23ph Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 23ph ("we," "us," "our," or "the Platform") collects, uses, stores, and protects the personal information of individuals ("you," "your," or "Player") who access or use the 23ph website at 23ph.vip and all associated services, features, and content.

23ph is committed to protecting the privacy and personal data of all Filipino players and users of our platform. We operate in accordance with applicable data protection laws and regulations in the Republic of the Philippines, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

By registering an account on 23ph, accessing the platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the 23ph platform immediately.

2. Data Controller

For the purposes of applicable data protection legislation, 23ph acts as the data controller in respect of the personal data collected through the 23ph platform. As data controller, 23ph determines the purposes and means by which your personal data is processed.

All data protection inquiries, requests to exercise data subject rights, and privacy-related complaints should be directed to the 23ph Data Protection Officer via the contact details provided in Section 14 of this Policy.

3. Information We Collect

23ph collects the following categories of personal data from players and users of the platform:

3.1 Identity and Contact Information

• Full legal name
• Date of birth (for age verification — must be 21 or older)
• Gender
• Nationality and country of residence
• Residential address (including barangay, city, province, and ZIP code for Philippine-based players)
• Email address
• Mobile phone number

3.2 Identity Verification Documents

• Government-issued identification (e.g., Philippine National ID, passport, driver's license, SSS/GSIS ID, PhilHealth ID, Voter's ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or live photo for identity verification purposes

3.3 Financial and Transaction Data

• GCash account number or registered mobile number
• PayMaya account details
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks)
• Deposit and withdrawal transaction history
• Betting and gaming transaction records

3.4 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration and login timestamps
• Pages visited and features used on the 23ph platform
• Referral source (how you arrived at 23ph)

3.5 Communications Data

• Records of communications with 23ph customer support (chat logs, email correspondence)
• Feedback, complaints, and dispute records
• Responses to surveys or promotional campaigns

4. How We Collect Your Data

23ph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the 23ph platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC (Know Your Customer) service providers; fraud detection data from risk management partners; payment confirmation data from GCash, PayMaya, and banking partners.

5. How We Use Your Data

23ph processes your personal data for the following purposes:

6. Legal Basis for Processing

23ph processes your personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill our obligations to you as a registered player, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, KYC obligations, and regulatory reporting duties.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for optional purposes such as marketing communications, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing of Personal Data

23ph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud and risk management partners: Service providers that assist 23ph in detecting and preventing fraudulent activity and money laundering.
• Game software providers: Licensed game developers and content providers whose games are available on the 23ph platform, to the extent necessary for game operation and fairness auditing.
• Regulatory and law enforcement authorities: Government agencies, regulators, and law enforcement bodies where disclosure is required by law, court order, or regulatory directive.
• Professional advisors: Legal counsel, auditors, and other professional advisors engaged by 23ph, subject to confidentiality obligations.

All third-party service providers engaged by 23ph are contractually required to process personal data only for the specified purpose and to maintain appropriate security measures consistent with applicable data protection law.

8. Data Retention

23ph retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in accordance with AML and KYC regulatory requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Technical and usage data collected via cookies and server logs is retained for up to twelve (12) months, unless a longer retention period is required for security or fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 23ph's data disposal procedures.

9. Data Security

23ph implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 23ph platform.
• Encryption of sensitive data at rest, including financial account details and identity documents.
• Access controls limiting personal data access to authorized 23ph personnel on a strict need-to-know basis.
• Regular security assessments and penetration testing of the 23ph platform infrastructure.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 23ph will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

10. Cookies and Tracking Technologies

23ph uses cookies and similar tracking technologies to operate and improve the platform. The following types of cookies are used:

• Essential cookies: Required for the platform to function correctly, including maintaining your login session and remembering your language and display preferences. These cannot be disabled without affecting platform functionality.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the 23ph platform, helping us identify areas for improvement. No personally identifiable information is collected through analytics cookies.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats.

You can manage cookie preferences through your browser settings. Please note that disabling essential cookies may prevent certain features of the 23ph platform from functioning correctly.

11. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 23ph:

• Right to be informed: The right to know what personal data 23ph collects about you and how it is used — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data 23ph holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to 23ph's legal and regulatory retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact the 23ph Data Protection Officer using the contact details in Section 14. We will respond to all verified requests within thirty (30) days of receipt, in accordance with applicable law.

12. Minors and Age Restriction

The 23ph platform is strictly intended for individuals who are 21 years of age or older. 23ph does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately close the associated account and delete all related personal data.

If you believe that a minor has registered on the 23ph platform, please contact our support team immediately so that we can take appropriate action.

13. Changes to This Policy

23ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email or through a prominent notice on the 23ph platform prior to the changes taking effect.

The effective date at the top of this Policy indicates when it was last updated. We encourage you to review this Policy periodically to stay informed about how 23ph protects your personal data.

14. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 23ph, please contact our Data Protection Officer:

Data Protection Officer — 23ph
Email: [email protected]
Platform: 23ph.vip
Support Hours: 24/7, including Philippine public holidays

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data protection rights have not been adequately addressed by 23ph.