27phfun Privacy Policy

Introduction & Scope

This Privacy Policy applies to all personal information collected, processed, stored, or otherwise handled by 27phfun in connection with the operation of its online gaming platform at 27phfun.vip. It applies to all registered players, prospective registrants, visitors who browse the platform without registering, and any other person whose personal data is processed by 27phfun in connection with the services it provides.

27phfun operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the data protection obligations imposed by Republic Act No. 10173 (the Data Privacy Act of 2012), its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission (NPC). This policy reflects those obligations and explains how 27phfun fulfils them in practice.

This policy should be read together with the 27phfun Terms & Conditions, which govern your use of the platform generally, and the Responsible Gaming policy, which addresses data processing specific to player protection tools.

Data Controller Details

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, 27phfun acts as the personal information controller (PIC) in respect of all personal data collected from players and visitors through the 27phfun.vip platform. As PIC, 27phfun determines the purposes for which personal information is collected and the means by which it is processed.

27phfun has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act, handling data subject rights requests, and serving as the primary point of contact for privacy-related queries. Contact details for the DPO are set out in Section 14 of this policy.

Personal Data We Collect

27phfun collects personal information through several channels and at different stages of the player lifecycle. The categories of data collected are described below.

3.1 — Registration Data

When you create a 27phfun account, we collect the following information:

• Full legal name (as it appears on a government-issued Philippine ID);
• Date of birth (for age verification — players must be 21 or older);
• Residential address within the Philippines;
• Mobile number registered with a Philippine network carrier;
• Email address (if provided);
• Chosen username and encrypted password.

3.2 — Identity Verification (KYC) Data

To comply with PAGCOR licensing requirements and the Anti-Money Laundering Act (AMLA) of the Philippines, 27phfun conducts Know Your Customer (KYC) verification. KYC data may include:

• Government-issued Philippine identification document (e.g., PhilSys ID, Passport, Driver's License, Voter's ID, SSS/GSIS Card);
• Selfie photograph for facial verification;
• Proof of address (e.g., utility bill, bank statement dated within 3 months);
• Proof of payment method (e.g., GCash account confirmation).

3.3 — Financial Transaction Data

For each deposit and withdrawal, 27phfun records:

• Transaction amount in Philippine Peso (₱);
• Payment method used (e.g., GCash, Maya, BPI, BDO, Metrobank);
• Transaction reference number and timestamp;
• Account balance changes resulting from the transaction.

27phfun does not store full GCash or bank account numbers. Payment tokenization is handled by the respective payment service providers.

3.4 — Gaming Activity Data

27phfun automatically records the following in connection with your gaming activity:

• Games played, wager amounts, and game outcomes;
• Session duration, login times, and logout times;
• Bonus utilization and wagering history;
• Responsible gaming tool configurations (deposit limits, self-exclusion status).

3.5 — Technical & Device Data

When you access 27phfun, we automatically collect:

• IP address and approximate geolocation (region/city level);
• Device type, operating system, and browser type;
• Cookie identifiers and session tokens (see Section 7);
• Referring URL and on-site navigation path.

3.6 — Communications Data

When you contact 27phfun customer support — via live chat, email, or any other channel — we retain records of that communication, including the content of messages, timestamps, and the resolution outcome, for quality assurance and dispute resolution purposes.

Summary of Data Categories:

How We Use Your Personal Data

27phfun uses the personal information it collects for the following purposes:

• Account creation and management: Registering your account, maintaining your player profile, and enabling you to log in securely to 27phfun;
• Age and identity verification: Confirming that you are at least 21 years old as required by PAGCOR regulations, and verifying your identity for KYC compliance;
• Transaction processing: Processing deposits and withdrawals through GCash, Maya, and Philippine bank channels in Philippine Peso;
• Game provision: Enabling you to play Color Game, slots, live casino games, bingo, and other games available on 27phfun;
• Fraud prevention and security: Detecting, investigating, and preventing unauthorized account access, bonus abuse, money laundering, and other fraudulent or illegal activity;
• Regulatory compliance: Meeting obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act, and the Data Privacy Act of 2012;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior, facilitating use of responsible gaming tools, and enforcing self-exclusion requests;
• Customer support: Responding to enquiries, complaints, and disputes raised through 27phfun's support channels;
• Platform improvement: Analysing aggregated, anonymized usage data to improve platform performance, game selection, and user experience;
• Promotional communications: Sending you information about bonuses and promotions — only where you have not opted out of such communications, and only by the channels you have consented to.

