22pub Privacy Policy
This Privacy Policy explains how 22pub collects, uses, stores, and protects your personal data in accordance with the Philippine Data Privacy Act of 2012 (R.A. 10173) and PAGCOR regulations.
Summary: 22pub collects personal data only to operate your account, process transactions, comply with PAGCOR and anti-money laundering regulations, and improve the platform. We do not sell your personal data to third parties. You have the right to access, correct, and delete your data subject to legal retention obligations. For any privacy concern, contact our Data Protection Officer at [email protected].
1 Introduction
This Privacy Policy ("Policy") is issued by 22pub ("we," "us," "our," "the Platform"), a PAGCOR-authorized online gaming platform operating at the domain 22pub.vip. This Policy applies to all personal data processed by 22pub in connection with your registration, access to, and use of the platform, including our website, mobile-optimized interface, customer support services, and any related communications.
22pub is committed to protecting the privacy and personal data of all users in a manner consistent with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and any issuances of the National Privacy Commission of the Philippines ("NPC"). Our data processing activities are also subject to applicable PAGCOR regulations governing player data handling.
By registering for and using the 22pub platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree to this Policy, you must not use the platform. The current version of this Policy is always available at /privacy-policy.
This Policy should be read together with the 22pub Terms & Conditions available at /terms-conditions. Defined terms used but not defined in this Policy carry the meanings given to them in the Terms & Conditions.
2 Data Controller Identity
For the purposes of the Data Privacy Act of 2012 and this Policy, the data controller responsible for the personal data you provide to 22pub is:
Platform Name: 22pub
Website: 22pub.vip
Regulatory Authorization: PAGCOR (Philippine Amusement and Gaming Corporation)
Applicable Law: Republic of the Philippines
Data Protection Officer Contact: [email protected] (plain text — not a clickable link)
22pub has designated a Data Protection Officer ("DPO") as required under the Data Privacy Act of 2012. The DPO is responsible for overseeing compliance with this Policy and applicable data protection laws, handling data subject access requests, and serving as the point of contact for the National Privacy Commission. You may contact the DPO via the support channel listed above.
3 Personal Data We Collect
22pub collects the following categories of personal data in connection with the operation of the platform:
3.1 Registration and Identity Data
When you create a 22pub account, we collect your full legal name, date of birth, nationality, Philippine mobile number, email address (if provided), and any username you choose. This data is necessary to create and administer your account and to verify your age and identity as required by PAGCOR regulations.
3.2 Know Your Customer (KYC) and Verification Data
Prior to processing withdrawals and as part of our regulatory compliance obligations, we collect government-issued identification documents (such as a UMID, driver's license, passport, or voter's ID), proof of address documents, and, where required, documentation evidencing source of funds. This data is collected and retained in accordance with PAGCOR AML requirements and the Anti-Money Laundering Act of 2001 (R.A. 9160) as amended.
3.3 Financial and Transaction Data
We collect data relating to your deposits, withdrawals, and gaming transactions, including payment method details (GCash number, PayMaya number, bank account details, or cryptocurrency wallet address), transaction amounts, timestamps, and transaction reference numbers. We do not store complete credit or debit card numbers.
3.4 Gaming Activity Data
We collect records of your gaming activity on the 22pub platform, including games played, bet amounts, outcomes, session duration, responsible gaming tool usage, and bonus participation history. This data is used for account administration, dispute resolution, regulatory reporting, and responsible gaming purposes.
3.5 Technical and Device Data
We automatically collect certain technical data when you access the platform, including your IP address, device type and model, operating system, browser type and version, and general geographic location derived from your IP address. This data is used for security, fraud prevention, and platform optimization purposes.
