Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by 21phcash ("we," "us," "our," or "the Platform") and applies to all personal data collected from individuals ("you," "Player," or "User") who access or use the 21phcash website at 21phcash.net and all associated services, features, and games offered thereon.

21phcash is committed to protecting the privacy and personal data of all players in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

By registering an account on 21phcash, making a deposit, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection, use, and processing of your personal data as described herein. If you do not agree to this Policy, you must not use the 21phcash platform.

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

2 Personal Data We Collect

21phcash collects the following categories of personal data from players, collected only to the extent necessary for the purposes described in this Policy:

21phcash does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by applicable law or regulation (for example, problem gambling self-declaration for responsible gaming purposes).

3 How We Collect Your Data

21phcash collects personal data through the following means:

• Direct collection: Information you provide when registering your 21phcash account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the 21phcash platform, including through cookies, web beacons, and server logs. See Section 7 for more detail on cookies.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors.
• Publicly available sources: Where permitted by law, we may supplement your data with information from publicly available sources for fraud prevention or regulatory compliance purposes.

4 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 processing your registration and verifying your identity.
• Transaction processing: To process deposits and withdrawals in Philippine Peso (₱) via your chosen payment method, and to maintain accurate financial records.
• Identity and age verification: To verify that you meet the minimum age requirement of 21 years and to conduct KYC checks as required by applicable regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal conduct on the Platform.
• Regulatory compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) reporting requirements and data retention obligations.
• Responsible gaming: To monitor gameplay patterns for signs of problem gambling and to administer self-exclusion, deposit limit, and session reminder tools requested by players.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Service improvement: To analyze usage patterns and improve the functionality, performance, and content of the 21phcash platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may opt out at any time.
• Legal proceedings: To establish, exercise, or defend legal claims involving 21phcash.

5 Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your 21phcash account, process transactions, and provide gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and data retention mandates.
• Legitimate interests: Processing necessary for 21phcash's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — for example, for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

21phcash does not sell your personal data. We may share your 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, to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention and AML partners: Service providers that assist 21phcash in detecting and preventing fraudulent activity and money laundering.
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Government agencies, regulators, and law enforcement bodies in the Philippines where disclosure is required by law, court order, or regulatory direction — including PAGCOR and the Anti-Money Laundering Council (AMLC).
• Professional advisers: Lawyers, auditors, and accountants engaged by 21phcash, subject to professional confidentiality obligations.

All third parties with whom 21phcash shares personal data are required to handle that data in accordance with applicable privacy laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

7 Cookies & Tracking Technologies

21phcash uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session security, and analyze usage patterns. The following types of cookies may be used:

• Essential cookies: Strictly necessary for the Platform to function. These include session authentication cookies that keep you logged in to your 21phcash account. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience on 21phcash.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the Platform — such as which games are most popular and how long sessions last — to help us improve 21phcash.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the Platform.

You can manage cookie preferences through your browser settings. Please note that disabling essential cookies may prevent you from accessing certain features of the 21phcash platform, including your account login.

8 Data Retention

21phcash retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general guide, 21phcash applies the following retention periods:

• Account data: Retained for the duration of your active account relationship with 21phcash, plus a minimum of five (5) years following account closure, in compliance with Philippine AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the end of the business relationship.
• Support communications: Retained for up to three (3) years from the date of the communication, or longer if relevant to an ongoing dispute or legal proceeding.
• Marketing consent records: Retained until you withdraw consent, plus a reasonable period thereafter to demonstrate compliance.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 21phcash's data disposal procedures.

9 Data Security

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

• SSL/TLS encryption: All data transmitted between your device and the 21phcash platform is encrypted using industry-standard SSL/TLS protocols.
• Secure data storage: Personal and financial data is stored on secure, access-controlled servers with restricted access limited to authorized personnel only.
• Access controls: Strict role-based access controls ensure that 21phcash staff can only access personal data to the extent necessary for their specific job function.
• Regular security assessments: 21phcash conducts regular security reviews and vulnerability assessments of its platform infrastructure.
• Incident response: In the event of a personal data breach that poses a risk to your rights and freedoms, 21phcash will notify the National Privacy Commission and affected players in accordance with the requirements of the Philippine Data Privacy Act.

While 21phcash takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your 21phcash account credentials and for notifying us immediately if you suspect unauthorized access to your account.

10 Your Data 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: The right to be told what personal data 21phcash collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data 21phcash holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held by 21phcash.
• Right to erasure: 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 retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time.
• 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) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact the 21phcash support team using the contact details provided in Section 15. We will respond to all verified requests within the timeframes required by applicable law. Please note that some rights are subject to limitations — for example, we cannot delete data that we are legally required to retain.

11 Children's Privacy

The 21phcash platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations applicable to casino-style online gaming. 21phcash does not knowingly collect personal data from individuals under the age of 21.

If 21phcash becomes aware that personal data has been collected from a person under the age of 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 21phcash platform, please contact our support team immediately.

Parents and guardians are encouraged to use parental control tools and to monitor their children's internet usage to prevent underage access to online gaming platforms.

12 International Data Transfers

21phcash primarily processes and stores personal data within the Philippines. In some cases, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or KYC verification partners operating in other jurisdictions.

Where such transfers occur, 21phcash ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses that require the recipient to handle your data to a standard equivalent to that required under Philippine law.

By using the 21phcash platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

13 Third-Party Links

The 21phcash platform may contain links to third-party websites or services — for example, payment provider portals. This Privacy Policy applies only to the 21phcash platform and does not cover the privacy practices of any third-party websites or services.

21phcash is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party services you access in connection with your use of 21phcash.

14 Updates to This Privacy Policy

21phcash reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will update the "Last Updated" date at the top of this page.

Where required by applicable law, or where changes are significant, we may also notify registered players via email or in-platform notification. Your continued use of the 21phcash platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy.

We recommend reviewing this Privacy Policy periodically to stay informed about how 21phcash protects your personal data.

15 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 21phcash handles your personal data, please contact our Data Privacy team. We are committed to addressing all privacy-related inquiries promptly and transparently.

For questions about responsible gaming tools, self-exclusion, or deposit limits, please visit our Responsible Gaming page. For general platform questions, visit our FAQ page.