Legal Basis for Processing

Under the Data Privacy Act of 2012, 27phfun processes personal information only where a lawful basis applies. The primary bases relied upon are:

• Contractual necessity: Processing required to perform the player agreement — including account registration, payment processing, and game delivery — is necessary to fulfil the contract between you and 27phfun;
• Legal obligation: Certain processing — including KYC, AML transaction monitoring, PAGCOR reporting, and age verification — is required by Philippine law or PAGCOR licensing conditions;
• Legitimate interests: Processing for fraud prevention, platform security, and aggregated analytics is carried out on the basis of 27phfun's legitimate interest in operating a secure and fair gaming platform, where such interests are not overridden by your privacy rights;
• Consent: Where 27phfun relies on consent as the processing basis (e.g., for optional marketing communications), you have the right to withdraw that consent at any time by contacting support or updating your account notification preferences.

Data Sharing & Third-Party Disclosure

27phfun does not sell, rent, or otherwise commercially transfer your personal data to third parties. Your information may be shared only in the following limited and controlled circumstances:

6.1 — Payment Service Providers

To process deposits and withdrawals, 27phfun shares necessary transaction data with licensed Philippine payment service providers, including GCash (GXchange Inc.), Maya (PayMaya Philippines Inc.), BPI, BDO, and Metrobank. These providers act as personal information processors bound by contractual data protection obligations.

6.2 — Game Technology Providers

Game studios and live casino platform providers (e.g., PG Soft, Jili Games, Pragmatic Play, Evolution Gaming) may receive limited gameplay data necessary to operate the specific game you are playing. Game providers receive session tokens and wager data, not your full personal profile.

6.3 — Regulatory Authorities

As a PAGCOR-licensed operator, 27phfun is required to maintain records of player activity and to report to PAGCOR and, where applicable, the Anti-Money Laundering Council (AMLC) in accordance with applicable law. Such disclosures are made only to the extent legally required and are not made speculatively.

6.4 — Law Enforcement

27phfun will disclose personal data to Philippine law enforcement agencies, courts, or other government bodies where required by a valid legal process, court order, or where 27phfun believes in good faith that disclosure is necessary to prevent a crime, protect the safety of individuals, or protect the legal rights of 27phfun.

6.5 — Business Transfers

In the event of a merger, acquisition, or sale of substantially all of 27phfun's assets, personal data held about players may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and of any resulting changes to data processing arrangements.

Cookies & Tracking Technologies

27phfun uses cookies and similar tracking technologies to operate the platform, maintain session states, detect fraud, and analyze platform performance. Cookies are small text files stored on your browser or device.

Types of Cookies Used by 27phfun

27phfun does not deploy third-party advertising cookies. You can manage cookie preferences through your browser settings. Note that disabling strictly necessary or fraud detection cookies may impair your ability to log in or use certain platform features.

Data Retention

27phfun retains personal data only for as long as it is necessary for the purpose for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The general retention schedule is as follows:

• Active account data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, as required by PAGCOR licensing and AMLA obligations;
• KYC and identity documents: Retained for a minimum of five (5) years from the date of the last transaction, in accordance with AMLA requirements;
• Financial transaction records: Retained for ten (10) years from the transaction date in accordance with Philippine accounting and anti-money laundering law;
• Customer support records: Retained for three (3) years from the date the matter was resolved;
• Technical/log data: Retained for twelve (12) months, except where specific records are required for ongoing investigations;
• Marketing consent records: Retained until consent is withdrawn and for one (1) year thereafter as proof of lawful processing.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 27phfun's data disposal procedures. Anonymized data that cannot be re-linked to an individual is not subject to retention limits.