3.6 Communications Data
We retain records of communications between you and 22pub customer support, including live chat transcripts, support ticket records, and any documentation you submit in connection with a query or complaint.
| Data Category | Examples | Primary Purpose |
|---|---|---|
| Identity Data | Name, DOB, mobile number | Account creation, age verification |
| KYC Documents | Government ID, proof of address | Regulatory compliance, AML |
| Financial Data | GCash number, transaction history | Payment processing, AML |
| Gaming Activity | Bets, session logs, game history | Account admin, dispute resolution, responsible gaming |
| Technical Data | IP address, device type | Security, fraud prevention |
| Communications | Support chat transcripts | Customer support, dispute resolution |
4 How We Collect Your Data
22pub collects personal data through the following channels:
- Directly from you — through account registration, KYC document submission, deposit and withdrawal requests, contact forms, and customer support interactions;
- Automatically — through your use of the platform via cookies, log files, and similar tracking technologies as described in Section 10;
- From payment service providers — GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency processing partners provide transaction confirmation data to 22pub to enable payment processing;
- From identity verification services — where we use third-party KYC service providers to assist in verifying the authenticity of identification documents submitted during the KYC process;
- From regulatory authorities — PAGCOR and other Philippine government agencies may provide or confirm information relating to your registration status, exclusion orders, or regulatory standing.
5 Purposes of Processing
22pub processes your personal data for the following specific purposes:
- Account Registration and Administration: Creating and managing your 22pub account, verifying your identity and age, and maintaining accurate account records;
- Transaction Processing: Processing deposits via GCash, PayMaya, bank transfer, or cryptocurrency, and processing withdrawal requests to your registered payment method;
- Regulatory Compliance: Meeting 22pub's obligations under PAGCOR authorization requirements, the Anti-Money Laundering Act, the Data Privacy Act, and any other applicable Philippine law or regulatory directive;
- Fraud and Security: Detecting, preventing, and investigating fraud, identity theft, money laundering, and other illegal or unauthorized activities on the platform;
- Responsible Gaming: Monitoring gaming activity to identify potential problem gambling behaviors, administering responsible gaming tools such as deposit and loss limits, and processing self-exclusion requests;
- Customer Support: Responding to your queries, resolving disputes, processing complaints, and improving the quality of our support services;
- Platform Improvement: Analyzing aggregated usage data to improve the performance, security, and features of the 22pub platform;
- Marketing Communications: Sending promotional offers, bonus notifications, and platform updates, subject to your communication preferences and applicable law. You may opt out of marketing communications at any time through your account settings.
22pub does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where such processing is required by law or regulatory directive.
6 Legal Basis for Processing
Under the Data Privacy Act of 2012, 22pub relies on the following legal bases for processing your personal data:
- Contractual Necessity: Processing necessary for the performance of the contract between you and 22pub — specifically, the Terms & Conditions governing your use of the platform. This covers account creation, payment processing, and account administration;
- Legal Obligation: Processing required for 22pub to comply with its legal and regulatory obligations, including PAGCOR requirements, AML obligations, tax reporting, and NPC directives;
- Legitimate Interests: Processing necessary for the legitimate interests of 22pub — including fraud prevention, platform security, dispute resolution, and platform improvement — provided those interests are not overridden by your rights and interests;
- Consent: Where required by law, we will obtain your express consent before processing your personal data, including for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
7 Data Sharing and Disclosure
22pub does not sell your personal data to any third party. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:
- Payment Service Providers: GCash (Mynt — Globe Fintech Innovations), Maya Philippines, BPI, BDO, Metrobank, and authorized cryptocurrency processing partners, solely to facilitate deposit and withdrawal transactions;
- KYC and Identity Verification Partners: Third-party identity verification service providers engaged by 22pub to assist with document verification. These providers are bound by data processing agreements and may not use your data for any purpose beyond the verification service;
- Game Software Providers: Providers such as Pragmatic Play, PG Soft, Jili, and WM Casino may receive limited technical data necessary for game delivery and RNG auditing. No financial or identity data is shared with game providers;
- Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue, and any other Philippine government body with lawful authority to require disclosure;
- Law Enforcement: Philippine law enforcement agencies where disclosure is required by law, court order, or to protect the safety of persons;
- Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by 22pub, subject to professional confidentiality obligations.
All third-party service providers who process personal data on behalf of 22pub are subject to data processing agreements that require them to handle your data securely, use it only for the specified purpose, and comply with applicable data protection law.
