Privacy Policy

1. Scope of This Policy

This Privacy Policy ("Policy") applies to all personal data collected by twinph through the website at https://twinph.cam and any associated mobile applications, sub-domains, or future digital platforms operated by twinph (collectively, the "Platform").

This Policy describes what information we collect from Filipino players, how we use that information, with whom we share it, and what choices you have regarding your personal data. By registering for a twinph account or using our services, you acknowledge that you have read and understood this Policy.

This Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy.

2. Data Controller

The data controller responsible for your personal information is twinph, headquartered in Manila, Philippines. twinph operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and complies with the Data Privacy Act of 2012 (Republic Act No. 10173).

For privacy-related enquiries, you may contact our Data Protection Officer at [email protected] (plain text only — not a clickable link).

3. Personal Data We Collect

twinph collects several categories of personal data necessary to provide gaming services and comply with legal obligations:

• Account Information: Full name, date of birth, residential address, email address, and mobile phone number.
• Identity Verification Data: Government-issued identification documents (e.g., Philippine passport, driver's licence, Unified Multi-Purpose ID), proof of address documents (utility bills, bank statements), and in some cases, selfie photos for biometric verification.
• Financial Data: Payment method details (GCash account number, PayMaya account number, bank account details for BPI, BDO, or Metrobank), transaction history, deposit and withdrawal records.
• Technical Data: IP address, browser type and version, device type, operating system, time zone setting, location data, and clickstream data (pages visited, time spent on each page).
• Gameplay Data: Game selections, betting patterns, session duration, win/loss records, and bonus usage.
• Communication Data: Records of your interactions with our customer support team (via live chat, email, or other communication channels).
• Marketing Preferences: Consent for promotional communications, preferences regarding SMS or email newsletters.

4. How We Collect Your Data

We collect your personal data through the following means:

• Direct Provision: Information you provide when registering your account, completing your profile, making a deposit, submitting identity documents, or contacting customer support.
• Automated Technologies: Data automatically collected through cookies, web beacons, and similar tracking technologies as you navigate the Platform.
• Third-Party Sources: Identity verification services, payment processors (GCash, PayMaya, banks), fraud prevention databases, and PAGCOR's self-exclusion registries.

5. How We Use Your Personal Data

twinph uses your personal data for the following purposes:

• Account Management: To create and maintain your twinph account, authenticate your identity, and enable you to access gaming services.
• Transaction Processing: To process deposits, withdrawals, and refunds using your chosen payment method (GCash, PayMaya, BPI, BDO, Metrobank).
• Regulatory Compliance: To verify your age (21+), conduct Know Your Customer (KYC) checks, prevent money laundering, and comply with PAGCOR reporting requirements.
• Fraud Prevention: To detect and prevent multi-accounting, collusion, bonus abuse, and other prohibited conduct outlined in our Terms & Conditions.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance via live chat or email.
• Responsible Gaming: To implement deposit limits, session time limits, self-exclusion requests, and monitor gambling behaviour for signs of problem gaming.
• Marketing Communications: To send you promotional offers, newsletters, and personalised recommendations based on your gaming preferences (only if you have opted in).
• Platform Improvement: To analyse user behaviour, improve website performance, develop new features, and optimise the player experience.

6. Legal Basis for Processing

Under Philippine data protection law, twinph processes your personal data based on the following legal grounds:

• Contract Performance: Processing is necessary to fulfil our contractual obligations under the Terms & Conditions, including providing gaming services and processing your transactions.
• Legal Obligation: Processing is required to comply with PAGCOR regulations, anti-money laundering laws, tax reporting requirements, and the Data Privacy Act of 2012.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and improving user experience, provided these interests do not override your fundamental rights.
• Consent: Where required by law, we obtain your explicit consent before processing sensitive data or sending marketing communications. You may withdraw consent at any time.

7. Sharing Your Data with Third Parties

twinph does not sell your personal data to third parties. However, we may share your data with the following categories of recipients for operational and legal reasons:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other licensed financial institutions to process deposits and withdrawals.
• Identity Verification Providers: Third-party KYC service providers to verify your identity and comply with anti-money laundering regulations.
• Game Providers: Licensed software developers and live casino studios that supply games on the twinph platform (e.g., Pragmatic Play, Evolution Gaming, Microgaming). These providers may access gameplay data to ensure game integrity.
• Regulatory Authorities: PAGCOR and other Philippine government agencies as required by law.
• Fraud Prevention Services: Third-party databases and analytics tools to detect multi-accounting, collusion, and other prohibited conduct.
• Legal and Professional Advisers: Lawyers, auditors, and consultants where necessary for legal compliance or dispute resolution.
• Business Successors: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity, subject to continued compliance with this Policy.