Data Security

27phfun implements technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, loss, and destruction. These measures include:

• Encryption in transit: All connections to 27phfun are secured with 256-bit SSL/TLS encryption, preventing interception of data during transmission;
• Encryption at rest: Sensitive personal data stored on 27phfun servers is encrypted using industry-standard encryption algorithms;
• Password security: Passwords are stored as salted cryptographic hashes — plain text passwords are never stored;
• Access controls: Access to personal data within 27phfun is limited to personnel with a legitimate operational need, governed by role-based access control and documented authorization;
• Two-factor verification: Critical account actions — including password resets and withdrawal requests — require OTP verification to the player's registered Philippine mobile number;
• Fraud monitoring: 27phfun's systems continuously monitor for anomalous access patterns, multi-account indicators, and suspicious transaction behavior;
• Penetration testing: 27phfun conducts regular security assessments of its platform infrastructure.

Your Data Subject Rights

Under the Data Privacy Act of 2012, registered players and other data subjects whose personal information is held by 27phfun have the following rights:

• Right to be Informed: The right to know what personal data 27phfun holds about you, for what purposes, and how long it will be retained — this Privacy Policy fulfils that obligation;
• 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 have inaccurate or incomplete personal data corrected — minor corrections (e.g., contact number updates) can be made through your account settings; more substantive corrections require a formal request;
• Right to Erasure ("Right to be Forgotten"): The right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to 27phfun's legal retention obligations under PAGCOR and AMLA regulations;
• Right to Object: The right to object to the processing of your personal data for marketing purposes at any time, and to processing based on legitimate interests where your privacy interests override them;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format where processing is based on consent or contract;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission if you believe 27phfun has violated your data privacy rights.

Children & Minors

If 27phfun discovers that personal data has been collected from a person under the age of 21, the associated account will be immediately closed, all data will be deleted (subject to any applicable legal retention obligations), and any funds in the account will be handled in accordance with the relevant PAGCOR regulatory requirements.

If you are a parent or guardian and believe that your child has created a 27phfun account, please contact us immediately at [email protected] and we will take prompt action.

Cross-Border Data Transfers

Some of 27phfun's service providers — including game studios headquartered outside the Philippines — may process personal data in jurisdictions other than the Philippines. In such cases, 27phfun takes steps to ensure that appropriate safeguards are in place before transferring personal data, including:

• Executing data processing agreements that impose obligations at least equivalent to those required by the Philippine Data Privacy Act;
• Restricting the categories of personal data transferred to those strictly necessary for the specific service being provided;
• Assessing the data protection laws of the recipient jurisdiction to ensure an adequate level of protection.

In all cases, cross-border transfers by 27phfun are conducted in accordance with NPC guidelines on cross-border transfers of personal data.

Amendments to This 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. Material amendments — meaning changes that substantially affect how your personal data is collected, used, or shared — will be communicated to registered players via the email address or mobile number on file at least seven (7) days before they take effect.

Non-material amendments (such as typographical corrections, clarifications that do not alter substantive obligations, or updates to formatting) may be made without advance notice. The "Last Updated" date displayed at the top of this policy reflects the date of the most recent revision.

Your continued use of 27phfun following the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. If you do not accept the revised policy, you should cease using the platform and contact support to close your account.

Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 27phfun, please contact our Data Protection Officer through the following channels:

• Email: [email protected] (subject line: "Privacy / DPO");
• Live Chat: Available on-site at 27phfun.vip, 24 hours a day, 7 days a week;
• Languages: English, Tagalog, Bisaya.

If you are not satisfied with 27phfun's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC is the government agency responsible for administering and enforcing the Data Privacy Act of 2012.