Privacy Policy – How 21phdream Protects Your Personal Data

1 About This Policy

This Privacy Policy describes how 21phdream ("the Company," "we," "us") collects, uses, stores, and protects the personal information of players and visitors who access the 21phdream website at https://21phdream.click.

By registering an account, depositing funds, or otherwise using the 21phdream platform, you acknowledge that you have read this Privacy Policy and understand how your personal data will be handled. If you do not agree with this policy, you should not use the platform.

This policy should be read alongside our Terms and Conditions and our Responsible Gaming policy, both of which are linked from the footer of every page on 21phdream.

2 Who We Are

21phdream is an online betting and gaming platform licensed to operate in the Philippines. For the purposes of the Philippine Data Privacy Act of 2012, 21phdream acts as the Personal Information Controller in relation to the personal data it processes about its players and site visitors.

Our designated Data Protection Officer (DPO) can be reached at privacy@21phdream.click for any privacy-related enquiries, data access requests, or complaints.

3 Personal Data We Collect

21phdream collects personal information through several channels — when you register, when you use the platform, and automatically through cookies and similar tracking technologies. The types of data we collect are outlined below.

3.1 Information You Provide Directly

3.2 Information Collected Automatically

When you access 21phdream, we automatically collect certain technical information including: your IP address, device type and operating system, browser type and version, pages visited and time spent on each page, referring URL, and session duration. This data is used for platform security, fraud detection, and improving the user experience.

3.3 Information from Third Parties

We may receive supplementary identity verification information from licensed Know Your Customer (KYC) service providers and anti-money laundering (AML) screening services. This is done to comply with our regulatory obligations and to protect the integrity of the 21phdream platform.

4 How We Use Your Personal Data

21phdream uses personal data for specific, legitimate purposes. We do not use your data in ways you wouldn't reasonably expect given how we've described our platform. Here are the purposes for which your data is used:

• Account management — creating, maintaining, and securing your 21phdream player account.
• Processing transactions — handling deposits, bets, withdrawals, and balance updates in Philippine Pesos across all supported payment methods including GCash, Maya, and bank transfers.
• Identity and age verification — confirming you meet the 21+ age requirement and that your identity matches the information provided at registration.
• Regulatory compliance — meeting our obligations under Philippine gaming laws, anti-money laundering regulations, and the Data Privacy Act of 2012.
• Fraud detection and platform security — identifying and preventing unauthorised account access, bonus abuse, and other forms of fraudulent activity.
• Customer support — responding to your queries, resolving disputes, and providing assistance related to bets, payments, and account issues.
• Platform improvement — analysing aggregated usage data to understand how players interact with 21phdream and to prioritise product improvements.
• Marketing communications — sending promotional offers, bonus notifications, and product updates to players who have opted in to receive them. You can opt out at any time.
• Responsible gaming monitoring — using account activity data to identify potential signs of problem gambling and to trigger appropriate support measures.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, every processing of personal information must have a lawful basis. 21phdream relies on the following legal grounds depending on the specific processing activity:

• Performance of a contract — processing that is necessary to fulfil the player agreement, such as creating and managing your account, processing deposits and withdrawals, and settling bets.
• Legal obligation — processing required to comply with applicable Philippine laws including AML regulations, tax reporting obligations, and gaming licence conditions.
• Legitimate interests — processing for fraud prevention, platform security, and internal analytics, where these interests are not overridden by your rights and freedoms.
• Consent — where we send you optional marketing communications or use non-essential cookies, we will obtain your explicit consent and provide a straightforward way to withdraw it at any time.

6 Sharing Your Personal Data

21phdream does not sell, rent, or trade your personal information to any third party for commercial gain. Your data is shared only in the following limited circumstances, and always under appropriate legal and contractual protections:

6.1 Service Providers

We work with trusted third-party service providers who process data on our behalf under written data processing agreements. These include payment processors (such as the providers behind GCash, Maya, GrabPay, and bank transfer systems), KYC and identity verification services, fraud detection and AML screening providers, cloud hosting and IT infrastructure providers, and customer support platforms. These providers are permitted to use your data only to perform their contracted services for 21phdream.

6.2 Regulatory and Legal Disclosures

We may disclose personal information to government authorities, law enforcement agencies, or regulatory bodies where we are legally required to do so — for example, in response to a lawful court order, a request from the Philippine Amusement and Gaming Corporation (PAGCOR), or as required under AML and counter-terrorism financing obligations.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 21phdream's business assets, personal data held by the Company may be transferred to the acquiring entity as part of that transaction. Where this occurs, players will be notified and the acquiring party will be required to continue honouring this Privacy Policy or notify affected players of any changes before they take effect.

