory Compliance and Legal Obligations

• Verifying your identity and age to comply with PAGCOR requirements
• Conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures
• Monitoring transactions for anti-money laundering (AML) and counter-terrorist financing (CTF) compliance
• Reporting suspicious activities to the Anti-Money Laundering Council (AMLC) as required by law
• Maintaining records as mandated by gaming regulations and tax laws
• Responding to lawful requests from government authorities, regulators, and law enforcement agencies

3.3 Fraud Prevention and Security

• Detecting and preventing fraudulent activities, unauthorized access, and policy violations
• Identifying multiple accounts, bonus abuse, and collusion between players
• Protecting against cyber threats, hacking attempts, and security breaches
• Investigating suspicious betting patterns and potential game manipulation
• Enforcing our Terms and Conditions and protecting intellectual property rights

3.4 Responsible Gaming and Player Protection

• Implementing responsible gaming tools (deposit limits, time limits, self-exclusion)
• Monitoring gaming behavior for signs of problem gambling
• Providing access to responsible gaming resources and support organizations
• Enforcing age restrictions to prevent underage gambling

3.5 Marketing and Personalization

With your explicit consent, we use your data to:

• Send promotional emails, SMS messages, and push notifications about bonuses, new games, and special offers
• Personalize content and recommendations based on your gaming preferences and history
• Conduct market research and customer satisfaction surveys
• Analyze marketing campaign effectiveness and optimize promotional strategies

You may withdraw marketing consent at any time through account settings or by contacting support.

3.6 Platform Improvement and Analytics

• Analyzing user behavior and gaming patterns to improve services and user experience
• Testing new features, games, and functionalities
• Identifying technical issues, bugs, and performance bottlenecks
• Conducting statistical analysis and generating aggregate reports (without personally identifying individuals)

4. Data Storage and Security

20ph implements robust technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

4.1 Security Measures

• Encryption: All sensitive data, including passwords and payment information, is encrypted using industry-standard AES-256 encryption both in transit (via TLS/SSL protocols) and at rest
• Access Controls: Strict role-based access controls limit employee access to personal data based on job responsibilities and business necessity
• Authentication: Multi-factor authentication for employee access to systems containing personal data
• Network Security: Firewalls, intrusion detection systems, and regular security audits protect our infrastructure
• Secure Payment Processing: Payment card data is processed through PCI-DSS Level 1 certified payment processors; 20ph does not store complete payment card numbers
• Regular Testing: Penetration testing, vulnerability assessments, and security audits conducted by independent third parties
• Incident Response: Comprehensive data breach response plan with notification procedures as required by the Data Privacy Act

4.2 Data Storage Locations

Your personal data is stored on secure servers located in jurisdictions with adequate data protection standards. Primary data centers are located in the Philippines, with backup systems in secure offshore locations. All data transfers comply with Philippine data protection laws and include appropriate safeguards such as Standard Contractual Clauses.

4.3 Third-Party Security

Third-party service providers with access to personal data (payment processors, cloud hosting providers, customer support platforms) are contractually obligated to maintain equivalent security standards and use data only for specified purposes. 20ph conducts due diligence assessments of all vendors handling personal data.

5. Data Sharing and Disclosure

20ph does not sell, rent, or trade your personal information to third parties for their marketing purposes. We share personal data only in the following circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to perform functions on our behalf:

• Payment Processors: GCash, PayMaya, banking partners, and cryptocurrency payment gateways to process financial transactions
• Game Providers: Third-party gaming software developers and live casino operators
• Cloud Infrastructure: Hosting providers for data storage and platform infrastructure
• Customer Support: Customer relationship management (CRM) platforms and live chat service providers
• Marketing Services: Email service providers, SMS gateways, and analytics platforms
• Identity Verification: Third-party verification services for KYC and age verification

These service providers operate under strict data processing agreements and are prohibited from using your personal data for purposes other than providing services to 20ph.

5.2 Regulatory and Legal Disclosures

We disclose personal data when required by law or to protect legal rights:

• PAGCOR and other gaming regulators for license compliance and audits
• Anti-Money Laundering Council (AMLC) for suspicious transaction reporting
• Bureau of Internal Revenue (BIR) for tax compliance and withholding tax reporting
• Law enforcement agencies pursuant to valid court orders, subpoenas, or warrants
• National Privacy Commission in response to investigations or complaints
• Legal counsel in connection with actual or threatened litigation

5.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or bankruptcy, your personal data may be transferred to successor entities. You will be notified via email and prominent notice on the Platform before your data is transferred and becomes subject to a different privacy policy.

5.4 Aggregate and De-identified Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you for research, statistical analysis, marketing, or other business purposes without restriction.

6. Cookies and Tracking Technologies

20ph uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance user experience, analyze Platform usage, and deliver personalized content.