8 Data Retention
22pub retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law and PAGCOR regulations:
| Data Type | Retention Period | Legal Basis |
|---|---|---|
| Account and identity records | 5 years after account closure | PAGCOR regulations, DPA |
| KYC documents | 5 years after account closure | AML Act (R.A. 9160 as amended) |
| Transaction records | 5 years from transaction date | AML Act, BIR regulations |
| Gaming activity logs | 3 years after account closure | PAGCOR regulations |
| Customer support records | 2 years from interaction date | Legitimate interest, dispute resolution |
| Self-exclusion records | Duration of exclusion + 5 years | PAGCOR responsible gaming requirements |
| Marketing preferences | Until opt-out or account closure | Consent |
After the applicable retention period, personal data will be securely deleted or anonymized in accordance with recognized data destruction standards. Anonymized aggregate data may be retained indefinitely for statistical and analytical purposes.
9 Data Security
22pub implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:
- Encryption in Transit: All data transmitted between your device and 22pub's servers is encrypted using 256-bit SSL/TLS encryption, the same standard used by major Philippine banks and e-wallets;
- Encryption at Rest: Sensitive personal data, including KYC documents and financial data, is encrypted at rest using industry-standard encryption algorithms;
- Access Controls: Access to personal data is restricted to authorized 22pub personnel and service providers on a strict need-to-know basis. All access is logged and auditable;
- Two-Factor Authentication: Privileged access to 22pub systems containing personal data requires two-factor authentication;
- Regular Security Audits: 22pub's security infrastructure is subject to regular independent security assessments and penetration testing;
- Incident Response: 22pub maintains a documented data breach incident response plan. In the event of a personal data breach that poses a risk to your rights, 22pub will notify the National Privacy Commission within 72 hours and affected individuals as required under the Data Privacy Act.
While 22pub maintains robust security measures, no online platform can guarantee absolute security. You play an important role in protecting your own data — keep your login credentials confidential, enable two-factor authentication on your account, and log out when using shared devices.
10 Cookies & Tracking Technologies
22pub uses cookies and similar tracking technologies to operate the platform, recognize returning users, maintain session state, prevent fraud, and analyze platform usage. The following categories of cookies are used:
- Strictly Necessary Cookies: Essential for the platform to function. They enable account login sessions, payment processing flows, and security features. These cookies cannot be disabled without impairing platform functionality;
- Performance Cookies: Collect anonymized data about how users interact with the platform — pages visited, session duration, error events — to help us improve performance and usability;
- Functional Cookies: Remember your preferences such as language settings, responsible gaming limit configurations, and game lobby display preferences;
- Security Cookies: Used for fraud detection, bot prevention, and account security monitoring. These cookies help 22pub identify and block suspicious login attempts and automated abuse.
22pub does not use third-party advertising or behavioral tracking cookies. No data collected through 22pub cookies is shared with advertising networks or data brokers.
You may configure your browser to block or delete cookies. Note that disabling strictly necessary cookies will prevent you from logging in to your 22pub account and using core platform features. Blocking performance or functional cookies will not affect your ability to play but may reduce platform functionality.
11 Your Data Subject Rights
Under the Data Privacy Act of 2012 and this Policy, you have the following rights with respect to your personal data held by 22pub. To exercise any of these rights, contact our Data Protection Officer via the support channels listed in Section 15. We will respond to all valid requests within thirty (30) calendar days.
Right to Access
You have the right to request a copy of the personal data that 22pub holds about you and information about how it is being processed. We will provide this information in a structured, commonly used format.
Right to Rectification
You have the right to request correction of inaccurate or incomplete personal data. Some data — such as your registered name and date of birth — can only be corrected through the KYC document verification process.
Right to Erasure (Right to be Forgotten)
You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent. Note that 22pub is legally required to retain certain data (such as KYC documents and transaction records) for minimum periods under PAGCOR regulations and the AML Act. Erasure requests will be honored to the maximum extent permitted by law.
Right to Object and Restrict Processing
You may object to processing based on legitimate interests or restrict processing in certain circumstances, including where you contest the accuracy of data or where processing is unlawful but you do not wish deletion.
Right to Data Portability
You have the right to receive personal data you have provided to 22pub in a structured, machine-readable format, and to request direct transmission to another controller where technically feasible.
Right to Lodge a Complaint
If you believe 22pub has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). 22pub encourages you to contact our DPO first so we have the opportunity to resolve the matter directly.
12 Children's Privacy and Minors Protection
21+ Age Requirement: The 22pub platform is strictly for persons aged 21 years and above. 22pub does not knowingly collect personal data from persons under 21 years of age.
