Privacy Policy

1. Introduction

22pub ("we," "us," "our," or "the Platform") is the operator of the online casino and sports betting platform accessible at 22pub.club. We respect the privacy of every Filipino player and are committed to handling personal data with transparency, security, and strict compliance with applicable Philippine data protection law.

This Privacy Policy ("Policy") describes the types of personal information that 22pub collects from users ("you," "Player," or "Data Subject") of the Platform, the purposes for which that information is processed, the parties with whom it may be shared, how long it is retained, and the rights available to you under Philippine law. This Policy should be read together with our Terms & Conditions.

2. Data Controller

The data controller responsible for your personal data is 22pub, operator of 22pub.club. For all data privacy matters, including requests to exercise your statutory rights, you may contact our Data Protection Officer (DPO) using the details set out in Section 15 of this Policy.

3. Data We Collect

22pub collects the following categories of personal data in the course of operating the Platform:

3.1 Identity Data: Full legal name, date of birth, nationality, government-issued identification document type and number (e.g., Philippine passport, SSS/GSIS ID, PhilSys National ID, UMID, driver's license, PRC ID).

3.2 Contact Data: Philippine mobile number (e.g., Globe, Smart, DITO), email address, and residential address including barangay, city/municipality, and province.

3.3 Financial Data: GCash number, Maya account number, bank account details (BPI, BDO, Metrobank, or other Philippine banks), cryptocurrency wallet addresses (for USDT TRC20 transactions), transaction history, deposit and withdrawal records, and account balance.

3.4 Gaming Data: Game history, bet amounts, win/loss records, session duration, preferred game categories, and responsible gaming tool settings (deposit limits, session alerts, self-exclusion status).

3.5 Technical Data: IP address, device type and model, operating system, browser type and version, mobile network, screen resolution, time zone, session timestamps, and cookies.

3.6 Communications Data: Records of your communications with 22pub support (live chat transcripts, email exchanges, and support ticket history).

3.7 Verification Data: Photographs of government-issued identification documents and selfie images submitted for identity verification (KYC) purposes.

4. How We Collect Your Data

22pub collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or responding to promotions.
• Automated technologies: Cookies, web beacons, pixel tags, and similar tracking technologies that operate when you access the 22pub platform. See Section 8 for further details.
• Third-party payment providers: Transaction data received from GCash, Maya, Philippine banks, and other payment processors when you conduct financial transactions on 22pub.
• Identity verification providers: Data received from third-party KYC/AML service providers engaged to verify your identity in compliance with anti-money laundering regulations.
• Publicly available sources: Information that is publicly available and relevant to compliance obligations, such as sanction lists or adverse media databases.

5. How We Use Your Data

22pub uses your personal data for the following purposes:

• To create, verify, and manage your 22pub account.
• To process deposits, withdrawals, and in-game transactions.
• To verify your identity and age (21+) in compliance with Philippine gambling and AML regulations.
• To deliver and improve our casino games, sports betting, bingo, fishing games, and other platform services.
• To communicate with you regarding your account, transactions, promotions, and platform updates.
• To operate and enforce our responsible gaming tools, including deposit limits, session alerts, and self-exclusion.
• To detect, investigate, and prevent fraud, money laundering, cheating, and other prohibited activities.
• To comply with our legal and regulatory obligations, including reporting obligations to PAGCOR and Philippine law enforcement authorities where required by law.
• To analyse Platform usage patterns and improve the 22pub player experience for Filipino users.
• To personalise promotional communications where you have consented to receive them.

6. Legal Basis for Processing

22pub processes your personal data on the following legal bases as recognised under the Philippine Data Privacy Act of 2012 (RA 10173):

• Contractual necessity: Processing required to perform our obligations to you under the Terms & Conditions, including account management and transaction processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML/KYC regulations, PAGCOR licensing requirements, and the Data Privacy Act.
• Legitimate interests: Processing for fraud prevention, security monitoring, platform improvement, and responsible gaming enforcement, where such interests are not overridden by your fundamental rights.
• Consent: Processing for direct marketing communications, where you have expressly consented. You may withdraw consent at any time by contacting 22pub support.

