23vipph Privacy Policy

This Privacy Policy ("Policy") is issued by 23vipph ("Company," "we," "us," or "our") and governs the collection, use, storage, sharing, and protection of personal data belonging to players, registered users, and visitors ("you" or "your") who access or use the website at https://23vipph.net and all associated services, games, promotions, and features (collectively, the "Service").

23vipph operates within the Republic of the Philippines and is subject to Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations as administered by the National Privacy Commission ("NPC"). This Policy is designed to meet the transparency and accountability requirements imposed on personal information controllers under the DPA.

This Policy should be read alongside the 23vipph Terms and Conditions, which govern your use of the Service more broadly. In the event of a conflict between this Policy and the Terms and Conditions on a data privacy matter, this Policy prevails.

23vipph collects personal data that you provide directly to us, data generated automatically through your use of the Service, and data received from trusted third parties where necessary. The specific categories of data we collect include the following:

We do not collect sensitive personal information as defined under Section 3(l) of the DPA (such as racial origin, political affiliations, health data, or sexual life) unless you voluntarily disclose such information in a support communication, in which case it is handled with the highest level of discretion and is not used for any purpose beyond resolving your specific query.

23vipph processes your personal data only for lawful, specified, and legitimate purposes. The following table summarizes the primary purposes for which we use your data and the corresponding legal basis under the Data Privacy Act of 2012:

You may opt out of marketing communications at any time by updating your notification preferences in your account dashboard or by contacting support at [email protected]. Opting out of marketing does not affect our ability to send you essential service-related communications such as account security alerts, withdrawal confirmations, and KYC requests.

Under the Data Privacy Act of 2012, 23vipph processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract we have with you when you register for and use the 23vipph Service — including account management, game access, and transaction processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests: Processing necessary for the legitimate interests of 23vipph — such as fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided those interests are not overridden by your rights and freedoms as a data subject.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for optional marketing communications. You may withdraw consent for consent-based processing at any time without affecting the lawfulness of prior processing.

23vipph uses cookies and similar tracking technologies to operate the platform, maintain session security, analyze usage patterns, and deliver a personalized experience to Filipino players. By continuing to use the 23vipph website, you consent to the use of cookies in accordance with this section.

Types of Cookies We Use:

• Strictly Necessary Cookies: These cookies are essential for the platform to function. They maintain your login session, remember your language preferences, and ensure secure navigation. These cookies cannot be disabled without affecting core platform functionality.
• Performance Cookies: These cookies collect anonymized data about how players use the 23vipph platform — such as which games are most visited and how long sessions last. This information is used solely to improve the Service.
• Functional Cookies: These cookies remember your preferences — such as your preferred payment method display and responsible gaming settings — so you do not have to reconfigure them on each visit.
• Analytics Cookies: We use first-party analytics tools to understand aggregate traffic patterns and user behavior on the 23vipph platform. This data is anonymized and is not linked to your personal account.

You can manage or delete cookies through your browser settings at any time. Note that disabling strictly necessary cookies may prevent you from accessing certain features of the 23vipph platform, including secure login.

23vipph does not sell your personal data. We share your data only with the categories of recipients listed below, and only to the extent necessary for each stated purpose:

• Payment Processors: GCash (G-Xchange, Inc.), PayMaya (PayMongo), and partner banks (BPI, BDO, Metrobank) receive transaction-specific data necessary to process your deposits and withdrawals. Each processor is bound by their own privacy policies and applicable Bangko Sentral ng Pilipinas ("BSP") regulations.
• Identity Verification Providers: Third-party KYC and AML verification services may receive copies of your government-issued ID and supporting documents for identity verification purposes. These providers operate under strict data processing agreements with 23vipph.
• Game Providers: Game studios and aggregators (such as Pragmatic Play, PG Soft, and others) may receive a session token and limited technical identifiers necessary to load and operate their games within the 23vipph platform. They do not receive your full identity or financial data.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission ("NPC"), and other Philippine government bodies may receive data where we are legally required to report or disclose it.
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by 23vipph may access relevant personal data in the course of providing professional services, subject to professional secrecy obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same data protection obligations described in this Policy.

23vipph retains your personal data for as long as is necessary to fulfill the purposes described in this Policy, subject to the following retention guidelines:

• Active Account Data: Personal data associated with your active 23vipph account is retained for the duration of the account relationship and for a period of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Transaction Records: Financial transaction records — including deposit and withdrawal history — are retained for a minimum of five (5) years from the date of each transaction in accordance with AMLA obligations.
• KYC Documents: Identity verification documents are retained for five (5) years following the end of the customer relationship, as required under the Revised Implementing Rules and Regulations of the AMLA.
• Support Communications: Customer support records, including chat logs and email correspondence, are retained for three (3) years from the date of the last interaction to support dispute resolution and regulatory review.
• Marketing Data: Where you have consented to receive marketing communications, your contact preferences are retained until you withdraw consent or close your account.

