Privacy Policy – 21phcash

1. Personal Data We Collect

21phcash collects personal data that is necessary to provide you with our Services, comply with our legal and regulatory obligations, and maintain the security and integrity of the platform. The categories of personal data we collect include:

2. How We Collect Your Data

2.1 Directly From You

The majority of personal data 21phcash holds about you is provided directly by you when you: register an account; complete KYC verification; make a deposit or withdrawal; contact our customer support team; participate in promotions or surveys; or communicate with us by any means.

2.2 Automatically

When you access and use the 21phcash platform, we automatically collect certain technical and usage data through cookies, web beacons, log files, and similar tracking technologies. This includes your IP address, device identifiers, browser information, pages visited, and actions taken on the platform.

2.3 From Third Parties

21phcash may receive personal data about you from third parties in limited circumstances, including: payment service providers (for transaction verification); identity verification service providers (for KYC purposes); fraud prevention and anti-money laundering screening services; and regulatory authorities where required by law.

3. How We Use Your Personal Data

21phcash uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your 21phcash player account, including verifying your identity and age;
• Service delivery: To provide you with access to our games, process your deposits and withdrawals, and deliver the Services you have requested;
• Regulatory compliance: To comply with our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the DPA, and other applicable Philippine laws;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other illegal activities;
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Communications: To send you transactional notifications, account alerts, and — where you have consented — promotional communications about 21phcash offers and updates;
• Platform improvement: To analyze usage patterns, conduct research, and improve the functionality and user experience of the 21phcash platform;
• Legal proceedings: To establish, exercise, or defend legal claims involving 21phcash.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 21phcash processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform our contract with you — specifically, to operate your 21phcash account and deliver the Services you have signed up for;
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AMLA obligations, and NPC directives;
• Legitimate interests: Processing is necessary for the legitimate interests of 21phcash, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and freedoms;
• Consent: Where we rely on your consent — for example, to send you marketing communications — you may withdraw that consent at any time by contacting us or updating your account preferences.

5. Sharing Your Personal Data

5.1 Service Providers

21phcash engages trusted third-party service providers to assist in operating the platform and delivering the Services. These providers may process your personal data on our behalf and are contractually bound to handle it securely and only for the purposes we specify. Categories of service providers include: payment processors (GCash, Maya, and Philippine bank partners); identity verification and KYC providers; IT infrastructure and cloud hosting providers; customer support platform providers; and analytics and fraud detection services.

5.2 Regulatory and Law Enforcement Authorities

21phcash may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), or other competent Philippine government authorities where required by law, court order, or regulatory directive.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of the 21phcash business, your personal data may be transferred to the relevant successor entity. We will notify you of any such transfer and the applicable privacy terms before your data is transferred and becomes subject to a different privacy policy.

5.4 No Sale of Personal Data

21phcash does not sell, rent, or trade your personal data to third parties for their own independent marketing or commercial purposes. Any sharing of data is limited to what is necessary for the purposes described in this Policy.

6. Data Retention

21phcash retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

Upon expiry of the applicable retention period, 21phcash will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

7. Data Security

7.1 Technical Safeguards

21phcash implements appropriate technical security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include Transport Layer Security (TLS) encryption for all data in transit, encryption of sensitive data at rest, firewalls and intrusion detection systems, regular security vulnerability assessments, and access controls limiting data access to authorized personnel only.

7.2 Organizational Safeguards

In addition to technical measures, 21phcash maintains organizational safeguards including staff training on data privacy and security obligations, data processing agreements with all third-party service providers, internal data access policies based on the principle of least privilege, and a designated Data Protection Officer (DPO) responsible for overseeing compliance with the DPA.

7.3 Data Breach Response

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 21phcash will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required under the DPA. Affected individuals will be notified without undue delay where the breach is likely to result in a high risk to their rights.

7.4 Your Responsibility

While 21phcash takes all reasonable steps to protect your data, you are also responsible for maintaining the security of your account credentials. Do not share your 21phcash username or password with anyone, and contact us immediately if you suspect unauthorized access to your account.

8. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 21phcash:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed by 21phcash, as set out in this Policy.
• Right to Access: You have the right to request a copy of the personal data 21phcash 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 may update certain information directly through your 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 and regulatory retention obligations.
• Right to Object: You have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis, or where we process your data for direct marketing purposes.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to Lodge a Complaint: If you believe that 21phcash has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

9. Cookies & Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 21phcash website. They help us recognize your device, remember your preferences, keep you logged in, and understand how you use our platform. We also use similar technologies such as web beacons and local storage for comparable purposes.

9.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the operation of the 21phcash platform, including maintaining your login session and enabling core security features. These cannot be disabled.
• Functional Cookies: Allow the platform to remember your preferences and settings, such as your preferred language and display options.
• Analytics Cookies: Help us understand how players interact with the 21phcash platform, which pages are most visited, and where improvements can be made. Data collected is aggregated and anonymized.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats on the platform.

9.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a cookie is set. Please note that disabling certain cookies may affect the functionality of the 21phcash platform and your ability to access some features.

10. Minors and Age Verification

The 21phcash platform is strictly intended for individuals who are at least twenty-one (21) years of age. We do not knowingly collect personal data from individuals under the age of 21. If you are a parent or guardian and believe that a minor has provided personal data to 21phcash, please contact us immediately at [email protected] and we will take prompt steps to delete such data and close any associated account.

11. Changes to This Privacy Policy

21phcash reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players by posting a prominent notice on the platform or by sending a notification to the email address associated with your account. The "Last Updated" date at the top of this page will always reflect the date of the most recent revision.

Your continued use of the 21phcash platform following the posting of an updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

12. Contact Our Data Protection Officer

21phcash has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Philippine Data Privacy Act. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact our DPO using the details below. We are committed to addressing all privacy-related inquiries promptly and transparently.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.