20ph Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") describes how 20ph ("we," "us," "our," or "the Platform") collects, uses, stores, shares, and protects personal data relating to individuals who visit, register on, or use the online casino and sports betting services available at 20ph.app ("the Platform").

This Policy applies to all users of the 20ph platform, including registered account holders, visitors browsing the site without an account, and individuals who contact our customer support team. It covers all personal data processed through the platform, regardless of whether you access 20ph from Manila, Quezon City, Cebu, Davao, or any other location in the Philippines.

This Policy should be read alongside our Terms and Conditions, which govern your use of the 20ph platform as a whole. In the event of any conflict between this Policy and the Terms and Conditions on matters of data privacy, this Policy shall prevail.

2 Data Controller

20ph is the data controller responsible for your personal data collected through the platform. As data controller, 20ph determines the purposes and means by which your personal data is processed, in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC).

All data processing activities carried out by 20ph are conducted within a PAGCOR-regulated environment, meaning our data handling practices are subject to both gaming regulatory oversight and the broader data protection framework under Philippine law.

If you have any questions about how 20ph processes your personal data, or wish to exercise any of your rights under the Data Privacy Act, you may contact our Data Protection Officer at [email protected].

3 Data We Collect

20ph collects personal data that is necessary to provide you with a secure, compliant, and personalized gaming experience. The categories of personal data we collect are described below.

3.1 Registration & Identity Data

When you create a 20ph account, we collect the personal data required to register and verify your identity, including:

• Full legal name (first name, middle name, last name)
• Date of birth (used to verify the 21+ age requirement under PAGCOR regulations)
• Email address and mobile number
• Residential address (city, province, region)
• Username and encrypted account password

3.2 KYC Verification Data

To comply with PAGCOR's Know Your Customer (KYC) requirements and Anti-Money Laundering Act (AMLA) obligations, 20ph may request the following verification documents:

• Government-issued photo ID (e.g., Philippine passport, SSS card, driver's license, UMID, PhilSys ID)
• Proof of address (e.g., utility bill, bank statement issued within the last three months)
• Selfie photograph or live facial verification, where required
• Source of funds declaration, for high-value accounts or as required by AMLA compliance

3.3 Financial & Transaction Data

We collect data related to your deposits, withdrawals, and wagering activity on 20ph, including:

• GCash mobile number, Maya account details, or bank account information (BPI, BDO, UnionBank) used for transactions
• Transaction amounts, dates, reference numbers, and payment method used
• Wagering history, game logs, bet amounts, and win/loss records
• Bonus claims, promotional participation, and reward redemption history

3.4 Technical & Usage Data

When you access the 20ph platform, we automatically collect certain technical data, including:

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Session duration, pages visited, and in-platform navigation patterns
• Cookie identifiers and similar tracking technologies (see Section 8)

3.5 Communications Data

If you contact 20ph via Live Chat, email, or any other support channel, we retain records of that correspondence, including the content of messages, timestamps, and support agent interactions, for quality assurance and dispute resolution purposes.

4 How We Collect Your Data

20ph collects your personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion on the 20ph platform.
• Automatically: Through cookies, server logs, and analytics tools when you browse or interact with the 20ph website or mobile platform.
• From payment providers: Transaction confirmation data from GCash, Maya, BPI, BDO, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT TRC20 processors when you initiate a deposit or withdrawal.
• From identity verification services: Where 20ph uses third-party KYC or facial verification providers to confirm the authenticity of your identity documents.
• From regulatory bodies: Where PAGCOR or other authorities share information relevant to your account or gaming activity in the course of regulatory compliance.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 20ph processes your personal data on the following lawful bases:

• Contractual necessity: Processing your identity, financial, and account data is necessary to perform our contract with you — i.e., to provide you with access to the 20ph platform, process your transactions, and manage your account.
• Legal obligation: Certain data processing is required by Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and data retention requirements under applicable regulations.
• Consent: Where we process your data for marketing communications, personalized promotions, or optional analytics features, we rely on your freely given, informed consent, which you may withdraw at any time.
• Legitimate interests: We process certain technical and usage data to protect the security and integrity of the 20ph platform, prevent fraud, and improve our services — where these interests are not overridden by your data protection rights.

6 How We Use Your Data

20ph uses the personal data we collect for the following specific purposes:

6.1 Account Management

To create, verify, maintain, and secure your 20ph account, including processing your login credentials, verifying your identity at registration, and enforcing the 21+ age restriction required under PAGCOR regulations.

6.2 Payment Processing

To process your deposits and withdrawals via GCash, Maya, BPI, BDO, UnionBank, and other accepted payment methods; to verify that payment sources are registered in your name; and to comply with AMLA transaction monitoring requirements.

6.3 Regulatory Compliance

To fulfill 20ph's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act, and any other applicable Philippine laws and regulations. This includes maintaining transaction records, filing regulatory reports, and cooperating with lawful requests from government authorities.

6.4 Responsible Gaming

To monitor gaming patterns and identify indicators of problem gambling behavior, apply self-exclusion and deposit limit controls requested by players, and comply with PAGCOR's responsible gaming program requirements. 20ph takes this responsibility seriously and processes relevant data to actively protect vulnerable players.

6.5 Security & Fraud Prevention

To detect, investigate, and prevent fraudulent transactions, unauthorized account access, money laundering, and abuse of the 20ph platform, including the use of automated tools and multi-account operations.

6.6 Customer Support

To respond to your queries, process complaints, and resolve disputes through our 24/7 Live Chat and email support channels. Support interaction records are retained to maintain quality standards and provide consistent service.

