1. Overview
101ph22 is committed to protecting the privacy and personal data of every player who uses our platform. We understand that trust is the foundation of a good gaming relationship, and that trust starts with being transparent about how we handle your information.
This Policy applies to all personal data collected through the 101ph22 website, mobile platform, customer support channels, and any other touchpoints where you interact with 101ph22. It covers data collected from registered players, visitors who browse the platform without registering, and individuals who contact our support team.
This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference. If there is any conflict between this Policy and those documents on matters of data privacy, this Policy shall prevail.
2. Data Controller
For the purposes of the Data Privacy Act of 2012 and applicable data protection regulations, 101ph22 acts as the Personal Information Controller (PIC) in respect of the personal data it collects from users of the platform.
As the Personal Information Controller, 101ph22 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 in accordance with this Policy and applicable Philippine law.
If you have any questions about how 101ph22 processes your personal data, or if you wish to exercise any of your data subject rights, please contact our Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy.
3. Personal Data We Collect
101ph22 collects the following categories of personal data from players and platform users:
3.1 Identity & Contact Data
- Full legal name as it appears on your government-issued ID
- Date of birth (for age verification purposes)
- Nationality and country of residence
- Residential address (including barangay, city/municipality, province)
- Philippine mobile number
- Email address
3.2 Account & Authentication Data
- Username and encrypted password
- Security questions and answers (if applicable)
- Account registration date and history
- Login timestamps and session data
3.3 Identity Verification (KYC) Data
- Government-issued ID (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID)
- Proof of address documents
- Selfie or facial image for identity verification
- Proof of payment method ownership
3.4 Financial & Transaction Data
- Deposit and withdrawal transaction records
- Payment method details (e.g., GCash mobile number, bank account name — not full account numbers)
- Transaction amounts, dates, and reference numbers
- Bonus and promotional activity records
3.5 Gaming Activity Data
- Game history, bet amounts, and outcomes
- Session duration and frequency of play
- Responsible gaming tool usage (deposit limits, self-exclusion requests)
- Bonus wagering activity
3.6 Technical & Device Data
- IP address and approximate geolocation
- Device type, operating system, and browser information
- Cookie identifiers and session tokens
- Platform access logs and error reports
3.7 Communications Data
- Customer support chat transcripts and email correspondence
- Feedback and survey responses
- Marketing preference settings
4. How We Collect Your Data
101ph22 collects personal data through the following means:
| Collection Method | Examples |
|---|---|
| Direct submission | Registration form, KYC document upload, support contact forms, survey responses |
| Automated collection | Cookies, session logs, IP address capture, device fingerprinting during platform use |
| Transaction processing | Payment gateway data shared during deposit and withdrawal processing |
| Third-party verification | Identity verification services used for KYC compliance |
| Regulatory sources | Watchlists and databases checked for AML and sanctions compliance |
5. How We Use Your Personal Data
101ph22 uses your personal data only for the purposes described below. We do not use your data for any purpose that is incompatible with the original purpose for which it was collected without your prior consent.
- Account management: Creating, maintaining, and securing your 101ph22 player account.
- Identity verification (KYC): Verifying your age (21+), identity, and eligibility to use the platform in compliance with Philippine gaming regulations.
- Transaction processing: Processing deposits, withdrawals, and bonus credits to and from your account.
- Regulatory compliance: Meeting our obligations under Philippine anti-money laundering (AML) laws, gaming regulations, and tax reporting requirements.
- Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, cheating, and unauthorized account access.
- Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior and administering responsible gaming tools such as deposit limits and self-exclusion.
- Customer support: Responding to your queries, complaints, and support requests.
- Platform improvement: Analyzing usage data to improve the performance, features, and user experience of the 101ph22 platform.
- Marketing communications: Sending you promotional offers, bonus notifications, and platform updates, subject to your marketing preferences. You may opt out at any time.
- Legal proceedings: Establishing, exercising, or defending legal claims where necessary.
6. Legal Basis for Processing
Under the Data Privacy Act of 2012, 101ph22 processes your personal data on the following legal bases:
- Contractual necessity: Processing required to perform our contract with you (i.e., operating your player account, processing transactions).
- Legal obligation: Processing required to comply with Philippine laws, including AML regulations, gaming licensing requirements, and tax obligations.
- Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our legitimate interests are not overridden by your privacy rights.
- Consent: Processing for marketing communications and non-essential cookies, where you have given your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
7. Data Sharing & Disclosure
101ph22 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:
7.1 Service Providers
We engage trusted third-party service providers to assist in operating the 101ph22 platform, including payment processors, KYC verification providers, cloud hosting providers, and customer support platforms. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.
7.2 Regulatory & Law Enforcement Authorities
101ph22 may disclose your personal data to Philippine government agencies, regulatory bodies (including PAGCOR), the Anti-Money Laundering Council (AMLC), and law enforcement authorities where required by law or where we have a good-faith belief that disclosure is necessary to comply with a legal obligation, protect the rights of 101ph22 or third parties, or prevent fraud or illegal activity.
