33ph Privacy Policy

1 Introduction

33ph ("we," "us," or "our") operates the online gaming platform accessible at 33ph.org (the "Platform"). We are committed to protecting the privacy and personal data of all users ("you," "Player," or "User") who access or use the Platform.

This Privacy Policy describes how 33ph collects, uses, stores, shares, and protects your personal data in connection with your use of the Platform. It also describes the rights you have in relation to your personal data and how you can exercise those rights.

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC"). By registering for a 33ph account or using the 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.

This Privacy Policy should be read together with the 33ph Terms & Conditions and the Responsible Gaming Policy, both of which are incorporated by reference.

2 Personal Data We Collect

33ph collects the following categories of personal data from users of the Platform:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (to verify you are 21 years of age or older);
• Nationality and country of residence;
• Registered mobile number and email address;
• Residential address.

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, driver's license, PhilSys National ID, SSS/GSIS card, PRC ID);
• Selfie or facial image submitted for identity verification purposes;
• Proof of address documents where required.

2.3 Financial and Transaction Data

• GCash or PayMaya account details (mobile number associated with the e-wallet);
• Philippine bank account details (bank name, account number) for bank transfer transactions;
• Deposit and withdrawal history;
• Transaction amounts, dates, and reference numbers.

2.4 Gaming Activity Data

• Game history, bet amounts, and outcomes;
• Session duration and frequency of play;
• Bonus and promotion usage;
• Responsible gaming tool settings (deposit limits, self-exclusion status).

2.5 Technical and Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Pages visited, features used, and time spent on the Platform;
• Cookie identifiers and session tokens.

2.6 Communications Data

• Records of communications with 33ph customer support;
• Feedback, complaints, and survey responses submitted to 33ph.

3 How We Collect Your Data

33ph collects personal data through the following means:

• Directly from you — when you register for a 33ph account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey;
• Automatically — through cookies, web beacons, and similar tracking technologies when you access and use the Platform;
• From third-party payment processors — GCash, PayMaya, and Philippine banks may share transaction confirmation data with 33ph to facilitate deposits and withdrawals;
• From identity verification service providers — 33ph may use third-party KYC service providers to assist with document verification and fraud detection;
• From regulatory and law enforcement authorities — where required by Philippine law or PAGCOR regulations.

4 How We Use Your Personal Data

33ph uses your personal data for the following purposes:

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 33ph processes your personal data on the following legal bases:

• Contractual necessity — processing is necessary to perform the contract between you and 33ph (i.e., to operate your account, process transactions, and provide gaming services);
• Legal obligation — processing is required to comply with applicable Philippine laws, including KYC/AML obligations under the Anti-Money Laundering Act (AMLA), PAGCOR licensing requirements, and the Data Privacy Act;
• Legitimate interests — processing is necessary for 33ph's legitimate interests in fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights;
• Consent — for marketing communications and certain non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Sharing Your Personal Data

33ph does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors — GCash, PayMaya, and Philippine banks, to facilitate deposits and withdrawals;
• KYC and identity verification providers — third-party service providers engaged to assist with document verification and fraud screening;
• IT and platform service providers — cloud hosting, data storage, and cybersecurity vendors who process data on our behalf under strict data processing agreements;
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where required by law or court order;
• Professional advisers — lawyers, auditors, and accountants, where necessary for legal or compliance purposes;
• Business successors — in the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to equivalent privacy protections.

All third parties with whom 33ph shares personal data are required to handle that data in accordance with the Philippine Data Privacy Act and are prohibited from using it for any purpose other than the one for which it was shared.

7 Data Retention

33ph retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Philippine law. The following general retention periods apply:

• Account and KYC data — retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AMLA and PAGCOR record-keeping requirements;
• Transaction and financial data — retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations;
• Gaming activity data — retained for the duration of your account and for up to three (3) years after account closure;
• Customer support communications — retained for up to three (3) years from the date of the communication;
• Technical and usage data — retained for up to twelve (12) months, after which it is anonymised or deleted.

When personal data is no longer required, 33ph will securely delete or anonymise it in accordance with industry best practices and NPC guidelines.

8 Data Security

33ph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 33ph Platform;
• Encryption of sensitive data at rest, including KYC documents and financial information;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication for internal systems that process personal data;
• Regular security audits, vulnerability assessments, and penetration testing;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While 33ph takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 33ph will notify you and the NPC in accordance with the requirements of the Data Privacy Act.

9 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 33ph:

To exercise any of these rights, please contact the 33ph Data Privacy Officer using the contact details provided in Section 14 of this Policy. 33ph will respond to your request within fifteen (15) business days, as required by the Data Privacy Act.

10 Cookies and Tracking Technologies

33ph uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. We use the following types of cookies:

• Strictly necessary cookies — essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies — remember your preferences (e.g., language settings) to improve your experience on the Platform.
• Analytics cookies — collect anonymised data about how users interact with the Platform to help us understand usage patterns and improve our services.
• Marketing cookies — used to deliver relevant promotional content to you based on your interests, where you have provided consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the service.

11 Minors and Age Restriction

The 33ph Platform is strictly intended for persons who are 21 years of age or older, in accordance with Philippine law governing casino-style gambling. 33ph does not knowingly collect personal data from individuals under the age of 21.

If 33ph becomes aware that it has inadvertently collected personal data from a person under 21 years of age, it 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 33ph support immediately.

12 Cross-Border Data Transfers

In some cases, 33ph may transfer your personal data to service providers or partners located outside the Philippines — for example, cloud infrastructure providers or KYC technology vendors. Where such transfers occur, 33ph ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under the Philippine Data Privacy Act;
• Transfers only to countries or organisations that the NPC has determined provide an adequate level of data protection;
• Your explicit consent, where required by applicable law.

33ph will not transfer your personal data internationally in a manner that undermines the protections afforded to you under Philippine law.

13 Changes to This Privacy Policy

33ph 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, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered users via email or in-platform notification.

We encourage you to review this Privacy Policy periodically to stay informed about how 33ph protects your personal data. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

14 Contact Us and Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 33ph, please contact our Data Privacy Officer:

• Email: [email protected]
• Mailing Address: 33ph Data Privacy Officer, Philippines

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint is available on the NPC's official website.

33ph is committed to resolving all data privacy concerns promptly and in accordance with the requirements of the Data Privacy Act of 2012.