Privacy Policy

1. Introduction

22pub ("we," "us," or "our") operates the online gaming platform accessible at https://22pub.app (the "Platform"). We are committed to protecting the privacy and personal data of all users ("you" or "Player") who access or use the 22pub Platform.

This Privacy Policy describes how 22pub collects, uses, stores, discloses, and protects your personal information in connection with your use of the Platform. It applies to all players registered on 22pub, including those accessing the Platform from Manila, Cebu, Davao, Quezon City, Makati, and all other locations across the Philippines.

By registering on or using the 22pub Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, please do not use the Platform.

2. Personal Data We Collect

2.1 Registration Data

When you create a 22pub account, we collect the following information:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Mobile number and/or email address
• Username and encrypted password
• Residential address
• Nationality and country of residence

2.2 Identity Verification (KYC) Data

To comply with our regulatory obligations and to protect against fraud, we may collect:

• Government-issued photo identification (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's license, UMID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or live photo for identity verification purposes
• Proof of payment method ownership

2.3 Financial Data

When you make deposits or withdrawals, we collect transaction-related information including payment method details (e.g., GCash account reference, BPI/BDO/Metrobank account details, PayMaya reference), transaction amounts in Philippine Peso (PHP), and transaction history.

2.4 Usage and Technical Data

We automatically collect certain technical data when you use the Platform, including:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, features used, and time spent on the Platform
• Game history, wagering activity, and session logs
• Login timestamps and access logs

2.5 Communications Data

If you contact our customer support team, we retain records of your communications, including chat transcripts, emails, and any information you provide in the course of seeking assistance.

3. How We Collect Your Data

22pub collects your personal data through the following means:

• Directly from you — when you register, complete KYC verification, make transactions, contact support, or participate in promotions.
• Automatically — through cookies, web beacons, log files, and similar tracking technologies when you access and use the Platform.
• From third parties — including identity verification service providers, payment processors, fraud prevention services, and regulatory authorities where permitted by law.

4. How We Use Your Personal Data

22pub uses your personal data for the following purposes:

• To create and manage your 22pub account and verify your identity.
• To process deposits, withdrawals, and other financial transactions.
• To comply with our legal and regulatory obligations, including anti-money laundering (AML) requirements and PAGCOR regulatory requirements.
• To verify that you meet the minimum age requirement of 21 years.
• To detect, investigate, and prevent fraud, cheating, and other prohibited conduct.
• To provide customer support and respond to your inquiries.
• To send you service-related communications, including account notifications and security alerts.
• To send you promotional communications about 22pub offers and bonuses, where you have consented to receive such communications.
• To improve and personalize your experience on the Platform.
• To conduct internal analytics and research to enhance our services.
• To enforce our Terms & Conditions and other applicable policies.

5. Legal Basis for Processing

22pub processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity — processing is necessary to perform our contract with you (i.e., to provide the 22pub gaming services).
• Legal obligation — processing is required to comply with applicable laws and regulations, including AML laws and PAGCOR requirements.
• Legitimate interests — processing is necessary for our legitimate business interests, such as fraud prevention, security, and service improvement, provided these interests are not overridden by your rights.
• Consent — where we rely on your consent (e.g., for marketing communications), you have the right to withdraw that consent at any time.

6. Data Sharing and Disclosure

22pub does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only where necessary and in accordance with applicable law:

• Payment processors — to facilitate deposits and withdrawals (e.g., GCash, PayMaya, BPI, BDO, Metrobank).
• Identity verification providers — to conduct KYC checks and age verification.
• Fraud prevention and security services — to detect and prevent fraudulent activity.
• IT and platform service providers — who assist in operating and maintaining the 22pub Platform under strict data processing agreements.
• Regulatory and law enforcement authorities — where required by law, court order, or regulatory instruction, including PAGCOR and the Anti-Money Laundering Council (AMLC).
• Professional advisers — including lawyers, auditors, and accountants, subject to professional confidentiality obligations.

All third parties with whom we share personal data are required to handle it in accordance with applicable data protection laws and our data processing requirements.

7. Cookies and Tracking Technologies

22pub uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

7.1 Types of Cookies We Use

• Essential cookies — necessary for the Platform to function correctly, including session management and security features.
• Analytics cookies — help us understand how players use the Platform so we can improve it.
• Preference cookies — remember your settings and preferences for a more personalized experience.
• Marketing cookies — used to deliver relevant promotional content, where you have consented.

You can control cookie settings through your browser. Note that disabling certain cookies may affect the functionality of the Platform.

8. Data Retention

22pub retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and KYC data is retained for a minimum of five (5) years following account closure, as required under Philippine AML regulations.
• Transaction records are retained for a minimum of five (5) years.
• Communications data is retained for as long as necessary to resolve any disputes and for a reasonable period thereafter.

When personal data is no longer required, 22pub will securely delete or anonymize it in accordance with our data retention procedures.

9. Data Security

22pub implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including passwords and financial information.
• Access controls limiting data access to authorized personnel only.
• Regular security assessments and penetration testing.
• Incident response procedures to address any data security breaches promptly.

While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. We encourage you to use a strong, unique password for your 22pub account and to keep your login credentials confidential.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 22pub:

• Right to be informed — you have the right to know what personal data we collect and how it is used.
• Right of access — you may request a copy of the personal data we hold 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, subject to our legal retention obligations.
• Right to object — you may object to the processing of your personal data for direct marketing purposes.
• Right to data portability — you may request a copy of your personal data in a structured, commonly used format.
• Right to lodge a complaint — you have 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 our Data Protection Officer via the contact details provided in Section 14 of this Policy. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

11. Children's Privacy

The 22pub Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a person under 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately.

12. Third-Party Links

The 22pub Platform may contain links to third-party websites or services. This Privacy Policy applies solely to the 22pub Platform. We are not responsible for the privacy practices of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

22pub reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will notify registered players via email or a prominent notice on the Platform, and update the "Last Updated" date at the top of this page. Your continued use of the Platform following the posting of changes constitutes your acceptance of the revised Privacy Policy.

14. Contact Us / Data Protection Officer

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