Privacy Policy

1. Introduction

21phlove ("we," "us," "our," or "the Company") operates the online gaming platform accessible at https://21phlove.club (the "Platform"). We are committed to protecting the personal information of all users, particularly those based in the Philippines, in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations.

This Privacy Policy applies to all personal data collected through the Platform, including during account registration, gameplay, financial transactions, customer support interactions, and any other use of our services. By accessing or using 21phlove, 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 Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which form part of your agreement with 21phlove.

2. Personal Data We Collect

Depending on how you interact with the 21phlove Platform, we may collect the following categories of personal data:

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data unless specifically required for responsible gaming compliance purposes and with your explicit consent.

3. How We Collect Your Data

21phlove collects personal data through the following means:

• Direct interactions: Information you provide when registering an account, completing KYC (Know Your Customer) verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: As you navigate the Platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: We may receive data about you from payment processors (e.g., GCash, PayMaya), identity verification providers, fraud prevention services, and analytics partners, where permitted by applicable law.
• Publicly available sources: In limited circumstances, we may supplement your profile with information from publicly available databases for identity verification or fraud prevention purposes.

4. Purpose of Processing Your Data

21phlove processes your personal data for the following purposes:

• To create and manage your player account and verify your identity in compliance with KYC requirements.
• To process deposits, withdrawals, and other financial transactions securely.
• To provide, maintain, and improve the Platform and its features, including games, promotions, and customer support.
• To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct.
• To comply with legal and regulatory obligations, including those imposed by PAGCOR and the National Privacy Commission (NPC) of the Philippines.
• To enforce our Terms & Conditions and other applicable policies.
• To send you service-related communications, including account notifications, security alerts, and transaction confirmations.
• To send you marketing communications about promotions, bonuses, and new features, where you have provided consent or where we have a legitimate interest to do so.
• To conduct responsible gaming monitoring and apply player protection measures where necessary.
• To analyze usage patterns and improve the overall player experience on the Platform.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 21phlove processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) rules and PAGCOR licensing requirements.
• Legitimate interests: Processing for fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time.

6. Data Sharing and Disclosure

21phlove does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: GCash, PayMaya/Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to facilitate financial transactions.
• Identity verification providers: Third-party KYC and AML compliance services used to verify player identity and prevent fraud.
• Game software providers: Licensed game developers whose software is integrated into the Platform, who may receive anonymized gameplay data.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where required by law.
• IT and security service providers: Cloud hosting, cybersecurity, and analytics vendors who process data on our behalf under strict contractual obligations.
• Legal and professional advisors: Lawyers, auditors, and consultants where necessary for legal proceedings or compliance reviews.

Any third party receiving your data is required to handle it in accordance with applicable data protection laws and our data processing agreements.

7. Data Retention

21phlove retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AML regulations.
• Financial transaction records: Retained for a minimum of five (5) years as required by Philippine financial regulations.
• Gaming history: Retained for three (3) years from the date of each transaction.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter.

When personal data is no longer required, it is securely deleted or anonymized in accordance with our data disposal procedures.

8. Data Security

21phlove implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including financial information and passwords.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Two-factor authentication (2FA) options for player accounts.
• Incident response procedures for detecting and responding to data breaches in accordance with NPC notification requirements.

While we take all reasonable precautions, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorized access.

9. Cookies and Tracking Technologies

21phlove uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function, including session management and security. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login status to improve your experience.
• Analytics cookies: Help us understand how players use the Platform so we can improve its performance and content.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 21phlove:

• Right to be informed: You have the right to know what personal data we collect and how it is processed.
• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may 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.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: You have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days.

11. Minors and Age Restriction

The 21phlove Platform is strictly intended for persons who are 21 years of age or older. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that a minor has provided us with personal data or has registered an account, we will immediately suspend the account, delete the associated personal data, and forfeit any balances in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that your child has provided personal data to 21phlove, please contact us immediately at the details provided in Section 13.

12. Changes to This Privacy Policy

21phlove reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will update the "Last Updated" date at the top of this page. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

Your continued use of the 21phlove Platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated Policy, you must stop using the Platform and may request account closure by contacting our support team.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please reach out to our Data Protection Officer:

• Email: [email protected]
• Support Email: [email protected]
• Live Chat: Available 24/7 via the 21phlove Platform

For complaints regarding data privacy violations, you may also contact the National Privacy Commission of the Philippines directly through their official channels.