Privacy Policy — 104ph22

Introduction

104ph22 ("we," "us," "our," or "104ph22") is committed to protecting the privacy and personal data of all users ("you," "Player," or "User") of the 104ph22 online gaming platform. This Privacy Policy describes how 104ph22 collects, uses, stores, discloses, and otherwise processes personal data in connection with the Platform accessible at https://104ph22.net.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). It should be read alongside our Terms & Conditions and all other policies published on the Platform.

By registering an account or otherwise using the 104ph22 Platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree to the terms of this Privacy Policy, you must not access or use the Platform.

Data Controller

For purposes of the Data Privacy Act of 2012, 104ph22 is the personal information controller in respect of the personal data collected through the Platform. This means 104ph22 determines the purposes for which and the means by which your personal data is processed.

104ph22 has designated a Data Protection Officer (DPO) who is responsible for overseeing this Privacy Policy and ensuring compliance with the DPA and related regulations. Contact details for the DPO are provided in Section 15 of this Policy.

Personal Data We Collect

104ph22 collects the following categories of personal data from players and Platform users:

104ph22 does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data beyond what is strictly required for identity document verification under PAGCOR KYC rules.

How We Collect Your Data

104ph22 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, respond to a survey, or participate in a promotion.
• Automatically through the Platform — through cookies, web beacons, server logs, and similar tracking technologies when you access or use the Platform. This includes your IP address, device identifiers, browser type, pages visited, and session duration.
• From third-party service providers — including KYC verification vendors, payment processors (GCash, Maya, BPI, BDO, Metrobank, 7-Eleven, Coins.ph), fraud detection services, and game software providers, who may share data with 104ph22 as part of their services.
• From regulatory and law enforcement bodies — including PAGCOR and the Anti-Money Laundering Council (AMLC), where legally required for compliance purposes.

How We Use Your Personal Data

104ph22 uses the personal data it collects for the following purposes:

• Account creation and management — to register your account, verify your identity, and maintain your player profile on the 104ph22 Platform.
• KYC and age verification — to confirm that you meet the minimum age requirement of 21 years and to verify your identity as required by PAGCOR regulations and AML obligations.
• Transaction processing — to process deposits, wagers, withdrawals, and bonus credits accurately and in accordance with your instructions.
• Platform security and fraud prevention — to detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, collusion, and other prohibited conduct on the Platform.
• Regulatory compliance — to meet 104ph22's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws and regulations.
• Customer support — to respond to your inquiries, resolve disputes, process complaints, and provide technical assistance.
• Responsible gaming — to monitor gaming activity patterns, administer player-requested limits and self-exclusion arrangements, and fulfill responsible gaming obligations under PAGCOR's player protection framework.
• Personalization and analytics — to improve the Platform's features, game offerings, and user experience based on aggregated usage data and individual preferences where consent has been provided.
• Marketing communications — to send promotional offers, bonuses, and platform updates where you have provided explicit opt-in consent. You may withdraw this consent at any time.

104ph22 does not use personal data for automated decision-making that produces legal effects or significantly affects you, without a human review process being available upon request.

Legal Basis for Processing

Under the Data Privacy Act of 2012, 104ph22 relies on the following legal bases for processing your personal data:

• Contractual necessity — processing required to perform the contract between 104ph22 and you as a registered player, including account management, transaction processing, and game provision.
• Legal obligation — processing necessary to comply with applicable Philippine laws, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate interests — processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where these interests are not overridden by your privacy rights.
• Consent — processing for marketing communications and certain optional data uses where you have provided explicit, freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

Data Sharing and Disclosure

104ph22 does not sell, rent, or trade personal data with third parties for their own commercial purposes. Personal data is shared only in the following circumstances:

• Service providers and processors — 104ph22 shares personal data with third-party vendors who provide services including payment processing (GCash, Maya, BPI, BDO, Metrobank, Coins.ph), KYC verification, IT infrastructure, fraud detection, and customer support software. These parties are bound by data processing agreements and may only process data as instructed by 104ph22.
• Game software providers — certain game providers require player session data to deliver games on the Platform. Only the minimum necessary data (such as player ID, session token, and stake amount) is shared with game providers. Full personal data is not disclosed to game providers.
• Regulatory and law enforcement authorities — 104ph22 is required by law to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other Philippine government bodies upon lawful request or as part of ongoing regulatory reporting obligations.
• Professional advisers — lawyers, auditors, and accountants engaged by 104ph22 may access personal data to the extent necessary to provide their professional services, subject to confidentiality obligations.
• Corporate transactions — in the event of a merger, acquisition, restructuring, or sale of 104ph22's business or assets, personal data held by 104ph22 may be transferred to the acquiring entity, subject to the same data protection obligations as this Privacy Policy.

