22win Privacy Policy

1. Introduction

Welcome to 22win. This Privacy Policy ("Policy") describes how 22win ("we", "us", "our", "the Platform") collects, uses, stores, and protects the personal information of users ("you", "your") who access or use the 22win website, mobile platform, and all associated services (collectively, the "Services").

We are committed to protecting your personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and all applicable data protection regulations. By registering an account or using our Services, you consent to the collection and use of your information as described in this Policy.

Please read this Policy carefully. If you do not agree with the terms outlined here, you should discontinue use of the 22win platform immediately. This Policy should be read alongside our Terms and Conditions, which govern your use of the Services.

2. Information We Collect

22win collects personal information that is necessary to provide you with a safe, secure, and personalized gaming experience. The categories of information we collect include:

2.1 Information You Provide Directly

• Registration Data: Full legal name, date of birth, gender, nationality, and residential address
• Contact Information: Email address and Philippine mobile number
• Identity Verification Documents: Government-issued ID (e.g., PhilSys ID, passport, driver's license), proof of address, and selfie photographs for KYC (Know Your Customer) compliance
• Financial Information: Payment method details including GCash account numbers, PayMaya details, BPI or BDO bank account information, and other approved payment channels used for deposits and withdrawals
• Communications: Messages, emails, and chat transcripts exchanged with our customer support team

2.2 Information Collected Automatically

• Device Information: IP address, device type, operating system, browser type and version, and unique device identifiers
• Usage Data: Pages visited, games played, session duration, betting history, transaction logs, and clickstream data
• Location Data: General geographic location derived from your IP address to verify jurisdictional eligibility
• Cookies and Tracking Technologies: Data collected through cookies, web beacons, and similar technologies as described in Section 5

2.3 Information from Third Parties

• Identity Verification Providers: Data from third-party KYC and age verification services used to confirm your identity and age
• Payment Processors: Transaction confirmation and fraud screening data from payment service providers
• Fraud Prevention Services: Risk assessment data from third-party fraud detection and prevention partners

3. How We Use Your Information

22win uses the personal information we collect for the following purposes:

Purpose	Legal Basis
Account registration and management	Contractual necessity
Identity verification and KYC compliance	Legal obligation
Processing deposits and withdrawals	Contractual necessity
Providing customer support	Contractual necessity
Fraud detection and prevention	Legitimate interest / Legal obligation
Responsible gaming monitoring	Legal obligation / Legitimate interest
Sending promotional communications (with consent)	Consent
Improving platform performance and user experience	Legitimate interest
Compliance with legal and regulatory requirements	Legal obligation

3.1 Marketing Communications

With your consent, 22win may send you promotional emails, SMS messages, or push notifications about new games, bonuses, and special offers. You may withdraw your consent and opt out of marketing communications at any time by updating your account preferences or contacting our support team. Opting out of marketing communications will not affect your ability to use the Services.

3.2 Responsible Gaming

22win uses your gaming activity data to monitor for signs of problem gambling and to enforce responsible gaming measures, including deposit limits, session time limits, and self-exclusion requests. This monitoring is conducted in your best interest and in compliance with our regulatory obligations.

4. Sharing Your Information

22win does not sell or rent your personal information to third parties. We may share your information with the following categories of recipients only as necessary to provide our Services:

4.1 Service Providers

We engage trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, customer support platforms, and analytics providers. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection laws.

4.2 Regulatory and Law Enforcement Authorities

22win may disclose your personal information to regulatory bodies, law enforcement agencies, or other government authorities where required by law, court order, or regulatory directive. This includes disclosures required for anti-money laundering (AML) compliance and fraud investigations.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, your personal information may be transferred to the acquiring entity. We will notify you of any such transfer and ensure that your data continues to be protected in accordance with this Policy.

4.4 With Your Consent

We may share your information with other third parties where you have given your explicit consent to such sharing.

5. Cookies and Tracking Technologies

5.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the 22win Platform. They help us recognize your device, remember your preferences, and improve your overall experience. We also use similar technologies such as web beacons, pixel tags, and local storage.

5.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly, including session management, login authentication, and security features. These cannot be disabled.
• Performance Cookies: Collect anonymous data about how users interact with the Platform to help us improve functionality and user experience.
• Functional Cookies: Remember your preferences such as language settings, game preferences, and display options.
• Analytics Cookies: Help us understand traffic patterns, popular games, and user behavior to optimize the Platform.

5.3 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform and your ability to use some features. Essential cookies cannot be disabled as they are necessary for the Platform to operate.

6. Data Security

22win implements industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and our servers
• AES-256 encryption for sensitive data stored in our databases
• Multi-factor authentication options for account access
• Regular security audits and penetration testing
• Strict access controls limiting employee access to personal data on a need-to-know basis
• 24/7 monitoring for suspicious activity and potential security breaches

While we take every reasonable precaution to protect your data, no method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant authorities as required by law.

7. Data Retention

22win retains your personal information for as long as your account is active and for a period thereafter as required by law or legitimate business purposes. Specifically:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required for AML compliance and regulatory record-keeping
• Transaction Records: Retained for a minimum of five (5 ) years in accordance with Philippine financial regulations
• Communication Records: Retained for three (3) years from the date of the communication
• Marketing Preferences: Retained until you withdraw your consent or request deletion

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

8. Your Rights

Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights with respect to your personal information held by 22win:

• Right to Be Informed: You have the right to know what personal data we collect, how it is used, and with whom it is shared.
• Right to Access: You may request a copy of the personal information we hold about you at any time.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• 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 our legal retention obligations.
• Right to Object: You may 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 may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• 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 your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the contact details provided in Section 11. We will respond to your request within thirty (30) days. We may need to verify your identity before processing your request.

9. Protection of Minors

22win strictly prohibits the use of our Services by individuals under the age of twenty-one (21). We do not knowingly collect personal information from minors. If we become aware that a user is under 21 years of age, we will immediately close the account, delete all associated personal data, and forfeit any account balance in accordance with our Terms and Conditions.

If you believe that a minor has registered an account on the 22win Platform, please contact us immediately at [email protected] so that we can take appropriate action.

10. Changes to This Policy

22win reserves the right to update or modify this Privacy Policy at any time. Any changes will be effective immediately upon posting the revised Policy on the Platform. We will notify you of material changes by sending an email to your registered address or by displaying a prominent notice on the Platform. Your continued use of the Services following notification of changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

11. Contact Us

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

• Email: [email protected]
• Platform: 22win.app
• Response Time: Within 30 business days

You may also reach our general customer support team through the live chat feature available on the Platform, available 24 hours a day, 7 days a week.