6.4 With Your Consent

We may share your data with third parties for other purposes where you have given explicit consent. You have the right to withdraw such consent at any time by contacting privacy@21phdream.click.

7 Cookies and Tracking Technologies

21phdream uses cookies and similar technologies to make the platform work, improve your experience, and understand how players use the site. Here's how we categorise them:

7.1 Strictly Necessary Cookies

These are essential for the platform to function. They manage your logged-in session, maintain your bet slip, and ensure payment forms work correctly. You cannot opt out of these without losing core functionality.

7.2 Analytical Cookies

These help us understand how visitors interact with 21phdream — which pages are most visited, where players drop off, and how long sessions last on average. Data is aggregated and anonymised. We use this information solely to improve the platform.

7.3 Preference Cookies

These remember your settings — such as your preferred language or currency display — so you don't have to reset them each visit.

7.4 Marketing Cookies

Where you have consented, we may use marketing cookies to deliver promotions and offers relevant to your betting activity on 21phdream. These are optional and can be declined or withdrawn at any time through your browser settings or by contacting us.

8 Data Retention

21phdream retains your personal data only for as long as is necessary for the purposes described in this policy. In general, our retention periods are as follows:

• Active account data — retained for the duration of your account plus five years after permanent account closure, to meet regulatory and legal obligations.
• Transaction records — retained for a minimum of five years from the date of each transaction, as required by Philippine AML and tax regulations.
• KYC documents — retained for five years after your account is closed or your last transaction, whichever is later.
• Support communications — retained for two years from the date of the communication, to support dispute resolution.
• Marketing consent records — retained for three years from the date consent was last confirmed or updated.
• Technical logs (IP addresses, session data) — retained for 90 days for security monitoring purposes, unless longer retention is required in connection with a specific security investigation.

When personal data reaches the end of its retention period, it is securely deleted or anonymised so that it can no longer be linked back to you.

9 Data Security

21phdream takes the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your information against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• TLS (Transport Layer Security) encryption for all data transmitted between your device and the 21phdream platform.
• Encryption of sensitive data fields (such as ID document details and financial information) in our databases.
• Strict access controls — only authorised staff with a legitimate need can access player personal data.
• Regular security assessments and penetration testing of our platform infrastructure.
• Staff training on data handling, phishing awareness, and information security best practices.

Despite these measures, no online platform can guarantee absolute security. In the unlikely event of a data breach that poses a risk to your rights and freedoms, 21phdream will notify affected players and the National Privacy Commission of the Philippines within the timeframe required by law.

10 Your Data Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal information held by 21phdream. These rights are real and we make them practical to exercise — not just listed for legal formality.

To exercise any of the above rights, submit your request in writing to privacy@21phdream.click. Please include your full name, registered email address, and a description of your request. We will respond within 15 business days. Where we are unable to fulfil a request due to a legal obligation, we will explain the reason clearly.

11 Children's Privacy

21phdream is strictly for adults aged 21 and above. We do not knowingly collect or process personal information from individuals under the age of 21. If we become aware that a player is under 21, we will immediately suspend the account, void any associated bets, return any deposited funds to the source, and delete all personal data associated with the account.

If you are a parent or guardian and believe a minor has created an account on 21phdream, please contact us immediately at privacy@21phdream.click so we can take appropriate action.

12 Updates to This Privacy Policy

21phdream may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or the services we offer. When we make material changes, we will notify registered players via the email address associated with their account at least seven days before the updated policy takes effect.

The most current version of this policy is always available at https://21phdream.click/privacy-policy. The "Last Updated" date at the top of this page shows when the most recent revision was made. Continued use of 21phdream after the effective date of any changes constitutes acceptance of the updated policy.

13 Contact Us and How to Raise a Complaint

If you have any questions about this Privacy Policy, want to exercise your data rights, or wish to raise a concern about how 21phdream handles your personal information, please get in touch with our Data Protection Officer:

• Email: privacy@21phdream.click
• General support: support@21phdream.click
• Live Chat: Available 24/7 on the 21phdream website

We aim to respond to all data privacy enquiries within 15 business days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC), which is the supervisory authority responsible for enforcing the Data Privacy Act.