7. Data Sharing & Disclosure

22pub does not sell your personal data to any third party. We may share your data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment processors: GCash (Mynt), Maya, GrabPay, Philippine banks (BPI, BDO, Metrobank), and other payment service providers, to process your financial transactions.
• Identity verification (KYC/AML) providers: Third-party providers engaged to verify your identity and comply with anti-money laundering obligations.
• Game software providers: Game developers and live dealer studio operators whose games are offered on the 22pub platform, to the extent necessary to deliver those games.
• Cloud and infrastructure providers: Hosting and technology providers that support the operation of the 22pub platform, bound by data processing agreements with appropriate safeguards.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and Philippine law enforcement agencies, where disclosure is required by law or court order.
• Professional advisors: Lawyers, accountants, and auditors engaged in connection with 22pub's business operations, subject to professional confidentiality obligations.

8. Cookies & Tracking Technologies

22pub uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small data files stored on your device that help us remember your preferences, maintain your session, and analyse Platform usage.

Types of cookies used by 22pub:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during your 22pub session. These cannot be disabled without breaking core functionality.
• Functional cookies: Store your preferences (language, display settings, responsible gaming limit configurations) to personalise your experience on 22pub.
• Analytics cookies: Help 22pub understand how players interact with the Platform — which games are most popular, how navigation is used, and where technical issues occur. Data collected is aggregated and anonymised.
• Security cookies: Used by 22pub's fraud detection and bot prevention systems to distinguish legitimate players from automated or malicious actors.

Most browsers allow you to manage cookie preferences through browser settings. Disabling strictly necessary cookies will impair your ability to use 22pub.

9. Data Retention

22pub retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, accounting, and reporting obligations.

Specifically:

• Account data is retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and Philippine AML regulations.
• Transaction records are retained for a minimum of ten (10) years, as required by the Anti-Money Laundering Act (RA 9160, as amended).
• Identity verification (KYC) documents are retained for a minimum of five (5) years following the end of the business relationship.
• Support communications are retained for three (3) years from the date of the last communication.
• Marketing consent records are retained until you withdraw consent and for one (1) year thereafter.

When personal data is no longer required, 22pub will securely delete or anonymise it in accordance with applicable standards.

10. Data Security

22pub implements technical and organisational security measures appropriate to the nature of the personal data we hold, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and 22pub servers.
• Encryption of sensitive data at rest, including identity verification documents and financial records.
• Role-based access controls that restrict internal access to personal data to authorised personnel only.
• Real-time intrusion detection and anomaly monitoring systems.
• Two-factor authentication for all 22pub administrative system access.
• Regular security audits and vulnerability assessments by independent cybersecurity professionals.
• Mandatory data privacy and security training for all 22pub employees with access to personal data.

While 22pub takes all reasonable steps to protect your personal data, no system is completely immune to security threats. In the event of a personal data breach that poses a real risk to your rights, 22pub will notify the National Privacy Commission and affected players in accordance with the requirements of RA 10173.

11. Your Rights Under RA 10173

As a data subject under the Philippine Data Privacy Act of 2012, you are entitled to the following rights with respect to your personal data held by 22pub:

To exercise any of these rights, contact 22pub's Data Protection Officer using the details in Section 15. We will respond to all valid requests within thirty (30) days.

12. Children & Minors

22pub is strictly prohibited to persons under 21 years of age. We do not knowingly collect personal data from individuals under 21. Any account found to belong to a person under 21 will be immediately closed, all data will be deleted (subject to mandatory legal retention periods), and any balance will be forfeited. If you believe a minor has created a 22pub account, please contact us immediately at [email protected].

13. International Data Transfers

22pub's primary servers are located in Asia. Where your personal data is processed by third-party service providers located outside the Philippines, 22pub ensures that appropriate safeguards are in place, including contractual data processing agreements that require those providers to maintain security and privacy standards consistent with RA 10173. By using 22pub, you consent to such international processing where necessary for the operation of the Platform.

14. Updates to This Privacy Policy

22pub may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform functionality. When we make material changes, we will post the updated Policy on this page with a revised effective date and, where practicable, provide notice to registered players via email or in-platform notification. Your continued use of 22pub following any update constitutes your acceptance of the revised Policy.

15. Contact & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how 22pub handles your personal data, please contact our Data Protection Officer: