Privacy Policy

1. Introduction

Welcome to the 22pub Privacy Policy. This document explains how 22pub ("we," "us," "our," or the "Company") collects, processes, stores, and protects your personal information when you access or use our website (https://22pub.cam) and associated services (collectively, the "Platform").

22pub operates as an online gambling and sports betting platform serving users in the Philippines. We are committed to transparency in our data handling practices and compliance with applicable data protection laws, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

By creating an account, accessing our Platform, or using any 22pub services, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. If you do not agree with this Privacy Policy, you must discontinue use of 22pub immediately.

2. Data Controller Information

22pub is the data controller responsible for the collection, processing, and protection of your personal information. For inquiries regarding this Privacy Policy, data protection concerns, or to exercise your rights under applicable data protection laws, please contact us at:

• Email: [email protected]
• Data Protection Officer: [email protected]
• Support Contact: Available 24/7 via live chat on our website

3. Information We Collect

22pub collects several categories of personal data to provide, maintain, secure, and improve our services. The information we collect includes:

3.1 Account Registration Data

When you register an account with 22pub, we collect the following information:

• Personal Identification: Full legal name, date of birth, nationality, and gender;
• Contact Information: Email address, mobile phone number, and residential address;
• Account Credentials: Username, password (stored in encrypted form), and security questions;
• Identity Verification Documents: Government-issued identification (passport, driver's license, national ID card), proof of address (utility bills, bank statements), and payment method verification documents.

3.2 Financial and Transaction Data

To process deposits, withdrawals, and betting transactions, we collect:

• Payment method details (bank account information, GCash/PayMaya wallet details, credit/debit card information);
• Transaction history, including deposit amounts, withdrawal requests, betting activity, and winnings;
• Source of funds documentation as required for anti-money laundering compliance;
• IP addresses and device identifiers associated with financial transactions for fraud prevention.

3.3 Usage and Technical Data

22pub automatically collects technical and usage information when you access our Platform:

• Device Information: Device type, operating system, browser type and version, screen resolution, and unique device identifiers;
• Connection Data: IP address, internet service provider, geographic location (derived from IP address), and time zone settings;
• Usage Logs: Pages visited, games played, betting patterns, session duration, clickstream data, and referral sources;
• Cookies and Tracking Technologies: Session cookies, preference cookies, analytics cookies, and marketing cookies (see Section 10 for details).

3.4 Communications and Customer Support

When you contact 22pub customer support via live chat, email, or other communication channels, we collect and store:

• The content of your communications;
• Attachments and supporting documents you provide;
• Support ticket history and resolution notes;
• Feedback, surveys, and reviews you submit.

3.5 Marketing and Promotional Preferences

We collect information about your preferences regarding promotional communications, including:

• Opt-in consent for email marketing, SMS promotions, and push notifications;
• Participation in bonus programs, tournaments, and loyalty rewards;
• Responses to promotional campaigns and engagement metrics.

4. How We Use Your Data

22pub processes your personal data for the following purposes:

4.1 Account Management and Service Provision

• Creating and maintaining your 22pub account;
• Processing registration, identity verification, and KYC (Know Your Customer) procedures;
• Enabling access to casino games, sports betting markets, and platform features;
• Managing your account balance, deposits, withdrawals, and transaction history.

4.2 Legal and Regulatory Compliance

• Verifying your identity and age to comply with gambling regulations;
• Preventing underage gambling and enforcing minimum age requirements;
• Conducting anti-money laundering (AML) and counter-terrorist financing (CTF) checks;
• Responding to legal requests, court orders, and regulatory inquiries;
• Reporting suspicious transactions to relevant authorities as required by law.

4.3 Fraud Prevention and Security

• Detecting and preventing fraudulent activity, account takeovers, and payment fraud;
• Monitoring betting patterns to identify match-fixing, collusion, or bonus abuse;
• Implementing security measures to protect against unauthorized access;
• Investigating breaches of our Terms and Conditions.

4.4 Communication and Customer Support

• Responding to your inquiries, complaints, and support requests;
• Sending transactional notifications (account verification, withdrawal confirmations, password resets);
• Providing updates on account activity, responsible gaming tools, and service changes;
• Conducting customer satisfaction surveys and collecting feedback.

4.5 Marketing and Promotional Activities

With your consent, we use your data to:

• Send promotional emails, SMS messages, and push notifications about bonuses, tournaments, and special offers;
• Personalize marketing content based on your gaming preferences and activity;
• Administer loyalty programs, VIP rewards, and cashback incentives;
• Conduct promotional campaigns and track engagement metrics.

You may withdraw your marketing consent at any time by adjusting your account settings or contacting support.

4.6 Platform Improvement and Analytics

• Analyzing user behavior to improve website functionality and user experience;
• Conducting A/B testing on features, layouts, and game offerings;
• Generating anonymized and aggregated statistics for business intelligence;
• Optimizing platform performance, load times, and mobile responsiveness.

