This Privacy Policy explains how 22win collects, uses, stores, and protects your personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable PAGCOR licensing requirements.
22win processes personal data in strict compliance with Republic Act 10173 (Data Privacy Act of 2012). Your rights as a data subject are enforceable under Philippine law and the National Privacy Commission.
22win does not sell, rent, or trade your personal information to third parties for their own marketing purposes. Your data is used solely to operate and improve the 22win platform and comply with legal obligations.
As a data subject under RA 10173, you have the right to access, correct, delete, and object to the processing of your personal data. Requests can be submitted to 22win's Data Protection Officer.
All personal data stored by 22win is encrypted at rest using industry-standard AES-256 encryption. Passwords are hashed using bcrypt and are never stored in plain text. Sensitive payment data is tokenized and never stored on 22win servers.
PAGCOR licensing requires 22win to collect and retain certain player data for regulatory, AML, and responsible gaming purposes. Some data processing is a legal obligation, not a commercial choice — we will always tell you which is which.
22win uses strictly necessary cookies for session management and optional analytics cookies to improve platform performance. You can manage cookie preferences at any time from your account settings or browser controls.
22win ("we," "us," "our," "the Company") is the data controller responsible for personal data collected through the 22win platform at 22win.vu. As data controller, 22win determines the purposes and means of processing your personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC) of the Philippines.
22win has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with data privacy obligations. The DPO may be contacted at the details provided in Section 13 of this Policy.
| Category | Examples | Purpose |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality | Account registration, KYC verification |
| Contact Data | Email address, mobile number, address | Account communications, security alerts |
| Government ID Data | Passport, driver's license, UMID, SSS ID | KYC verification, PAGCOR compliance |
| Financial Data | GCash number, bank account (masked), payment history | Deposit/withdrawal processing, AML compliance |
| Account Credentials | Username, hashed password | Account authentication and security |
22win may receive personal data from third-party identity verification providers, payment processors (e.g., GCash/Maya infrastructure providers), fraud detection services, and PAGCOR's player registration database where cross-referencing is required by PAGCOR licensing conditions.
22win uses your personal data for the following purposes:
Under RA 10173 and its Implementing Rules, 22win processes your personal data based on the following legal grounds:
22win shares personal data with carefully selected third-party service providers who process data strictly on 22win's behalf and under binding data processing agreements. These include: KYC identity verification providers; payment processing infrastructure providers; fraud detection and anti-money laundering screening services; cloud hosting providers; customer support platform providers; and game software providers (aggregated, non-identifiable data only).
22win is required by law to disclose player data to: PAGCOR, upon request as part of licensing compliance and audits; the Anti-Money Laundering Council (AMLC), for covered and suspicious transaction reporting under AMLA; the National Privacy Commission (NPC), upon receipt of a valid legal order; and law enforcement authorities, pursuant to a valid court order or subpoena issued by Philippine courts.
22win does not sell, rent, lease, or otherwise transfer your personal data to unaffiliated third parties for their own commercial or marketing purposes. This prohibition is absolute and applies to all categories of personal data collected by 22win.
In the event of a merger, acquisition, or sale of all or substantially all of 22win's assets, personal data held by 22win may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. Players will be notified of any such transfer via their registered email address prior to the transfer taking effect.
| Cookie Type | Purpose | Can Be Disabled? |
|---|---|---|
| Strictly Necessary | Session authentication, security tokens, CSRF protection. Required for the platform to function. | No — disabling these will break login functionality |
| Functional | Language preferences, game sound/display settings, responsible gaming notification preferences. | Yes — disabling resets preferences on each visit |
| Analytics | Aggregated, anonymized data on page visits, game engagement, and performance metrics to improve 22win. | Yes — opt out in account settings or browser |
22win does not use third-party advertising cookies or sell cookie-derived data to advertising networks.
22win retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law:
When personal data is no longer required, 22win will securely delete or anonymize it in accordance with NPC-approved data disposal procedures.
22win implements the following technical and organizational measures to protect your personal data:
Under RA 10173 and its Implementing Rules, you have the following rights regarding your personal data held by 22win:
To exercise any of these rights, contact 22win's Data Protection Officer using the details in Section 13. 22win will respond to all data subject requests within fifteen (15) business days of receipt, as required by NPC regulations.
22win is strictly an adult platform. No individual under the age of 21 years is permitted to register or use 22win. 22win does not knowingly collect personal data from individuals under 21 years of age. If 22win discovers that personal data has been collected from an underage individual, the account will be immediately closed, all data will be deleted within thirty (30) days (except where retention is legally required for PAGCOR reporting), and the matter will be reported to PAGCOR as required. If you believe an underage individual has registered on 22win, please notify the DPO immediately.
22win's primary data processing infrastructure is located within or proximate to the Philippines. Certain service providers — including cloud infrastructure and security services — may process data in other jurisdictions. Where personal data is transferred outside the Philippines, 22win ensures that appropriate safeguards are in place, including data processing agreements that impose data protection standards equivalent to or exceeding those required by RA 10173 and the NPC, consistent with NPC Advisory Opinion and applicable cross-border transfer requirements.
22win reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. Material changes will be communicated to registered players via email notification to their registered address and via a prominent notice on the 22win platform for a period of not less than thirty (30) days prior to the changes taking effect. The "Last Updated" date at the top of this Policy will reflect the date of the most recent revision. Continued use of 22win after the effective date of any revision constitutes your acceptance of the updated Policy.
For all data privacy inquiries, requests to exercise data subject rights, or concerns regarding 22win's data processing practices, please contact the 22win Data Protection Officer:
If you are not satisfied with 22win's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission at privacy.gov.ph.
Your data is safe with us. PAGCOR-licensed, Data Privacy Act compliant, and built for Filipino players who deserve a trustworthy platform.
Access Your 22win AccountMust be 21 years or older. PAGCOR-licensed. Play responsibly.