When personal data is no longer required for its stated purpose and no legal obligation requires its further retention, 23vipph will securely delete or anonymize the data in accordance with established data disposal procedures.

As a data subject under Republic Act No. 10173, the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 23vipph. These rights are exercisable free of charge by contacting our Data Protection Officer at the details provided in Section 13.

To exercise any of your rights, submit a written request to our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." We will acknowledge your request within five (5) business days and respond in full within fifteen (15) business days, extendable by a further fifteen (15) days in complex cases with prior notification to you.

For complaints to the National Privacy Commission, players in the Philippines may visit the NPC's official website or submit a complaint through the NPC's formal complaints process.

23vipph implements a comprehensive set of technical, organizational, and physical security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Key security measures include:

• SSL/TLS Encryption: All data in transit between your device and the 23vipph platform is encrypted using Transport Layer Security (TLS 1.2 or higher).
• Data-at-Rest Encryption: Sensitive stored data — including KYC documents, payment references, and session tokens — is encrypted using AES-256 or equivalent standards.
• Access Controls: Access to personal data within 23vipph's systems is restricted on a strict need-to-know basis. Staff access is governed by role-based access controls and subject to confidentiality obligations.
• Two-Factor Authentication: 2FA is available for all player accounts and is strongly recommended. Internal administrative access to player data systems requires multi-factor authentication.
• Penetration Testing: 23vipph's platform undergoes regular security assessments, including penetration testing, to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the event of a personal data breach that poses a risk to data subjects, 23vipph will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with NPC Circular 16-03.

The 23vipph platform is strictly intended for use by individuals who are twenty-one (21) years of age or older, in accordance with PAGCOR regulations and Philippine law governing online gambling. 23vipph does not knowingly collect, process, or retain personal data from individuals below the age of 21.

During the registration process, players are required to confirm their age and submit a government-issued photo ID demonstrating that they meet the 21+ age requirement as part of KYC verification. Any account found to belong to an individual under 21 will be immediately suspended, all associated balances will be frozen, and the data will be handled in accordance with applicable legal requirements.

If you believe that a person under the age of 21 has registered for or is using a 23vipph account, please notify us immediately at [email protected] so that we can take prompt action.

In the normal course of operating the 23vipph platform, certain personal data may be processed by or transferred to service providers — such as game technology providers and cloud infrastructure partners — whose systems may be located outside the Republic of the Philippines.

When such transfers occur, 23vipph ensures that your personal data receives adequate protection by implementing one or more of the following safeguards:

• Binding contractual clauses in data processing agreements that impose data protection obligations on the recipient consistent with the standards of the Philippine Data Privacy Act of 2012.
• Transfers to recipients in countries, territories, or organizations that have been assessed by the National Privacy Commission as providing an adequate level of data protection.
• Where required, obtaining your explicit consent to the transfer after informing you of the possible risks associated with transfers to jurisdictions that may not have equivalent data protection frameworks.

23vipph's primary player account data and KYC records are maintained within Philippine-jurisdiction infrastructure to the maximum extent practicable, and cross-border transfers are limited to what is strictly necessary to deliver the gaming services you have requested.

23vipph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. The effective date at the top of this page will be updated whenever the Policy is revised.

For material changes — those that significantly affect your rights or how we use your personal data — 23vipph will provide prior notice via email to your registered address and/or a prominent notification on the 23vipph platform homepage, at least seven (7) calendar days before the changes take effect.

For non-material changes — such as corrections of typographical errors, clarifications of existing language, or minor formatting updates — the Policy may be updated without specific prior notice, although the effective date will always be updated to reflect the revision.

Your continued use of the 23vipph platform after the effective date of any amendment to this Policy constitutes your acknowledgment of and agreement to the revised Policy. If you do not agree to the revised Policy, you must stop using the Service and may request account closure in accordance with the Terms and Conditions.

23vipph has appointed a Data Protection Officer ("DPO") in accordance with Section 21 of the Data Privacy Act of 2012 and its Implementing Rules and Regulations. The DPO is responsible for ensuring 23vipph's ongoing compliance with the DPA and serves as the primary point of contact for data subject rights requests, privacy inquiries, and complaints.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have concerns about how 23vipph handles your personal data, please contact our Data Protection Officer using the details below:

If you are not satisfied with our response or believe that 23vipph has violated your rights under the Data Privacy Act of 2012, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory authority responsible for enforcing the DPA and protecting the privacy rights of Filipino data subjects.

For general inquiries about the 23vipph platform, responsible gaming tools, account management, or technical support, our 24/7 Filipino-speaking customer support team is available at [email protected]. Whether you are based in Manila, Cebu, Davao, Quezon City, Makati, or anywhere else in the Philippines, we are here to help.