6.7 Marketing & Promotions

Where you have provided consent, 20ph may use your contact details and gameplay preferences to send you personalized promotional offers, bonus notifications, and platform updates. You may opt out of marketing communications at any time by contacting support or updating your account preferences.

6.8 Platform Improvement

To analyze aggregated usage data, identify platform performance issues, and improve the overall gaming experience for Filipino players on the 20ph platform. Where possible, data used for this purpose is anonymized or pseudonymized.

7 Data Sharing & Disclosure

20ph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data only in the following limited circumstances:

• Payment processors: GCash, Maya, BPI, BDO, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT TRC20 processors receive the minimum transaction data necessary to process your deposits and withdrawals.
• KYC and identity verification providers: Where 20ph uses a third-party service to verify government-issued IDs or perform liveness checks, your submitted documents are processed under strict confidentiality agreements.
• Game content providers: Our licensed game providers may receive anonymized session data for the purpose of administering game rounds and resolving technical disputes. They do not receive your personal identity or financial data.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government bodies may receive your data where required by law, court order, or regulatory direction.
• Fraud prevention networks: In cases of suspected fraud or money laundering, 20ph may share relevant data with other licensed operators or industry fraud prevention organizations, as permitted under applicable law.
• Professional advisers: Lawyers, auditors, and compliance consultants engaged by 20ph who require access to your data in the course of providing professional services, subject to strict confidentiality obligations.

8 Cookies & Tracking Technologies

The 20ph platform uses cookies and similar tracking technologies to enhance your user experience, maintain session security, and gather usage analytics. Below is a summary of the cookies we use:

Essential cookies are strictly necessary for the 20ph platform to function and cannot be disabled. For functional, analytics, and marketing cookies, you may manage your preferences at any time through your browser settings. Note that disabling certain cookies may affect the functionality of some platform features.

We do not use cookies or tracking technologies to build advertising profiles for third-party ad networks or to track your activity on websites other than 20ph.app.

9 Data Retention

20ph retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following retention periods apply:

• Account and identity data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and AMLA obligations.
• Financial and transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act and its implementing regulations.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the business relationship.
• Support and communications records: Retained for three (3) years from the date of the interaction, unless the subject matter relates to an unresolved dispute or legal proceeding, in which case records are retained until resolution.
• Marketing consent records: Retained for the duration of your consent plus two (2) years following withdrawal, to demonstrate compliance with consent requirements.
• Technical and usage logs: Retained for up to thirteen (13) months for analytics purposes; security logs may be retained for up to five (5) years for fraud investigation purposes.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymized in a manner that prevents re-identification.

10 Data Security

20ph implements a multi-layered approach to data security designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your browser or device and the 20ph platform, ensuring that your login credentials, financial data, and personal information cannot be intercepted in transit.
• Encrypted storage for all sensitive personal data — including passwords (stored as one-way hashes), payment account details, and KYC documents — on secured servers.
• Access controls: Personal data is accessible only to 20ph staff and service providers on a strict need-to-know basis, enforced through role-based access control systems.
• Regular security assessments including vulnerability scanning and penetration testing of the 20ph platform infrastructure.
• Two-factor authentication (2FA) available for player accounts, adding an additional layer of protection beyond your password.
• Fraud monitoring systems that continuously analyze transaction and login patterns to detect and flag suspicious activity in real time.

11 Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 20ph:

• Right to be informed: You have the right to be informed of how your personal data is collected, used, stored, and shared. This Privacy Policy fulfills that obligation.
• Right of access: You may request a copy of the personal data 20ph holds about you, along with information about how it is processed.
• Right to rectification: If any personal data 20ph holds about you is inaccurate or incomplete, you have the right to request its correction.
• Right to erasure (right to be forgotten): You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests, at any time.
• Right to data portability: Where technically feasible, you may request a copy of the personal data you provided to 20ph in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: If you believe 20ph has processed your personal data in a manner inconsistent with the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will acknowledge your request within five (5) business days and aim to fulfill it within thirty (30) calendar days, subject to identity verification and any applicable legal exceptions.

12 Children's Privacy & Age Restriction

The 20ph platform is strictly intended for individuals who are at least twenty-one (21) years of age, in compliance with PAGCOR's age restriction for online casino and sports betting activities in the Philippines. 20ph does not knowingly collect personal data from individuals under 21 years of age.

During the registration process, all users are required to declare that they meet the 21+ age requirement. 20ph further enforces this restriction through mandatory KYC identity verification, which includes confirmation of date of birth against a valid government-issued Philippine ID.

If 20ph discovers that personal data has been collected from an individual who does not meet the 21+ age requirement, the affected account will be immediately suspended, all associated data will be securely deleted in accordance with our data retention policy, and any funds held in the account will be handled in accordance with applicable PAGCOR guidelines.

13 Changes to This Privacy Policy

20ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. When we make material changes to this Policy, we will notify registered players by email or through a prominent notice on the platform, no less than seven (7) days prior to the updated Policy taking effect.

The "Last Updated" date displayed at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how 20ph protects your personal data.

Your continued use of the 20ph platform after the effective date of any revised Privacy Policy constitutes your acknowledgment and acceptance of the updated terms. If you do not agree with any amendment, you should discontinue use of the platform and request account closure before the revised Policy takes effect.

14 Contact & Complaints

If you have any questions, concerns, or formal complaints regarding this Privacy Policy or the way 20ph handles your personal data, please reach out to our Data Protection Officer through any of the following channels:

We aim to acknowledge all privacy-related complaints within 48 hours and to resolve them within 30 calendar days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.