Privacy Policy

01 Introduction

This Privacy Policy explains how p2828 ("we," "us," or "our") collects, uses, shares, and protects your personal information when you visit our website at https://p2828.cam, register an account, deposit funds, play games, or interact with our customer support.

We are committed to protecting your privacy and handling your personal data transparently, in full compliance with the Philippine Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and applicable PAGCOR rules on player data management.

By using p2828, you consent to the practices described in this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of our services and close your account.

02 Information We Collect

We collect personal information in three main ways: information you provide directly, information collected automatically, and information from third-party sources.

2.1 Information You Provide Directly

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued ID numbers (for KYC verification);
• Contact Data: Email address, mobile phone number, and residential address;
• Financial Data: Bank account details, GCash/Maya mobile number, crypto wallet addresses, and payment history;
• Account Data: Username, password (encrypted), security questions, and account preferences;
• Communication Data: Chat transcripts, email correspondence, and feedback you send to our support team.

2.2 Information Collected Automatically

• Device Data: IP address, device type, operating system, browser version, and screen resolution;
• Usage Data: Pages visited, games played, time spent, click patterns, and interaction with features;
• Location Data: Approximate geographic location based on your IP address (to comply with PAGCOR jurisdictional restrictions);
• Cookies & Similar Technologies: Session data, preferences, and analytics identifiers (see Section 6 for details).

2.3 Information from Third Parties

• Payment Processors: Transaction confirmations from GCash, Maya, banks, and crypto networks;
• Identity Verification Services: Confirmation of government ID validity and match against public records;
• Fraud Prevention Providers: Risk scores and alerts regarding suspicious activity.

03 How We Use Your Information

We use your personal information for the following purposes, all of which are directly related to providing our services:

Purpose	Type of Data Used
Account creation & management	Identity, Contact, Account data
Processing deposits & withdrawals	Financial, Identity, Account data
KYC & anti-money laundering compliance	Identity, Financial, Communication data
Detecting & preventing fraud	Device, Usage, Financial, Communication data
Providing customer support	Contact, Communication, Account data
Personalizing game recommendations	Usage, Account data
Marketing & promotional offers	Contact, Usage data (with your consent)
Legal & regulatory compliance	All categories as required by law
Platform improvement & analytics	Device, Usage, Aggregated data

We do not use your information for automated decision-making that produces legal effects without human review. Any automated fraud detection triggers human verification before account actions are taken.

04 Legal Basis for Processing

Under the Philippine Data Privacy Act, we rely on the following legal bases for processing your personal data:

• Contractual Necessity: To perform our agreement with you — for example, processing deposits, running games, and paying out withdrawals;
• Legal Obligation: To comply with PAGCOR regulations, anti-money laundering (AML) laws, and tax reporting requirements;
• Legitimate Interest: To detect fraud, secure our platform, improve services, and prevent abuse;
• Consent: For sending marketing emails, SMS, or promotional notifications — you may withdraw this consent at any time.

05 How We Share Information

We never sell your personal information. We only share data with third parties in the following limited circumstances:

5.1 Service Providers

We share necessary data with trusted partners who help us operate the platform:

• Payment processors: GCash, Maya, GrabPay, banks, and crypto payment gateways;
• Identity verification services: To verify your documents during KYC;
• Fraud detection providers: To identify suspicious behavior and protect players;
• Cloud hosting providers: To store your data securely on encrypted servers;
• Customer support platforms: To facilitate live chat and email communication;
• Game providers: To load games and record gameplay results.

All service providers are bound by strict data processing agreements and may only use your data to perform the specific services we've requested.

5.2 Legal & Regulatory Disclosures

We may disclose your information when required by law, including:

• In response to a court order, subpoena, or formal legal request;
• To comply with PAGCOR regulations and AML reporting requirements;
• To report suspected fraud, money laundering, or criminal activity;
• To protect the rights, property, or safety of p2828, our players, or the public.

5.3 Business Transfers

If p2828 is acquired, merged, or sold, your personal data may be transferred to the acquiring entity. We will notify you via email and prominent website notice before any such transfer takes place, and the new entity will be bound by this Privacy Policy unless you are given the opportunity to opt out.

06 Cookies & Tracking Technologies

p2828 uses cookies and similar technologies to enhance your experience, keep you logged in, and analyze platform usage.

