Your privacy matters to us. This Privacy Policy explains exactly what personal data 22two collects, why we collect it, how we use it, and the rights you have as a player based in the Philippines.
This Privacy Policy ("Policy") describes how 22two ("22two," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the 22two online gaming platform available at 22two.app and any associated mobile or web applications (collectively, the "Platform").
This Policy applies to all personal data processed in connection with your registration, use of games and services, financial transactions, customer support interactions, and any other activity conducted through the 22two Platform. It covers data collected from players located in the Philippines, including those accessing the Platform from Metro Manila, Cebu, Davao, Quezon City, Makati, and all other regions across the country.
By registering an account or continuing to use the 22two 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 any part of this Policy, please discontinue use of the Platform and contact us to close your account.
This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. In the event of any conflict between this Policy and those documents on matters of data privacy, this Policy shall prevail.
Back to topFor the purposes of applicable data protection legislation, 22two acts as the data controller in respect of the personal data it collects and processes through the Platform. As data controller, 22two determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.
22two is committed to complying with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations, as well as any other applicable data protection laws and regulations that govern the handling of personal information of Filipino data subjects.
If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact our designated Data Protection Officer using the contact details provided in Section 15 of this Policy.
Back to top22two collects several categories of personal data in connection with your use of the Platform. The specific data collected depends on how you interact with us and the services you use. The main categories are set out in the table below.
| Category | Examples of Data Collected |
|---|---|
| Identity Data | Full name, date of birth, gender, government-issued ID number, nationality |
| Contact Data | Email address, mobile number, residential address (city, province, region) |
| Account Data | Username, encrypted password, account preferences, communication settings |
| Financial Data | GCash account reference, PayMaya reference, BPI/BDO/Metrobank account name, transaction history, deposit and withdrawal records |
| Gaming Data | Game history, wager amounts, win/loss records, session duration, bonus usage |
| Technical Data | IP address, device type, browser type and version, operating system, time zone, screen resolution |
| Usage Data | Pages visited, features used, click patterns, session timestamps, referral source |
| Communications Data | Support chat transcripts, email correspondence, feedback submissions |
| Verification Data | Copies of government-issued ID, selfie photographs submitted for KYC verification |
22two does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data unless specifically required by law or regulation (for example, in connection with responsible gaming assessments or self-exclusion requests).
Back to top22two collects personal data through a variety of means, depending on the nature of your interaction with the Platform:
22two only collects personal data that is necessary for the purposes described in this Policy. We do not collect data speculatively or beyond what is required to deliver our services and meet our legal obligations.
22two processes your personal data for the following purposes:
22two processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012 and applicable regulations:
22two does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate safeguards:
All third parties with whom 22two shares personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.
22two retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
The following general retention periods apply:
When personal data is no longer required, 22two will securely delete or anonymise it in accordance with our data disposal procedures.
Back to top22two takes the security of your personal data seriously and implements a range of technical and organisational measures designed to protect your data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:
While 22two employs robust security measures, no system is completely immune to security risks. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect any unauthorised access to your account.
22two uses cookies and similar tracking technologies to operate the Platform, improve your experience, and analyse how the Platform is used. A cookie is a small text file placed on your device when you visit the Platform. The following categories of cookies are used:
You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. 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 service delivery.
Back to topUnder the Data Privacy Act of 2012 and its implementing rules, you have the following rights in relation to your personal data held by 22two:
To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. We will respond to your request within thirty (30) days. In some cases, we may need to verify your identity before processing your request.
Back to topThe 22two Platform is strictly intended for adults aged 21 years and above. 22two does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the registration process and is enforced through our KYC procedures.
If 22two becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any deposits made by an underage player will be returned, and any winnings accrued will be voided.
If you are a parent or guardian and believe that your child under the age of 21 has registered an account on the 22two Platform, please contact us immediately at the details provided in Section 15 so that we can take appropriate action.
In the course of operating the Platform, your personal data may be transferred to and processed in countries outside the Philippines, including countries where 22two's technology infrastructure providers and service partners are located. Such transfers may occur where the recipient country does not have data protection laws equivalent to those in the Philippines.
Where personal data is transferred outside the Philippines, 22two ensures that appropriate safeguards are in place to protect your data, including:
By using the 22two Platform, you acknowledge and consent to the transfer of your personal data outside the Philippines in accordance with the safeguards described in this section.
Back to top22two reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or Platform features. When material changes are made, we will notify you by posting a prominent notice on the Platform or by sending a notification to the email address associated with your account.
The updated Policy will take effect on the date indicated at the top of the document. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to stay informed about how 22two protects your personal data.
Where changes to this Policy require your fresh consent (for example, where we intend to process your data for a new purpose not previously disclosed), we will seek that consent before the new processing begins.
Back to topIf you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 22two, please contact our Data Protection Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.
You may reach our Data Protection Officer by email at: [email protected]
For general support inquiries unrelated to data privacy, you may contact our customer support team at: [email protected]
Our support team is available 24 hours a day, 7 days a week. Please include your registered account username and a clear description of your query in all correspondence to help us assist you efficiently.
If you are not satisfied with our response to your privacy inquiry, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.
Your Privacy at a Glance
A plain-language summary of the key privacy commitments 22two makes to every Filipino player on the Platform. This summary does not replace the full Policy above.
Every data transmission between your device and the 22two Platform is protected by 256-bit SSL encryption. Your personal and financial information is never sent in plain text over the internet.
Only authorised 22two personnel with a legitimate need can access your personal data. All staff are bound by confidentiality obligations and undergo regular data protection training.
22two will never sell, rent, or trade your personal data to third parties for their own marketing purposes. Your data is used only to deliver and improve our services to you.
22two's data practices are aligned with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations.
You have the right to access, correct, delete, and port your personal data. You can also withdraw marketing consent and manage cookie preferences at any time through your account settings.
22two maintains a formal data breach response procedure. If a breach poses a risk to your rights, we will notify you and the National Privacy Commission promptly as required by law.
Your data is protected, your privacy is respected, and your gaming experience is backed by a platform built for Filipino players. Ready to get started?