5. Legal Basis for Processing

22pub processes your personal data based on the following legal grounds under applicable data protection laws:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., providing gambling services);
• Legal Obligation: Processing is required to comply with legal and regulatory obligations (KYC, AML, age verification);
• Legitimate Interests: Processing serves our legitimate business interests (fraud prevention, security, platform improvement) without overriding your privacy rights;
• Consent: Where required, we obtain your explicit consent for marketing communications and non-essential cookies.

6. Data Sharing and Third-Party Disclosure

22pub does not sell your personal data. However, we may share your information with trusted third parties under the following circumstances:

6.1 Service Providers

We engage third-party service providers to support our operations, including:

• Payment processors (GCash, PayMaya, banks) to facilitate deposits and withdrawals;
• Identity verification services to conduct KYC and AML checks;
• Cloud hosting providers (AWS, Google Cloud) for data storage and server infrastructure;
• Customer support platforms for live chat and ticketing systems;
• Analytics providers (Google Analytics) to measure website performance;
• Marketing platforms for email campaigns and SMS notifications.

All third-party service providers are contractually bound to protect your data and use it only for the purposes specified by 22pub.

6.2 Legal and Regulatory Authorities

We may disclose your personal data to law enforcement agencies, regulators, or government authorities when:

• Required by law, court order, subpoena, or legal process;
• Necessary to comply with gambling licensing requirements;
• Reporting suspicious transactions under AML/CTF regulations;
• Cooperating with investigations into fraud, money laundering, or other criminal activity.

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or bankruptcy, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer, and the new entity will be bound by this Privacy Policy.

6.4 Game Providers

22pub partners with licensed game providers (Evolution Gaming, Pragmatic Play, NetEnt, etc.) to offer casino games. These providers may collect limited data (bet amounts, game results) to operate their games. Game providers are independent data controllers subject to their own privacy policies.

7. Data Retention

22pub retains your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal obligations. Specific retention periods include:

• Active Accounts: Personal data is retained for the duration of your account activity;
• Closed Accounts: Data is retained for a minimum of five (5) years after account closure to comply with anti-money laundering regulations and resolve disputes;
• Transaction Records: Financial transaction data is retained for at least seven (7) years as required by law;
• Marketing Data: Marketing preferences and communication history are retained until you withdraw consent or request deletion;
• Technical Logs: Server logs and IP addresses are typically retained for six (6) to twelve (12) months for security purposes.

After the retention period expires, personal data is securely deleted or anonymized.

8. Security Measures

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

• Encryption: All sensitive data (passwords, payment information) is encrypted using SSL/TLS protocols;
• Access Controls: Personal data is accessible only to authorized personnel on a need-to-know basis;
• Firewalls and Intrusion Detection: Network security systems monitor and prevent unauthorized access attempts;
• Regular Security Audits: Third-party security experts conduct periodic audits and penetration testing;
• Data Backup: Regular backups ensure data recovery in case of system failure;
• Employee Training: Staff members receive training on data protection and security best practices.

Despite these measures, no system is completely secure. 22pub cannot guarantee absolute security, and you acknowledge that you provide information at your own risk. You are responsible for maintaining the confidentiality of your account credentials.

9. Your Privacy Rights

Under applicable data protection laws, including the Philippine Data Privacy Act, you have the following rights regarding your personal data:

• Right of Access: You may request a copy of the personal data we hold about you;
• Right to Rectification: You may request correction of inaccurate or incomplete data;
• Right to Erasure: You may request deletion of your personal data, subject to legal and regulatory retention requirements;
• Right to Restriction: You may request limitation of processing in certain circumstances;
• Right to Data Portability: You may request a structured, machine-readable copy of your data;
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes;
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time.

To exercise your rights, contact our Data Protection Officer at [email protected]. We will respond to your request within thirty (30) days. Note that certain rights may be limited by legal obligations (e.g., we cannot delete data required for AML compliance).

10. Cookies and Tracking Technologies

22pub uses cookies and similar tracking technologies to enhance your experience on our Platform. Cookies are small text files stored on your device that allow us to recognize you and remember your preferences.

Types of Cookies We Use:

• Essential Cookies: Required for platform functionality (account login, session management, security);
• Preference Cookies: Remember your language, currency, and display settings;
• Analytics Cookies: Collect data on how you use our Platform to improve performance (Google Analytics, Hotjar);
• Marketing Cookies: Track your interaction with promotional content and enable targeted advertising.

You can manage cookie preferences through your browser settings. Disabling cookies may affect platform functionality. By using 22pub, you consent to our use of cookies as described.

11. Protection of Minors

22pub strictly prohibits individuals under the age of twenty-one (21) from accessing or using our services. We do not knowingly collect personal data from minors. If we become aware that a minor has provided personal information, we will take immediate steps to delete such data and close the account.

Parents and guardians are encouraged to monitor their children's internet usage and prevent access to gambling websites. If you believe a minor has registered an account with 22pub, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

22pub reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting a notice on our website homepage;
• Sending an email notification to your registered email address;
• Displaying an in-app notification upon your next login.

The revised Privacy Policy will become effective immediately upon posting. Your continued use of 22pub services after the effective date constitutes acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.