22ph does not sell, rent, or trade your personal data to any third party for their own marketing purposes. Your data may be shared with the following categories of recipients, strictly as necessary:
7.1 Service Providers
22ph engages trusted third-party service providers to assist in operating the Platform. These include payment processors (GCash, PayMaya, BDO, BPI, Metrobank), identity verification providers, cloud hosting and infrastructure providers, customer support platform providers, and fraud detection services. All service providers are contractually bound to process your data only on 22ph's instructions and in accordance with applicable data protection law.
7.2 Regulatory and Law Enforcement Authorities
22ph may disclose your personal data to PAGCOR, the AMLC, the National Privacy Commission, the Bureau of Internal Revenue (BIR), or other competent Philippine government authorities where required by law, court order, or regulatory directive. 22ph will notify you of such disclosures where legally permitted to do so.
7.3 Game and Software Providers
Certain games on the 22ph platform are provided by third-party game studios and software suppliers. These providers may receive limited technical data (such as session tokens and game result data) necessary to deliver their games. They do not receive your full personal profile.
7.4 Business Transfers
In the event of a merger, acquisition, restructuring, or sale of all or part of 22ph's business, your personal data may be transferred to the relevant successor entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.
No Cross-Border Transfers Without Safeguards: Where personal data is transferred outside the Philippines, 22ph ensures that appropriate safeguards are in place — including contractual data protection clauses — to maintain a standard of protection equivalent to that required under RA 10173.