Privacy Policy

This Privacy Policy ("Policy") is published by 24phdream ("24phdream," "we," "us," or "our"), the operator of the online gaming platform accessible at https://24phdream.asia and all associated subdomains and interfaces (collectively, the "Platform"). This Policy governs the collection, use, storage, sharing, and protection of personal data provided by or collected about users ("Player," "you," or "your") of the 24phdream Platform.

24phdream operates in compliance with Republic Act No. 10173, the Philippine Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and applicable issuances of the National Privacy Commission ("NPC"). We are committed to handling the personal data of Filipino players — from Manila, Cebu, Davao, Quezon City, and across the archipelago — with transparency, integrity, and the highest standards of data security.

By registering an account at 24phdream, accessing the Platform, or using any service we provide, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to the terms of this Policy, you must not use the 24phdream Platform.

• "Personal Data" means any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual.
• "Sensitive Personal Information" has the meaning ascribed to it under Section 3(l) of RA 10173, including government-issued ID numbers, health and medical information, and financial data.
• "Processing" refers to any operation performed upon personal data, including collection, recording, storage, use, disclosure, and deletion.
• "Data Controller" means 24phdream as the entity that determines the purposes and means of processing personal data submitted through the Platform.
• "Data Processor" means any natural or legal person who processes personal data on behalf of 24phdream under a written data processing agreement.
• "DPO" means Data Protection Officer — the individual appointed by 24phdream to oversee compliance with this Policy and with RA 10173.
• "Cookies" means small text files stored on your device by the Platform for the purposes of session management, analytics, and functionality.

24phdream collects the following categories of personal data from players, either directly or through automated technical means:

Collected when you create a 24phdream account: legal full name, date of birth, email address, Philippine mobile number, username, hashed account password, and city or province of residence.

Collected during mandatory identity verification: copies of government-issued Philippine identification documents (e.g., Passport, Driver's License, PhilSys National ID, UMID, PRC ID), selfie photographs for facial verification, and where required, proof of address documentation (e.g., utility bills, bank statements).

Collected during deposits and withdrawals: GCash account details, PayMaya account details, bank account numbers (BPI, BDO, Metrobank) where applicable, transaction amounts, transaction dates and times, and transaction reference numbers. 24phdream does not store full credit or debit card numbers.

Generated through Platform use: game history, bet amounts and outcomes, session durations, sports betting activity (including PBA, NBA, and other events wagered on), bingo participation records, and bonus usage history.

Collected automatically when you access the Platform: IP address, device type and model, operating system, browser type and version, referring URL, pages visited, session timestamps, and mobile network information.

Records of communications between you and 24phdream support, including live chat transcripts, email correspondence, and any documents or images submitted in support communications.

24phdream collects personal data through the following means:

• Direct submission: Data you actively provide during account registration, KYC submission, deposit and withdrawal transactions, live chat or email communications with support, and when completing responsible gaming forms.
• Automated collection: Technical data including IP addresses, device identifiers, and session logs collected automatically through cookies, server logs, and similar technologies when you access the Platform.
• Third-party verification services: Identity data returned to 24phdream by KYC and age verification service providers who process your submitted documents on our behalf under data processing agreements.
• Payment processors: Transaction confirmation data provided by GCash, PayMaya, and partner banks following deposit and withdrawal processing.
• Social login providers: If you choose to register or log in using a Google or Facebook account, those platforms share certain profile data (name, email, profile photo) with 24phdream as described in their respective privacy policies.

Under RA 10173 and its IRR, 24phdream processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms and Conditions, including account management, gameplay, deposit and withdrawal processing, and customer support.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering obligations under the AMLA, PAGCOR regulatory requirements, age verification mandates, and lawful orders of courts or regulatory authorities.
• Legitimate interests: Processing necessary for fraud prevention, Platform security, abuse detection, and internal analytics — provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications, where your explicit consent has been obtained and may be withdrawn at any time without affecting the lawfulness of prior processing.

