21phmaya Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 21phmaya ("we," "us," "our," or "the Platform") collects, uses, stores, shares, and protects the personal information of individuals ("you," "your," or "Player") who access or use the 21phmaya website, mobile platform, games, and all related services (collectively, the "Services").

21phmaya is committed to safeguarding the privacy of all players, particularly in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations. This Policy applies to all personal data collected through your use of the 21phmaya platform, regardless of whether you are a registered player or a visitor browsing our site.

This Privacy Policy should be read alongside our Terms & Conditions, which govern your overall use of the 21phmaya platform and are incorporated herein by reference.

2 Who We Are

21phmaya is an online gaming and entertainment platform operated for the benefit of Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Makati, Quezon City, and beyond. The platform offers a range of gaming products including live dealer casino games, slots, bingo, Andar Bahar, table tennis betting, and other entertainment services.

For the purposes of this Privacy Policy, 21phmaya acts as the data controller in respect of the personal information collected from players and visitors through the platform. As data controller, 21phmaya determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

3 Personal Data We Collect

21phmaya collects personal data that is necessary to provide our Services, verify player identity, process financial transactions, and comply with applicable legal and regulatory obligations. The categories of personal data we collect include the following:

3.1 Registration & Identity Data

• Full legal name
• Date of birth (for age verification — players must be 21 years of age or older)
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted password
• Government-issued identification documents (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys ID) submitted during KYC verification

3.2 Financial & Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash account reference, PayMaya account reference, BPI, BDO, or Metrobank account details — stored in tokenized or reference form only)
• Account balance history
• Bonus and promotional credit records

3.3 Gaming Activity Data

• Game session history, including games played, wagers placed, and outcomes
• Betting patterns and preferences
• Responsible gaming tool usage (e.g., deposit limits set, self-exclusion requests)

3.4 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and duration
• Cookies and similar tracking technology data (see Section 8)

3.5 Communications Data

• Records of communications between you and 21phmaya support staff
• Feedback, complaints, and dispute records
• Marketing preference settings

4 How We Collect Your Data

21phmaya collects personal data through the following means:

5 How We Use Your Personal Data

21phmaya uses the personal data we collect for the following purposes:

• Account management: Creating, maintaining, and administering your 21phmaya player account.
• Identity verification: Confirming your identity and age (21+) in compliance with Philippine gaming regulations and KYC requirements.
• Transaction processing: Processing deposits, withdrawals, and bonus credits through approved payment channels including GCash, PayMaya, BPI, BDO, and Metrobank.
• Service delivery: Providing access to games, live dealer tables, bingo, slots, Andar Bahar, table tennis betting, and all other platform features.
• Customer support: Responding to your enquiries, resolving disputes, and providing technical assistance.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, and other prohibited conduct on the platform.
• Regulatory compliance: Meeting our obligations under Philippine law, including anti-money laundering (AML) reporting requirements and responsible gaming obligations.
• Responsible gaming: Monitoring gaming activity to identify potential problem gambling behaviors and administering responsible gaming tools such as deposit limits and self-exclusion.
• Platform improvement: Analyzing usage patterns and player feedback to improve the quality, performance, and features of the 21phmaya platform.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time.

6 Legal Basis for Processing

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

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration, including account management, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and responsible gaming mandates.
• Legitimate interests: Processing carried out for the legitimate interests of 21phmaya, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent — particularly for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

21phmaya 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 and subject to appropriate data protection safeguards:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment partners, for the purpose of processing deposits and withdrawals.
• Identity verification and KYC providers: Third-party services engaged to verify player identity and conduct AML screening.
• IT and platform service providers: Cloud hosting, data storage, cybersecurity, and technical support providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Government agencies, regulators, and law enforcement bodies where disclosure is required by applicable Philippine law, court order, or regulatory directive.
• Fraud prevention and risk management services: Third-party providers engaged to detect and prevent fraudulent activity on the platform.
• Professional advisors: Legal counsel, auditors, and other professional advisors engaged by 21phmaya, subject to professional confidentiality obligations.

In the event of a merger, acquisition, or sale of all or part of 21phmaya's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.

8 Cookies & Tracking Technologies

21phmaya uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and support security functions. A cookie is a small text file placed on your device when you visit our website.

8.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the platform to function correctly. These include session authentication cookies that keep you logged in to your 21phmaya account. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations to provide a more personalized experience.
• Analytics cookies: Help us understand how players interact with the platform — which pages are visited most, how long sessions last, and where players encounter difficulties. This data is aggregated and anonymized.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

8.2 Managing Cookies

You can control non-essential cookies through your browser settings or through the cookie preference center available on the 21phmaya platform. Please note that disabling certain cookies may affect the functionality of the platform and your ability to access some features. Strictly necessary and security cookies cannot be disabled without impacting your ability to use the Services.

9 Data Retention

21phmaya retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, to comply with our legal and regulatory obligations, and to resolve any disputes or enforce our agreements. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures. Where data is anonymized, it may be retained indefinitely for statistical and analytical purposes as it can no longer be linked to an identifiable individual.

10 Data Security

21phmaya implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your device and the 21phmaya platform is encrypted using industry-standard SSL/TLS protocols.
• Data encryption at rest: Sensitive personal data stored on our servers is encrypted using strong encryption algorithms.
• Access controls: Access to personal data is restricted to authorized 21phmaya personnel and third-party processors on a strict need-to-know basis. All access is logged and audited.
• Password security: Player passwords are stored in hashed form using industry-standard cryptographic hashing algorithms. We never store passwords in plain text.
• Regular security assessments: 21phmaya conducts regular security audits, vulnerability assessments, and penetration testing to identify and address potential weaknesses in our systems.
• Incident response: We maintain a documented data breach response procedure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected players and relevant authorities in accordance with applicable law.

11 Your Data Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by 21phmaya. To exercise any of these rights, please contact us using the details provided in Section 15.

12 Children's Privacy

The 21phmaya platform is strictly intended for adults who are 21 years of age or older, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21. If you are under 21 years of age, you are not permitted to use the 21phmaya platform and must not submit any personal data to us.

If 21phmaya becomes aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the 21phmaya platform, please contact us immediately at [email protected].

13 Third-Party Services & Links

The 21phmaya platform may integrate with or reference third-party services, including payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank. These third-party services operate under their own privacy policies and terms of service, which are independent of this Policy.

21phmaya is not responsible for the privacy practices or content of any third-party services. We encourage you to review the privacy policies of any third-party services you use in connection with your 21phmaya account, particularly your chosen payment provider, before submitting personal data to them.

Where 21phmaya engages third-party data processors (as described in Section 7), those processors are contractually bound to handle your data in accordance with this Policy and applicable data protection law. They are not permitted to use your data for their own purposes.

14 Updates to This Privacy Policy

21phmaya reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the Services we offer . When material changes are made to this Policy, we will notify registered players through one or more of the following methods: an email notification to the address registered on your account, a prominent notice displayed on the 21phmaya website, or an in-platform notification upon your next login.

The date of the most recent revision to this Privacy Policy is indicated at the top of this page under "Last Updated." We encourage you to review this Policy periodically to stay informed about how 21phmaya protects your personal data. Your continued use of the platform following the posting of any revised Policy constitutes your acceptance of the changes.

If you do not agree with any changes to this Privacy Policy, you should discontinue use of the 21phmaya platform and may request the closure of your account by contacting our support team.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 21phmaya handles your personal data, please contact our dedicated privacy support team. We take all privacy enquiries seriously and will respond promptly.

You can reach us through the following channel:

If you are not satisfied with our response to your privacy enquiry, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.