22wins Privacy Policy

1 Introduction

22wins ("we," "us," or "our") operates the online casino and sports betting platform accessible at https://22wins.app (the "Platform"). As the personal information controller of the data you provide to us, 22wins is responsible for ensuring that your personal data is collected, stored, processed, and protected in accordance with applicable Philippine law and international best practices.

This Privacy Policy describes our practices regarding the collection and use of personal information from players and visitors across the Philippines — whether you're based in Manila, Cebu, Davao, Quezon City, Makati, or anywhere else in the archipelago. We are committed to being transparent about our data practices so you can make informed decisions about your personal information.

This Privacy Policy should be read together with the 22wins Terms & Conditions and Responsible Gaming Policy. If you have any questions about how 22wins handles your personal data, please contact us using the details in Section 12.

2 Data We Collect

22wins collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Registration & Identity Data

When you create a 22wins account, we collect your full legal name, date of birth, email address, Philippine mobile number, and a username and password of your choosing. This information is required to establish your account and verify your eligibility to use the Platform.

2.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and anti-money laundering (AML) requirements, we may collect copies of government-issued identification documents such as your Philippine passport, SSS ID, PhilHealth ID, UMID, or driver's license. We may also collect proof of address documents such as utility bills or bank statements.

2.3 Financial Data

We collect information related to your deposits and withdrawals, including your GCash or PayMaya account details, bank account information (for BPI, BDO, Metrobank transfers), and transaction history on the 22wins Platform. We do not store full card numbers; payment card data is processed by our certified payment service providers.

2.4 Gaming Activity Data

We collect records of your gaming activity on the 22wins Platform, including games played, bets placed, amounts wagered, winnings and losses, session durations, and bonus usage. This data is used for account management, regulatory compliance, and responsible gaming monitoring.

2.5 Technical & Device Data

We automatically collect certain technical data when you access the 22wins Platform, including your IP address, browser type and version, operating system, device identifiers, and referring URLs. This data helps us maintain Platform security and improve user experience.

2.6 Communications Data

If you contact 22wins customer support via live chat or email, we retain records of those communications, including the content of your messages and our responses, for quality assurance and dispute resolution purposes.

3 How We Use Your Data

22wins uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 22wins account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to all games, promotions, and features available on the 22wins Platform, including slots, live casino, bingo, sports betting, and Dragon Hatch.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, PESONet, Visa, and Mastercard in Philippine Peso.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, AML obligations, and the Philippine Data Privacy Act, including KYC verification and transaction monitoring.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce deposit limits and self-exclusion requests, and provide responsible gaming tools to all 22wins players.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, and other prohibited conduct on the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance through our live chat and email support channels.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your consent or where we have a legitimate interest to do so. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the 22wins Platform.

4 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 22wins processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to provide you with access to the 22wins Platform and to process your gaming transactions.
• Legal Obligation: Processing is required to comply with PAGCOR regulations, AML laws, tax reporting obligations, and other applicable Philippine legal requirements.
• Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform, including fraud prevention, security monitoring, and Platform analytics — provided these interests are not overridden by your privacy rights.
• Consent: For certain processing activities, such as sending marketing communications or using non-essential cookies, we rely on your explicit consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Data Sharing & Disclosure

5.1 Service Providers

22wins shares personal data with trusted third-party service providers who assist us in operating the Platform. These include payment processors (for GCash, PayMaya, and bank transfer services), KYC verification providers, game software suppliers, cloud hosting providers, and customer support platform operators. All service providers are contractually bound to process your data only on our instructions and in compliance with applicable data protection laws.

5.2 Regulatory Authorities

22wins may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government authorities where required by law, court order, or regulatory directive. We will notify you of such disclosures where legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 22wins' business assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you via email or a prominent Platform notice before your data is transferred and becomes subject to a different privacy policy.

5.4 No Unauthorized Third-Party Sharing

Aside from the circumstances described above, 22wins does not share, sell, or disclose your personal data to any unauthorized third party. We do not share your data with advertisers, data brokers, or any other commercial third parties for their own purposes.

6 Cookies & Tracking Technologies

The 22wins Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and analyze Platform usage. The types of cookies we use include:

• Essential Cookies: Required for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the 22wins Platform, helping us identify areas for improvement. These are only set with your consent.
• Preference Cookies: Used to remember your Platform settings and preferences, such as language and display options, to provide a more personalized experience.
• Marketing Cookies: Used to deliver relevant promotional content based on your interests. These are only set with your explicit consent and can be withdrawn at any time.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may affect your ability to use certain features of the 22wins Platform. For more information on managing cookies in popular Philippine browsers and devices, refer to your browser's help documentation.

7 Data Retention

22wins retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. Specific retention periods include:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years after account closure, in compliance with PAGCOR and AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations.
• KYC Documents: Retained for a minimum of five (5) years after the end of the business relationship, or longer if required by applicable law.
• Support Communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution.
• Technical Logs: Retained for up to twelve (12) months for security and fraud investigation purposes.

When personal data is no longer required for any of the above purposes, 22wins will securely delete or anonymize it in accordance with our data disposal procedures.

8 Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the 22wins Platform.
• Encryption of sensitive data at rest, including KYC documents and financial information.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of Platform infrastructure.
• Two-factor authentication options for player accounts to prevent unauthorized access.
• Continuous monitoring of Platform systems for suspicious activity and potential security incidents.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 22wins will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Philippine Data Privacy Act.

9 Your Data Rights

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

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed by 22wins — which is the purpose of this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data 22wins holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update basic account information directly through your 22wins account settings.
• Right to Erasure: You have the right to 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 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 that data to another controller where technically feasible.
• 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 the above rights, please contact the 22wins Data Privacy Officer via email at [email protected]. We will respond to all verified data rights requests within thirty (30) days of receipt.

10 Children's Privacy

The 22wins Platform is strictly intended for adults who are 21 years of age or older, in compliance with Philippine gaming regulations. 22wins does 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 immediately suspend the associated account, delete the personal data, and return any deposits in accordance with applicable regulations.

If you are a parent or guardian and believe that your child has registered on the 22wins Platform, please contact us immediately at [email protected] so we can take prompt action.

11 Changes to This Privacy Policy

22wins reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, we will notify registered players via email or a prominent notice on the 22wins Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent changes were made. We encourage you to review this Privacy Policy periodically to stay informed about how 22wins protects your personal data. Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.

12 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 22wins handles your personal data, please contact our Data Privacy Officer through any of the following channels:

• Email: [email protected]
• Live Chat: Available on the 22wins Platform, Monday to Sunday, 8:00 AM – 12:00 MN Philippine Standard Time.

If you are not satisfied with our response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph. The NPC is the independent government body responsible for administering and implementing the Data Privacy Act of 2012.