6.1 Types of Cookies We Use

• Essential Cookies: Required for basic functions like login sessions, deposit processing, and security. These cannot be disabled;
• Performance Cookies: Help us understand how players use the platform so we can improve speed and usability;
• Functionality Cookies: Remember your preferences, language, and game history;
• Marketing Cookies: Used to show relevant promotions based on your play patterns (only with your consent);
• Third-Party Cookies: Set by analytics providers and advertising partners for aggregated reporting.

6.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies — however, disabling essential cookies will prevent you from logging in and playing. For more information, consult your browser's help documentation.

07 Data Security

We take the security of your personal information very seriously. Our security measures include:

• 256-bit SSL Encryption: All data transmitted between your device and our servers is encrypted end-to-end;
• Encrypted Storage: Personal data is stored in encrypted databases with access limited to authorized personnel only;
• Two-Factor Authentication: Available on all accounts for an additional layer of protection;
• Firewall & Intrusion Detection: Advanced network security monitors and blocks unauthorized access attempts;
• Regular Security Audits: Independent third-party audits test our systems against the latest threats;
• Employee Training: All staff undergo regular privacy and security training;
• Access Controls: Employees can only access the minimum data needed to perform their jobs.

08 Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy, and to comply with legal and regulatory requirements.

Data Type	Retention Period
Account information (name, email, contact)	Active account + 5 years after closure
KYC documents (IDs, selfies)	5 years after account closure (AML requirement)
Transaction records	5 years (PAGCOR / AML requirement)
Gameplay history	3 years after last activity
Support chat logs	2 years after last contact
Marketing consent records	Until consent is withdrawn + 1 year
Cookies & analytics data	Maximum 24 months

When retention periods expire, we permanently delete or anonymize your data using secure methods. Backup copies may persist for up to 90 days for disaster recovery purposes before being purged.

09 Your Privacy Rights

Under the Philippine Data Privacy Act and similar international regulations, you have the following rights regarding your personal data:

• Right to be Informed: You have the right to know what data we collect and how we use it;
• Right to Access: You can request a copy of all personal data we hold about you;
• Right to Object: You can object to certain types of processing, including direct marketing;
• Right to Erasure / Blocking: You can request deletion of your data, subject to legal retention requirements;
• Right to Rectification: You can correct any inaccurate or outdated personal information;
• Right to Data Portability: You can request your data in a machine-readable format;
• Right to File a Complaint: You can file complaints with the National Privacy Commission (NPC);
• Right to Damages: You may claim compensation if you suffered damages due to inaccurate or unlawfully obtained data.

How to Exercise Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected] or via live chat. We will respond within 15 business days as required by the NPC. We may ask you to verify your identity before processing the request to prevent unauthorized access.

10 International Data Transfers

p2828 operates primarily within the Philippines, but some service providers (such as cloud hosting or fraud detection platforms) may store or process data outside the country.

When we transfer personal data internationally, we ensure appropriate safeguards are in place:

• The receiving country has adequate data protection laws recognized by the NPC;
• Or we execute standard contractual clauses with the receiving entity;
• Or the transfer is necessary for the performance of our contract with you (e.g., payment processing).

By using p2828, you consent to these international data transfers when they are necessary for the provision of our services.

11 Children's Privacy

p2828 is strictly for adults aged 21 years and older, in accordance with PAGCOR regulations. We do not knowingly collect or process personal information from anyone under 21.

If we discover that a minor has registered an account or provided personal information, we will:

• Immediately close the account and delete the associated data;
• Refund any deposits (following verification and applicable law);
• Report the incident to PAGCOR if required;
• Cooperate with parents, guardians, and authorities as appropriate.

If you believe a minor has accessed p2828, please contact us immediately at [email protected].

12 Third-Party Links & Services

Our platform may contain links to third-party websites, game providers, or services (such as payment processors or social media pages). This Privacy Policy does not apply to those third parties.

We encourage you to review the privacy policies of any third-party services you visit. p2828 is not responsible for the privacy practices or content of external websites.

13 Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or regulatory obligations. When we make material changes, we will notify you through:

• Email sent to the address registered on your account;
• A prominent notice on the p2828 website;
• An in-account notification the next time you log in.

The "Version effective" date at the top of this page indicates when the latest changes took effect. We encourage you to review this policy periodically to stay informed about how we protect your information.

Continued use of p2828 after changes to this Privacy Policy constitutes your acceptance of the updated terms.

14 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact our Data Protection Officer (DPO):

Filing a Complaint with the NPC

If you are unsatisfied with our response, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines:

• Website: https://www.privacy.gov.ph
• Email: [email protected]
• Address: 3rd Floor, Core G, GSIS Headquarters Building, Financial Center, Pasay City, Metro Manila