Privacy Policy

1. Introduction

22two666 ("we," "us," "our," or the "Platform") is committed to protecting the personal information of all users who access and use our online gaming services. This Privacy Policy applies to all personal data collected through the 22two666 website, mobile platform, and any related services offered to players in the Philippines and other permitted jurisdictions.

By registering an account or continuing to use the 22two666 Platform, 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 any part of this Policy, you should discontinue use of the Platform immediately.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

For the purposes of applicable data protection legislation, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, 22two666 acts as the data controller in respect of personal data collected through the Platform.

All data protection inquiries, requests to exercise your rights, or concerns regarding this Privacy Policy should be directed to our Data Protection Officer at the contact details provided in Section 14 of this Policy.

3. Data We Collect

22two666 collects the following categories of personal data from users of the Platform:

Category	Examples	Purpose
Identity Data	Full name, date of birth, gender, government-issued ID number	Account registration, age verification, KYC compliance
Contact Data	Email address, mobile number, residential address (city, province)	Account communications, support, notifications
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), transaction history	Processing deposits and withdrawals, fraud prevention
Technical Data	IP address, device type, browser type, operating system, session logs	Platform security, fraud detection, service improvement
Usage Data	Games played, wager amounts, session duration, bonus usage	Responsible gaming monitoring, personalization, analytics
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Customer service, dispute resolution, quality assurance

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data unless specifically required by law or responsible gaming obligations.

4. How We Collect Data

22two666 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 participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from payment processors; publicly available information where permitted by law.

5. How We Use Your Data

22two666 uses the personal data we collect for the following purposes:

• To create, verify, and manage your 22two666 account.
• To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels.
• To comply with our legal and regulatory obligations, including anti-money laundering (AML) requirements and responsible gaming mandates.
• To verify your age and identity in accordance with the 21+ age restriction applicable to casino-style gaming in the Philippines.
• To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct.
• To provide customer support and resolve disputes.
• To send you transactional communications, account notifications, and — where you have opted in — promotional offers and updates.
• To monitor and enforce responsible gaming limits, self-exclusion requests, and cooling-off periods.
• To improve the Platform, analyze usage patterns, and develop new features and game offerings.

22two666 does not sell your personal data to third parties for their own marketing purposes.

6. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 22two666 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML, KYC, and responsible gaming requirements.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.

7. Sharing Your Data

22two666 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers for the purpose of processing financial transactions.
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory requirements.
• Game software providers: Licensed game developers and live dealer studios whose games are hosted on the 22two666 Platform.
• Regulatory authorities: Government agencies and regulators, including PAGCOR and the National Privacy Commission (NPC), where disclosure is required by law.
• Professional advisors: Legal counsel, auditors, and other professional service providers engaged by 22two666 in the ordinary course of business.
• Law enforcement: Where required by a valid court order, subpoena, or other legal process.

22two666 does not transfer your personal data to recipients outside the Philippines except where necessary to provide the Platform services and subject to appropriate safeguards consistent with the Data Privacy Act.

8. Cookies & Tracking Technologies

22two666 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how you use the Platform.

We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled.
• Performance cookies: Collect anonymized data about how users interact with the Platform to help us improve performance and user experience.
• Functional cookies: Remember your preferences, such as language settings and login status.
• Analytics cookies: Help us understand aggregate usage patterns and measure the effectiveness of our content and promotions.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

9. Data Retention

22two666 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements.

As a general rule, account data and transaction records are retained for a minimum of five (5) years following the closure of your account, in accordance with AML regulations and applicable Philippine law. Communications data is retained for three (3) years. Technical and usage data is retained for up to two (2) years.

Where data is no longer required, 22two666 will securely delete or anonymize it in accordance with our data retention schedule.

10. Data Security

22two666 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Encryption of data in transit using industry-standard TLS/SSL protocols.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Access controls limiting data access to authorized personnel on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning.
• Staff training on data protection and information security best practices.

While 22two666 takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorized access.

11. Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 22two666:

• Right to be informed: The right to know what personal data we collect and how it is used.
• Right of access: The right to request a copy of the personal data we hold 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 our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. We will respond to all verified requests within thirty (30) days.

12. Children's Privacy

The 22two666 Platform is strictly intended for users who are 21 years of age or older. We do 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 take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered on the Platform, please contact us immediately at the details provided in Section 14.

13. Changes to This Policy

22two666 reserves the right to update or amend this Privacy Policy at any time. Any changes will be published on this page with a revised "Last Updated" date. Where changes are material, we will notify registered users via email or in-platform notification. Your continued use of the Platform following the publication of any amendment constitutes your acceptance of the revised Policy.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our Data Protection Officer:

Email: [email protected]

We aim to respond to all data protection inquiries within thirty (30) days of receipt. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.