22pub implements mandatory age verification as part of the account registration process and conducts further verification during KYC review. If 22pub discovers that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, all balances will be handled in accordance with PAGCOR regulations, and the collected data will be deleted as soon as legally permissible.
Parents and guardians who believe their child under 21 has registered on the 22pub platform should contact the DPO immediately via the contact details in Section 15. 22pub will respond promptly to all such notifications and cooperate fully in any investigation.
13 Cross-Border Data Transfers
As an online gaming platform, 22pub may engage service providers and game software partners whose servers are located outside the Philippines. Where personal data is transferred internationally, 22pub takes the following measures to ensure adequate protection:
- 22pub only transfers personal data to countries or organizations that have been assessed to provide an adequate level of data protection;
- Where an adequacy determination is not available, 22pub relies on data processing agreements incorporating standard contractual clauses or binding corporate rules as approved by the National Privacy Commission;
- Transfers required by Philippine law or PAGCOR regulation are conducted in strict compliance with those requirements;
- Game software providers receive only the minimum technical data necessary for game delivery — no financial or KYC data is transferred to game providers.
By using the 22pub platform, you acknowledge that your data may be processed in countries other than the Philippines in accordance with the safeguards described above.
14 Changes to This Privacy Policy
22pub reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, legal requirements, or platform features. Material changes to this Policy will be communicated to registered players via their registered mobile number or, where applicable, through a prominent notice on the 22pub platform, at least seven (7) days before the changes take effect.
Where changes are required by law, a regulatory directive, or urgent security concerns, they may take effect immediately upon publication. The date displayed at the top of this page reflects when the current version was last updated. Your continued use of the 22pub platform following notification of changes constitutes your acceptance of the revised Policy.
Previous versions of this Privacy Policy are available upon request from the Data Protection Officer.
15 Contact & Data Protection Officer
For all privacy-related queries, data subject access requests, complaints, or concerns, please contact 22pub's Data Protection Officer through the following channels:
Live Chat: Available 24/7 via the on-site chat widget at 22pub.vip. Select "Privacy & Data" as the query type.
Support Email: [email protected] — please include "Privacy Request" in the subject line
(This is a plain text address — not a clickable mailto link)
Response Time: 22pub will acknowledge your request within 3 business days and provide a substantive response within 30 calendar days. Complex requests involving large volumes of data may take up to an additional 30 days; you will be notified of any extension.
National Privacy Commission (NPC): If you are unsatisfied with 22pub's response to a privacy complaint, you have the right to file a complaint directly with the National Privacy Commission of the Philippines. Information about the NPC complaint process is available at the NPC's official government website. 22pub will cooperate fully with any NPC investigation.
How 22pub Protects Your Privacy
These are not just policy statements — they reflect how 22pub's data infrastructure is actually built and operated for every Filipino player on the platform.
256-bit SSL Encryption
Every byte of data transmitted between your phone and 22pub is encrypted using 256-bit SSL — the same standard trusted by BPI, BDO, and GCash. Your personal data never travels in plain text, anywhere in the platform.
We Never Sell Your Data
22pub's business model is built on gaming, not data brokerage. Your personal data is never sold, rented, or traded to third-party advertisers, data brokers, or any party outside of the authorized service providers described in this Policy.
R.A. 10173 Compliance
22pub's data practices comply with the Philippine Data Privacy Act of 2012, including designation of a Data Protection Officer, a documented breach response plan, and respect for all data subject rights established under Philippine law.
Full Data Subject Rights
You can request access to, correction of, deletion of, or a portable copy of your personal data at any time. 22pub's DPO responds to all valid data subject requests within 30 days — a legally binding obligation, not a courtesy.
Minimal Retention, Maximum Security
22pub retains your data only for as long as legally required — no longer. When the retention period expires, data is securely destroyed using recognized standards. We don't hold data indefinitely "just in case."
No Behavioural Advertising
22pub does not use your gaming activity, browsing behavior, or personal profile to serve third-party advertising. The only marketing communications you receive from 22pub are the casino's own promotional offers — and you can opt out at any time.
Play on a Platform That Respects Your Privacy
22pub is PAGCOR authorized, Data Privacy Act compliant, and built around the trust of Filipino players. Your data is protected. Your games are fair. Your winnings are yours.
PAGCOR authorized. 21+ only. Gambling is for entertainment purposes only.