25ph12 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 25ph12 ("25ph12," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the 25ph12 website, mobile platform, games, and related services (collectively, the "Platform").

This Policy applies to all personal data processed by 25ph12 in connection with the operation of the Platform, including data collected during account registration, identity verification (KYC), gameplay, financial transactions, customer support interactions, and marketing communications.

By registering an account on 25ph12 or otherwise 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. If you do not agree with this Policy, you must not use the 25ph12 Platform.

This Policy is to be read together with the 25ph12 Terms & Conditions, which govern your use of the Platform.

2. Data Controller Information

25ph12 acts as the data controller for personal data collected through the Platform. As data controller, 25ph12 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

25ph12 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO at the address provided in Section 13 of this Policy.

3. Personal Data We Collect

25ph12 collects the following categories of personal data in connection with the operation of the Platform:

We do not intentionally collect sensitive personal information as defined under the DPA (such as health data, political opinions, or religious beliefs) unless specifically required for responsible gaming assessments or legal compliance purposes, in which case your explicit consent will be obtained.

4. How We Collect Your Data

25ph12 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically through cookies, server logs, and similar technologies when you access and interact with the Platform.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment verification data from payment processors such as GCash and Maya.
• Regulatory sources: Information received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory authorities in connection with compliance obligations.

5. Purposes and Legal Basis for Processing

25ph12 processes your personal data for the following purposes, each supported by a lawful basis under the DPA:

• Account registration and management — To create and maintain your 25ph12 account, verify your identity, and provide access to the Platform. Legal basis: performance of a contract.
• Identity verification (KYC) — To verify that you meet the 21+ age requirement and to comply with PAGCOR licensing conditions. Legal basis: legal obligation.
• Payment processing — To process deposits, withdrawals, and related financial transactions. Legal basis: performance of a contract.
• Anti-money laundering (AML) compliance — To monitor transactions and report suspicious activity to the AMLC as required under RA 9160 (AMLA) and its amendments. Legal basis: legal obligation.
• Responsible gaming — To monitor gameplay patterns, enforce deposit limits and self-exclusion requests, and identify players who may be experiencing gambling-related harm. Legal basis: legitimate interest and legal obligation.
• Customer support — To respond to your inquiries, complaints, and support requests. Legal basis: performance of a contract and legitimate interest.
• Platform security and fraud prevention — To detect, investigate, and prevent fraudulent activity, cheating, and unauthorized access. Legal basis: legitimate interest and legal obligation.
• Marketing communications — To send you promotional offers, bonus notifications, and platform updates, where you have opted in to receive such communications. Legal basis: consent. You may withdraw consent at any time by updating your communication preferences in your account settings.
• Platform improvement — To analyze usage patterns and improve the functionality, performance, and user experience of the Platform. Legal basis: legitimate interest.

6. Disclosure of Personal Data

25ph12 does not sell, rent, or trade your personal data to third parties. 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:

• KYC and identity verification providers — Third-party services that assist in verifying your identity and age in compliance with PAGCOR requirements.
• Payment processors — GCash, Maya/PayMaya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing financial transactions.
• IT and platform service providers — Cloud hosting, cybersecurity, and technical support providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities — PAGCOR, the AMLC, the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law, court order, or regulatory directive.
• Professional advisors — Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

Any third party that processes personal data on behalf of 25ph12 is required to do so only in accordance with our instructions and in compliance with the DPA. We do not transfer personal data outside the Philippines except where required by law or where adequate data protection safeguards are in place.

7. Cookies and Tracking Technologies

25ph12 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, maintain your session, and understand how you use the Platform.

We use the following types of cookies:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Performance cookies: Collect anonymized data about how players use the Platform (e.g., pages visited, error messages) to help us improve performance. No personally identifiable information is collected.
• Functional cookies: Remember your preferences such as language settings and display options to provide a more personalized experience.

25ph12 does not use third-party advertising cookies or behavioral tracking cookies that follow you across other websites. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair Platform functionality.

8. Data Retention

25ph12 retains your personal data for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable Philippine law and regulatory obligations. Specific retention periods include:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and AMLA obligations.
• Financial transaction records: Retained for a minimum of five (5) years as required under the AMLA and Bureau of Internal Revenue (BIR) regulations.
• Customer support records: Retained for three (3) years following the resolution of the relevant inquiry or complaint.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year for audit purposes.
• Technical and usage data: Retained for up to twelve (12) months, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

9. Data Security

25ph12 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 25ph12 Platform.
• Encryption of sensitive data at rest, including financial information and government ID details.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Multi-factor authentication (MFA) for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 25ph12 will notify the National Privacy Commission and affected players within the timeframes prescribed by the DPA and NPC Circular No. 16-03.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 25ph12:

• Right to be informed — To be notified of how your personal data is being collected and processed, as set out in this Policy.
• Right of access — To request a copy of the personal data 25ph12 holds about you, including information on how it is being used.
• Right to rectification — To request correction of any inaccurate, incomplete, or outdated personal data in your account.
• Right to erasure or blocking — To request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention requirements.
• Right to object — To object to the processing of your personal data for direct marketing, profiling, or any other purpose not strictly necessary for the performance of our contract with you.
• Right to data portability — To receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to damages — To claim compensation for any damages sustained as a result of inaccurate, incomplete, or unauthorized processing of your personal data.
• Right to file a complaint — To lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer as described in Section 13. We will respond to all verified requests within thirty (30) days, or within the timeframe prescribed by the NPC for complex requests.

11. Children and Minors

The 25ph12 Platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect personal data from persons under 21 years of age. If we become aware that personal data has been collected from a minor, we will immediately close the associated account, delete the data, and return any deposits to the original payment method where technically feasible.

If you are a parent or guardian and believe that a minor has registered on the 25ph12 Platform, please contact us immediately at [email protected] so that we can take prompt action.

12. Changes to This Privacy Policy

25ph12 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. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the 25ph12 Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

13. Contact and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 25ph12, please contact our Data Protection Officer:

• Email: [email protected]
• Role: Data Protection Officer, 25ph12
• Response Time: Within 30 days of receipt of a verified request
• Languages: English and Filipino

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been adequately addressed by 25ph12.