27phfun Privacy Policy

1 Introduction

Welcome to the 27phfun Privacy Policy. 27phfun ("we," "us," or "our") operates the online gaming platform accessible at https://27phfun.org (the "Platform"). We are committed to safeguarding the privacy and personal data of every individual who interacts with the 27phfun Platform, whether as a registered player, a visitor, or in any other capacity.

This Privacy Policy has been prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. It sets out the types of personal data we collect, the purposes for which we process that data, the parties with whom we may share it, and the rights you have in relation to your personal data.

This Privacy Policy applies to all personal data collected through the 27phfun Platform, including data collected via our website, mobile platform, customer support channels, and any other means by which you interact with 27phfun. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2 Personal Data We Collect

27phfun collects the following categories of personal data:

We do not collect sensitive personal information (as defined under the Data Privacy Act) unless it is strictly necessary for compliance with legal obligations, such as anti-money laundering regulations, and only with your explicit consent where required.

3 How We Collect Your Data

27phfun collects personal data through the following means:

• Direct interactions: Data you provide when registering your 27phfun account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. See Section 7 for more details on our cookie practices.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment data from GCash, Maya, and banking partners in connection with your transactions.
• Publicly available sources: Information from public records or databases where permitted by applicable law for the purpose of verifying your identity or conducting AML checks.

4 How We Use Your Personal Data

27phfun processes your personal data for the following purposes:

• Account management: To create, maintain, and administer your 27phfun account, including verifying your identity and age (21+ requirement) and managing your account settings.
• Service delivery: To provide you with access to games, process your bets, credit winnings to your account, and deliver the full range of 27phfun Platform features.
• Payment processing: To process deposits and withdrawals via GCash, Maya, and bank transfer, and to maintain accurate financial records.
• Legal and regulatory compliance: To comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws, including KYC verification and suspicious transaction reporting.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing and promotions: To send you relevant promotional offers, bonus notifications, and platform updates, subject to your marketing preferences and applicable consent requirements.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the 27phfun Platform.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, 27phfun processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., to provide the 27phfun Platform services, process payments, and manage your account.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AMLA obligations, and NPC directives.
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and the use of non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

27phfun 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 data protection safeguards:

• KYC and identity verification providers: Third-party service providers that assist us in verifying your identity and age in compliance with regulatory requirements.
• Payment processors: GCash, Maya, and banking partners involved in processing your deposits and withdrawals.
• AML and fraud screening providers: Compliance technology providers that assist us in detecting and preventing money laundering and fraudulent activity.
• IT and platform service providers: Cloud hosting, data storage, and technology infrastructure providers that support the operation of the 27phfun Platform.
• Customer support providers: Third-party customer support platforms used to manage live chat and support ticket systems.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities, where disclosure is required by law or regulatory directive.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other legal process.

All third-party service providers engaged by 27phfun are contractually required to process personal data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable data protection laws.

7 Cookies & Tracking Technologies

27phfun uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session, and collect usage analytics. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, authentication, and security. These cookies cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and responsible gaming tool configurations, to provide a personalized experience.
• Analytics cookies: Collect anonymized data about how users interact with the Platform to help us improve performance and user experience. Used with your consent.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. Used with your consent.

8 Data Retention

27phfun 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. Our standard retention periods are as follows:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AMLA record-keeping requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA and PAGCOR requirements.
• Customer support communications: Retained for two (2) years from the date of the interaction, or longer if required for ongoing dispute resolution.
• Marketing data: Retained until you withdraw your consent to receive marketing communications or request deletion, subject to any overriding legal retention obligations.
• Technical and usage logs: Retained for up to twelve (12) months for security and fraud prevention purposes.

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

9 Data Security

27phfun implements a comprehensive set of 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 the 27phfun Platform;
• Encryption of sensitive data at rest, including financial data and government ID information;
• Multi-factor authentication options for player accounts;
• 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;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While 27phfun takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that affects your rights and freedoms, 27phfun will notify the National Privacy Commission and affected individuals in accordance with the timelines prescribed under the Data Privacy Act and NPC Circular No. 16-03.

10 Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 27phfun:

• Right to be informed: The right to be notified of how your personal data is collected, processed, and used — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data 27phfun holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data we hold about you.
• Right to erasure or blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, or where processing is unlawful, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

11 Children's Privacy

The 27phfun Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with Philippine gambling regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the 27phfun Platform, please contact us immediately at the details provided in Section 15.

12 International Data Transfers

Some of 27phfun's third-party service providers — including cloud infrastructure, KYC verification, and analytics providers — may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that afforded under Philippine law, 27phfun ensures that appropriate safeguards are in place, including:

• Standard contractual clauses approved by the National Privacy Commission;
• Binding corporate rules where applicable;
• Transfers to countries recognized by the NPC as providing adequate data protection.

By using the 27phfun Platform, you consent to the transfer of your personal data to third-party service providers outside the Philippines, subject to the safeguards described above.

13 Third-Party Links

The 27phfun Platform may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to the 27phfun Platform and does not cover the privacy practices of any third-party websites. 27phfun is not responsible for the content, privacy policies, or data practices of any third-party sites. We encourage you to review the privacy policy of any third-party site you visit.

14 Updates to This Privacy Policy

27phfun 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. When material changes are made, we will notify registered players by email or via an in-platform notification at least seven (7) days before the changes take effect, where practicable.

The date of the most recent revision is displayed at the top of this page. Your continued use of the 27phfun Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the updated Privacy Policy, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.

15 Contact & Data Protection Officer

27phfun has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our DPO:

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 been violated. The NPC can be reached through its official website at privacy.gov.ph.