7.3 Business Transfers
In the event of a merger, acquisition, or sale of all or substantially all of the assets of 101ph22, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you via a prominent notice on the 101ph22 platform prior to your data being transferred and becoming subject to a different privacy policy.
8. Data Retention
101ph22 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:
| Data Category | Retention Period | Reason |
|---|---|---|
| Account & identity data | Duration of account + 5 years after closure | AML compliance, regulatory audit |
| KYC documents | Duration of account + 5 years after closure | AMLC and gaming regulatory requirements |
| Transaction records | 10 years from transaction date | Tax and AML reporting obligations |
| Gaming activity logs | 5 years from date of activity | Dispute resolution, responsible gaming |
| Support communications | 3 years from last interaction | Quality assurance, dispute resolution |
| Marketing preferences | Until opt-out or account closure | Consent management |
| Technical & device logs | 12 months from collection | Security monitoring, fraud detection |
When your personal data is no longer required for any of the above purposes, 101ph22 will securely delete or anonymize it in accordance with our internal data disposal procedures.
9. Data Security
101ph22 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:
- SSL/TLS encryption: All data transmitted between your device and the 101ph22 platform is encrypted using industry-standard SSL/TLS protocols.
- Password hashing: Account passwords are stored using strong one-way cryptographic hashing algorithms. 101ph22 staff cannot view your password in plain text.
- Access controls: Access to personal data is restricted to authorized 101ph22 personnel and service providers on a strict need-to-know basis. All access is logged and audited.
- Secure data centers: Player data is stored on servers located in secure, access-controlled data center facilities with physical and environmental safeguards.
- Regular security assessments: 101ph22 conducts periodic security reviews and vulnerability assessments to identify and address potential risks to player data.
- Incident response: In the event of a personal data breach that poses a risk to your rights and freedoms, 101ph22 will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.
10. Cookies & Tracking Technologies
101ph22 uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyze how the platform is used. The following types of cookies may be used:
10.1 Strictly Necessary Cookies
These cookies are essential for the platform to function and cannot be disabled. They include session cookies that keep you logged in during your visit and security cookies that help protect against fraudulent activity. No consent is required for these cookies as they are necessary for the provision of the service.
10.2 Functional Cookies
These cookies remember your preferences and settings, such as your preferred language and responsible gaming tool configurations, to provide a more personalized experience on the 101ph22 platform.
10.3 Analytics Cookies
With your consent, 101ph22 uses analytics cookies to collect aggregated, anonymized data about how players use the platform. This data helps us understand which features are most popular, identify technical issues, and improve the overall platform experience. Analytics data is not used to identify individual players.
10.4 Managing Cookies
You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies may affect the functionality of the 101ph22 platform and your ability to access certain features. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.
11. Your Privacy Rights
Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 101ph22. These rights may be subject to certain limitations where processing is required for legal compliance or regulatory purposes.
Request a copy of the personal data 101ph22 holds about you and information about how it is processed.
Request correction of inaccurate or incomplete personal data held in your 101ph22 account.
Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.
Object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
Receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.
Request that 101ph22 restrict the processing of your personal data in certain circumstances, such as while a rectification request is being assessed.
To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified data subject requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and we will notify you of any such extension.
If you are not satisfied with our response to a data subject request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.
12. Minors & Age Policy
The 101ph22 platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 101ph22 does not knowingly collect personal data from individuals under the age of 21.
As part of our registration and KYC process, all players are required to verify their age before accessing real-money gaming features. If 101ph22 discovers that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, delete the personal data in question, and void any transactions or winnings associated with that account.
13. International Data Transfers
101ph22 primarily stores and processes player data within the Philippines. In certain circumstances, your personal data may be transferred to, stored in, or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or KYC verification platforms that operate internationally.
Where such international transfers occur, 101ph22 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual clauses approved by the National Privacy Commission, binding corporate rules, or transfers to countries recognized as providing an adequate level of data protection.
By using the 101ph22 platform and consenting to this Privacy Policy, you acknowledge and agree to the transfer of your personal data as described in this section, subject to the safeguards outlined above.
14. Changes to This Privacy Policy
101ph22 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered players via email or an in-platform notification.
We encourage you to review this Privacy Policy periodically to stay informed about how 101ph22 protects your personal data. Your continued use of the 101ph22 platform after any amendments have been posted constitutes your acknowledgment of the revised Policy.
The most current version of this Privacy Policy will always be available at 101ph22.app/privacy-policy. If you do not agree with any changes to this Policy, you should stop using the platform and may request account closure by contacting our support team.
15. Contact & Data Protection Officer
If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 101ph22, please contact our Data Protection Officer (DPO):
When submitting a data subject request, please include your registered account username, a clear description of your request, and a copy of a valid government-issued ID to allow us to verify your identity before processing your request. This verification step is required to protect your data from unauthorized access requests.
If you are not satisfied with our response, you may escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing the Data Privacy Act of 2012.