Cookies and Tracking Technologies

104ph22 uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session security, and gather analytics data. The types of cookies used include:

• Strictly necessary cookies — required for the Platform to function correctly. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without impairing Platform functionality.
• Functional cookies — used to remember your preferences such as language settings, game display preferences, and responsible gaming limit configurations.
• Analytics cookies — used to collect aggregated, anonymized data about how players use the Platform, including which games are most visited, session durations, and navigation paths. This data is used to improve Platform performance and user experience.
• Security cookies — used to detect fraudulent login attempts, unusual access patterns, and suspicious session behavior.

104ph22 does not use third-party advertising or cross-site tracking cookies. You may configure your browser to refuse certain cookies, though doing so may affect the functionality of the Platform. A cookie preference centre is available through your account settings.

Data Retention

104ph22 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by applicable Philippine law:

• Account and KYC data — retained for a minimum of 5 years following account closure, as required under PAGCOR KYC record-keeping requirements and the Anti-Money Laundering Act.
• Transaction records — retained for a minimum of 5 years following the date of each transaction, in compliance with AMLA and BIR requirements.
• Gaming activity records — retained for a minimum of 3 years following account closure for responsible gaming, dispute resolution, and regulatory audit purposes.
• Customer support communications — retained for 2 years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing preference records — retained for the duration of the account and for 1 year following account closure to maintain accurate opt-out records.

Following the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification. Where data is anonymized, the anonymized data may be retained indefinitely for statistical purposes.

Your Privacy Rights

Under the Data Privacy Act of 2012, as a Philippine data subject you have the following rights with respect to your personal data held by 104ph22:

To exercise any of the above rights, submit a written request to the 104ph22 Data Protection Officer at the contact details provided in Section 15. 104ph22 will respond to all data subject requests within 15 business days of receipt. In complex cases, this period may be extended by a further 30 days, with written notification to you of the extension and the reason for it.

Children and Minors

The 104ph22 Platform is strictly intended for individuals who are at least 21 years of age, in accordance with PAGCOR regulations governing online gaming in the Philippines. 104ph22 does not knowingly collect personal data from individuals under the age of 21.

Age verification is a mandatory component of the 104ph22 KYC process. Any account found to have been registered by or on behalf of a person under 21 years of age will be immediately closed, all associated balances will be forfeited, and the matter may be reported to PAGCOR.

If you are a parent or guardian and you believe your child or a minor in your care has registered an account or submitted personal data to 104ph22, please contact us immediately at the details provided in Section 15. We will investigate and take appropriate action promptly.

Security Measures

104ph22 implements a range of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS) — all data transmitted between your browser or device and the 104ph22 Platform is encrypted using industry-standard TLS protocols.
• Password hashing — account passwords are stored as salted cryptographic hashes and are never stored or transmitted in plaintext.
• Access controls — access to personal data within 104ph22's systems is restricted on a need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and receive regular data privacy training.
• KYC document encryption — identity documents submitted during KYC verification are stored in encrypted form with multi-factor access controls.
• Intrusion detection and monitoring — 104ph22 operates real-time security monitoring systems to detect and respond to unauthorized access attempts, DDoS attacks, and other security threats.
• Regular security assessments — 104ph22 conducts periodic security reviews and vulnerability assessments to identify and address security risks in the Platform.

While 104ph22 implements robust security measures, no online platform can guarantee absolute security. You are encouraged to use a strong, unique password for your 104ph22 account and to enable two-factor authentication where available.

Cross-Border Data Transfers

104ph22 primarily processes personal data within the Philippines. Where personal data is transferred to or accessed by service providers or game software providers located outside of the Philippines — for example, in connection with internationally operated game studios or cloud infrastructure providers — 104ph22 ensures that such transfers are conducted in accordance with the Data Privacy Act of 2012 and the NPC's rules on cross-border data transfers.

Safeguards applied to cross-border transfers include:

• Data processing agreements incorporating the NPC's standard contractual clauses for international data transfers where applicable.
• Restriction of transferred data to the minimum necessary for the receiving party to perform its specific service function.
• Due diligence assessment of receiving parties' data protection practices prior to engagement.

Changes to This Privacy Policy

104ph22 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, Platform features, or our data processing practices. When material changes are made, 104ph22 will:

• Post the revised Privacy Policy on the Platform with an updated "Last Updated" date.
• Notify registered account holders via the email address associated with their account at least 7 days before the effective date of material changes.
• Where changes require fresh consent (for example, a new processing purpose), request that consent separately through an in-platform notification before the new processing commences.

Your continued use of the 104ph22 Platform after the effective date of an updated Privacy Policy constitutes acceptance of the revised terms. If you do not agree with any changes, you should cease using the Platform and may request account closure by contacting our Data Protection Officer.

Contact the Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 104ph22, please contact our Data Protection Officer:

Data Protection Officer — 104ph22
Email: [email protected]
Subject line: Data Privacy Request

Our DPO and support team are available 24 hours a day, 7 days a week, Philippine Standard Time (PST / UTC+8). We aim to acknowledge all privacy-related communications within 24 hours and to resolve requests within 15 business days.

If you are unsatisfied with 104ph22's response to a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through the NPC's official complaint channels.