All third-party data processors are contractually bound to protect your data and use it only for the purposes specified by twinph.

8. Data Retention

twinph retains your personal data only for as long as necessary to fulfil the purposes outlined in this Policy and comply with legal obligations:

• Active Accounts: Data is retained for the duration of your active account plus a period required to settle any outstanding transactions or disputes.
• Closed Accounts: After account closure, certain data (transaction records, identity documents) are retained for up to seven (7) years to comply with PAGCOR record-keeping requirements and anti-money laundering laws.
• Marketing Data: If you opt out of marketing communications, your preference is retained indefinitely to ensure we honour your request.
• Technical Logs: Server logs and technical data are typically retained for 90 days unless longer retention is required for security investigations or legal claims.

9. Security Measures

twinph implements robust security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction:

• SSL Encryption: All data transmitted between your device and twinph servers is protected by 256-bit Secure Socket Layer (SSL) encryption.
• Secure Storage: Personal data is stored on secure servers located in PAGCOR-approved data centres with restricted physical and digital access.
• Access Controls: Only authorised twinph personnel with a legitimate need to access your data (e.g., customer support staff, compliance officers) are granted permission.
• Two-Factor Authentication (2FA): We strongly encourage players to enable 2FA on their accounts for an additional layer of security.
• Regular Audits: Our systems undergo regular security audits and vulnerability assessments by independent third-party cybersecurity firms.

While we take all reasonable precautions, no method of transmission over the Internet is 100% secure. You are responsible for maintaining the confidentiality of your login credentials.

10. Cookies & Tracking Technologies

twinph uses cookies and similar tracking technologies to enhance your experience on the Platform:

• Essential Cookies: Required for the Platform to function properly, including session management and security features. These cannot be disabled.
• Performance Cookies: Collect anonymous data on how you use the Platform (e.g., which pages are visited most frequently) to help us improve performance.
• Functionality Cookies: Remember your preferences (e.g., language settings, favourite games) to personalise your experience.
• Marketing Cookies: Track your interactions with promotional content to deliver relevant offers and measure campaign effectiveness (only if you have consented).

You can manage cookie preferences through your browser settings. Disabling certain cookies may limit your access to some features of the Platform.

11. Your Data Rights

Under the Data Privacy Act of 2012 (Republic Act No. 10173), Filipino players have the following rights regarding their personal data:

• Right to Access: You may request a copy of the personal data twinph holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete data.
• Right to Erasure: You may request deletion of your data, subject to legal retention requirements.
• Right to Object: You may object to the processing of your data for marketing purposes at any time.
• Right to Data Portability: You may request your data in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact our Data Protection Officer at [email protected]. We will respond to your request within 30 days.

12. Children's Privacy

twinph strictly enforces a 21+ age restriction in accordance with Philippine gambling laws. The Platform is not intended for use by individuals under the age of 21, and we do not knowingly collect personal data from minors.

If we discover that a minor has registered an account, the account will be immediately closed, and any personal data will be deleted in accordance with legal requirements. Parents or guardians who believe their child has provided personal data to twinph should contact us immediately.

13. International Data Transfers

While twinph primarily operates within the Philippines and stores data on Philippine-based servers, certain third-party service providers (e.g., game software developers, payment processors) may be located outside the Philippines.

In such cases, we ensure that adequate safeguards are in place to protect your data in accordance with Philippine data protection standards. This may include the use of standard contractual clauses, adequacy decisions, or other lawful mechanisms.

14. Changes to This Policy

twinph reserves the right to update this Privacy Policy from time to time to reflect changes in legal requirements, business practices, or platform features. Material changes will be communicated to registered players via email and through a prominent notice on the Platform.

The "Last Updated" date at the top of this page indicates when the most recent changes were made. Continued use of the Platform following notification of changes constitutes your acceptance of the revised Policy.

15. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact our Data Protection Officer:

• Email: [email protected] (plain text only — not a clickable link)
• Live Chat: Available 24/7 on the twinph website for immediate assistance in English or Tagalog.
• Postal Address: twinph Data Protection Officer, Metro Manila, Philippines.

We aim to respond to all privacy-related enquiries within 48 hours and will resolve complaints within 14 business days where possible.