6.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Enable core functionality such as account login, session management, and security features. These cookies are necessary for the Platform to function.	Session or up to 30 days
Performance Cookies	Collect information about Platform usage, page load times, and error messages to improve performance and user experience.	Up to 2 years
Functionality Cookies	Remember your preferences (language, region, username) and provide enhanced, personalized features.	Up to 1 year
Advertising Cookies	Track browsing behavior across websites to deliver targeted advertisements and measure campaign effectiveness. These are used only with your consent.	Up to 1 year

6.2 Managing Cookie Preferences

You can control cookie settings through your browser preferences. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies may affect Platform functionality and your ability to access certain features. Disabling performance or advertising cookies will not prevent you from using the Platform.

6.3 Third-Party Cookies

Third-party service providers (analytics platforms, advertising networks, social media plugins) may set cookies through the Platform. These cookies are governed by the respective third parties' privacy policies. 20ph does not control third-party cookies and recommends reviewing their privacy policies.

7. Your Privacy Rights

Under the Data Privacy Act of 2012, you have specific rights regarding your personal data. 20ph is committed to facilitating the exercise of these rights.

7.1 Right to Access

You have the right to request confirmation of whether we process your personal data and to obtain access to such data. You may request copies of your personal information by contacting our Data Protection Officer.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. You may update most personal information directly through your account settings. For information that cannot be updated through your account, contact customer support.

7.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or when you withdraw consent. However, we may retain certain data when required by law, for regulatory compliance, or to resolve disputes. Specific retention requirements are detailed in Section 8.

7.4 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time by clicking unsubscribe links in emails, adjusting notification settings in your account, or contacting support.

7.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller. Data portability requests can be submitted to our Data Protection Officer.

7.6 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

7.7 Right to Lodge a Complaint

You have the right to lodge a complaint with the National Privacy Commission if you believe your data protection rights have been violated. Contact information: National Privacy Commission, 5th Floor, Philippine International Convention Center (PICC), Vicente Sotto Avenue, Pasay City, Metro Manila, Philippines; Email: [email protected].

7.8 Exercising Your Rights

To exercise any privacy right, contact our Data Protection Officer at [email protected] with "Privacy Rights Request" in the subject line. Requests will be processed within thirty (30) calendar days. We may request additional information to verify your identity before processing requests.

8. Data Retention

20ph retains personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements.

8.1 Retention Periods

• Active Accounts: Personal data is retained for the duration of your active account and for six (6) years following account closure to comply with PAGCOR record-keeping requirements and tax laws
• Transaction Records: Financial transaction data is retained for ten (10) years as required by anti-money laundering regulations
• Identity Verification Documents: KYC documentation is retained for seven (7) years following account closure or last transaction
• Gaming Activity Logs: Game play records and betting history are retained for five (5) years for regulatory compliance and dispute resolution
• Marketing Communications: Marketing preference data is retained until you withdraw consent or request deletion
• Support Communications: Customer support tickets and chat transcripts are retained for three (3) years for quality assurance and dispute resolution

8.2 Secure Deletion

Upon expiration of applicable retention periods, personal data is securely deleted or anonymized using industry-standard data destruction methods including secure overwriting, degaussing, or physical destruction of storage media.

9. Children's Privacy

20ph strictly prohibits use of our Platform by individuals under twenty-one (21) years of age. We do not knowingly collect personal information from minors. Our age verification procedures are designed to prevent underage access.

If we become aware that we have inadvertently collected personal data from an individual under 21 years of age, we will immediately delete such information from our systems and permanently close the associated account without prior notice. Any winnings or deposits will be forfeited in accordance with our Terms and Conditions.

Parents or guardians who believe a minor has provided personal information to 20ph should immediately contact our Data Protection Officer at [email protected].

10. International Data Transfers

Your personal data may be transferred to and processed in countries outside the Philippines where our service providers, data centers, or business partners are located. These jurisdictions may have different data protection standards than the Philippines.

When transferring personal data internationally, 20ph implements appropriate safeguards to ensure adequate protection:

• Transfers to countries recognized by the National Privacy Commission as having adequate data protection frameworks
• Use of Standard Contractual Clauses approved by the European Commission and adopted for Philippine data transfers
• Binding Corporate Rules for transfers within corporate groups
• Explicit consent for transfers to jurisdictions without adequate safeguards, where required by law

By using the 20ph Platform, you acknowledge and consent to the international transfer of your personal data as described in this Privacy Policy.

11. Changes to This Privacy Policy

20ph reserves the right to modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. Material changes will be communicated through:

• Email notification to registered account holders
• Prominent notice on the Platform homepage
• In-app notifications for mobile users
• Updated "Last Modified" date at the top of this Privacy Policy

Continued use of the Platform following notification of changes constitutes acceptance of the modified Privacy Policy. If you do not agree with changes, you must cease using the Platform and may request account closure and data deletion, subject to applicable retention requirements.

We recommend reviewing this Privacy Policy periodically to stay informed about how we protect your personal information.

12. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact:

When contacting us regarding privacy matters, please include your account username (if applicable) and a detailed description of your inquiry or request. We will respond to all privacy-related inquiries within thirty (30) calendar days as required by the Data Privacy Act.