Privacy Policy

21ph ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of every player who uses our online casino and sports betting platform at https://21ph.app. This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC).

This Privacy Policy applies to all personal information collected through the 21ph website, mobile browser experience, customer support channels, and any other interaction you have with the 21ph Platform. It covers players based in Manila, Cebu, Davao, Quezon City, Makati, and all other locations across the Philippines where 21ph services are accessible.

By registering an account on 21ph, making a deposit, or otherwise using our Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

21ph collects only the personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by law (for example, information relevant to responsible gaming assessments).

21ph collects personal data through the following means:

• Direct interactions: When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or respond to a survey or promotion on the 21ph Platform.
• Automated technologies: As you interact with the 21ph Platform, we automatically collect technical and usage data through cookies, server logs, and similar tracking technologies. See Section 9 for more details on our cookie practices.
• Third-party sources: We may receive data about you from identity verification providers, payment processors (such as GCash and PayMaya), fraud prevention services, and analytics partners — all of whom are bound by confidentiality obligations.
• KYC and AML checks: As required by Philippine gaming regulations and anti-money laundering laws, we may obtain data from government databases or third-party verification services to confirm your identity and the legitimacy of your funds.

21ph uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your 21ph player account, including verifying your identity and age (21+ requirement).
• Service delivery: To provide access to games, process bets, calculate winnings, and deliver the full 21ph gaming experience to players across the Philippines.
• Payment processing: To process deposits and withdrawals in Philippine Peso (₱) via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Legal and regulatory compliance: To comply with applicable Philippine laws, including the Data Privacy Act of 2012, anti-money laundering regulations, and gaming regulatory requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the 21ph Platform.
• Responsible gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion orders, and identify players who may need support.
• Customer support: To respond to your queries, resolve disputes, and improve the quality of our support services.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your explicit consent. You may opt out at any time.
• Platform improvement: To analyze usage patterns and improve the performance, design, and features of the 21ph Platform.

Under the Data Privacy Act of 2012 (RA 10173), 21ph processes your personal data on the following legal bases:

• Consent: Where you have given clear, informed consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary to perform our contract with you — i.e., to operate your 21ph account, process transactions, and deliver gaming services.
• Legal obligation: Where processing is required to comply with a legal obligation under Philippine law, including KYC, AML, and gaming regulatory requirements.
• Legitimate interests: Where processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.

21ph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers who assist us in verifying your identity and complying with Philippine regulatory requirements.
• Technology and hosting providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Game software providers: Licensed game developers whose software powers games on the 21ph Platform. These providers may receive limited technical data necessary to deliver the game experience.
• Regulatory and law enforcement authorities: Philippine government agencies, including the National Privacy Commission, gaming regulatory bodies, and law enforcement, where required by law or court order.
• Professional advisors: Lawyers, auditors, and accountants who are bound by professional confidentiality obligations.

Any third party that receives your personal data from 21ph is contractually required to handle it in accordance with the Data Privacy Act of 2012 and to use it only for the specific purpose for which it was shared.

21ph retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Our general retention periods are as follows:

When your personal data is no longer required, 21ph will securely delete or anonymize it in accordance with our data disposal procedures.

21ph takes the security of your personal data seriously. We implement a range of technical and organizational measures to protect your data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your device and the 21ph Platform is encrypted using industry-standard 256-bit SSL/TLS technology.
• Access controls: Access to personal data is restricted to authorized 21ph personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Secure data storage: Personal data is stored on secure servers with multiple layers of physical and logical access controls.
• Regular security audits: 21ph conducts regular security assessments and penetration testing to identify and address potential vulnerabilities.
• Incident response: In the event of a personal data breach, 21ph will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

While we take every reasonable precaution to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your 21ph login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

21ph uses cookies and similar tracking technologies to enhance your experience on the Platform, ensure security, and gather analytics data that helps us improve our services. A cookie is a small text file placed on your device when you visit the 21ph website.

We use the following categories of cookies:

• Strictly necessary cookies: These are essential for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Performance and analytics cookies: These cookies collect anonymized information about how players use the 21ph Platform — such as which pages are visited most frequently and how long sessions last. This data helps us optimize the Platform experience.
• Functional cookies: These cookies remember your preferences, such as your preferred language or display settings, to provide a more personalized experience on 21ph.
• Marketing cookies: With your consent, we may use cookies to deliver relevant promotional content about 21ph games and offers. You may withdraw this consent at any time.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 21ph Platform. For more information on managing cookies, refer to your browser's help documentation.

Under the Data Privacy Act of 2012 (RA 10173), Filipino players have the following rights with respect to their personal data held by 21ph:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data that 21ph holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request that inaccurate or incomplete personal data held by 21ph be corrected or updated.
• Right to erasure: In certain circumstances, you have the right to request the deletion of your personal data. Note that this right may be limited where retention is required by law (e.g., AML record-keeping obligations).
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• 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 it to another data controller where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 21ph has violated your data privacy rights.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will respond to all verified requests within thirty (30) days in accordance with the requirements of RA 10173.

The 21ph Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. This requirement is consistent with Philippine gaming regulations governing online casino and sports betting platforms.

As part of our registration and KYC process, all players are required to provide a valid Philippine government-issued ID to verify that they meet the 21+ age requirement. Acceptable IDs include a Passport, Driver's License, SSS ID, GSIS ID, or PhilHealth ID.

If 21ph discovers that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, delete the personal data in question, and take appropriate action in accordance with our Terms & Conditions and applicable Philippine law.

21ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players via email or through a prominent notice on the 21ph Platform prior to the changes taking effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage all 21ph players to review this Privacy Policy periodically to stay informed about how we protect their personal data. Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 21ph handles your personal data, please contact our Data Protection Officer (DPO). Our DPO is responsible for overseeing 21ph's compliance with the Data Privacy Act of 2012 and is your primary point of contact for all data privacy matters.

When submitting a data privacy request, please include your registered 21ph username, a clear description of your request, and a copy of a valid government-issued ID for identity verification purposes. We will acknowledge your request within five (5) business days and provide a full response within thirty (30) days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the government body responsible for enforcing the Data Privacy Act of 2012.