24phdream uses the personal data we collect for the following specific purposes:

• Creating, managing, and maintaining your 24phdream player account.
• Verifying your identity and age (21+) in accordance with PAGCOR requirements and RA 10173.
• Processing deposits via GCash, PayMaya, and partner banks, and processing withdrawal requests to verified payment accounts.
• Delivering gameplay services — including live dealer games, slots, sports betting, bingo, and Big Hammer arcade games — and maintaining accurate game and betting records.
• Preventing fraud, money laundering, identity theft, and other illegal activities, including compliance with the Anti-Money Laundering Act (AMLA) reporting obligations.
• Operating responsible gaming tools including deposit limits, session reminders, cool-off periods, and self-exclusion programs.
• Providing customer support through live chat and email channels.
• Analyzing Platform usage patterns to improve service quality, resolve technical issues, and develop new features.
• Sending service-essential notifications about your account, transactions, security alerts, and policy updates.
• Sending promotional and marketing communications where you have provided consent, including information about bonuses and promotions.
• Complying with legal obligations, responding to lawful requests from PAGCOR and other regulatory authorities, and enforcing our Terms and Conditions.

24phdream does not sell or commercially transfer your personal data to third parties. We share personal data only in the following limited and controlled circumstances:

We share data with carefully selected third-party service providers who process personal data on our behalf under written data processing agreements that require them to maintain appropriate technical and organizational security measures. These include: KYC and identity verification providers, payment processing partners (GCash, PayMaya, partner banks), game content providers (who may receive technical identifiers for gameplay purposes), cloud infrastructure providers, and fraud detection service providers.

24phdream may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), courts of competent jurisdiction, and other Philippine government authorities where disclosure is required by applicable law, regulatory directive, court order, or legal process.

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of 24phdream's assets, your personal data may be transferred to the acquiring entity, provided that the acquiring entity agrees to process your personal data in accordance with this Privacy Policy and applicable Philippine law. 24phdream will notify registered players of any such transfer prior to its completion.

The 24phdream Platform uses cookies and similar tracking technologies to provide core functionality, maintain security, and analyze Platform performance. The following types of cookies are used:

• Strictly necessary cookies: Required for the Platform to function, including session authentication cookies that keep you logged in to your 24phdream account. These cannot be disabled without impairing core functionality.
• Performance and analytics cookies: Used to understand how players interact with the Platform — pages visited, session durations, error occurrences, and navigation patterns. This data is aggregated and anonymized for analysis purposes.
• Functional cookies: Used to remember your preferences, such as language settings, game lobby display preferences, and responsible gaming settings.
• Security cookies: Used to detect and prevent fraudulent login attempts, bot activity, and unusual account behavior patterns.

You may manage cookie preferences through your browser settings. Blocking strictly necessary cookies will prevent you from logging in to your 24phdream account and using real-money gaming services. Blocking analytics and functional cookies may impair certain Platform features but will not prevent core gameplay access.

24phdream retains personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying legal, accounting, regulatory, or reporting obligations. The retention periods specified in Section 3 of this Policy apply to each category of personal data.

Financial transaction records and KYC documentation are retained for the periods required under the Philippine Anti-Money Laundering Act (AMLA) and AMLC regulations, which currently mandate retention for a minimum period of five years from the date of the transaction, and in some circumstances longer periods for high-value or suspicious transactions.

When personal data is no longer required for any lawful purpose, 24phdream will securely delete or anonymize it in a manner that prevents reconstruction of the original data. Physical documents containing personal data are disposed of through certified secure destruction processes.

Account closure by the player does not immediately trigger deletion of all personal data. Regulatory retention obligations apply independently of account status, and 24phdream will retain the minimum necessary data for the legally required periods even after an account has been closed.

24phdream implements and maintains a comprehensive set of technical and organizational security measures designed to protect personal data from unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data in transit is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest (including KYC documents and financial data) is encrypted using AES-256 encryption.
• Access controls: Access to personal data systems is restricted to authorized personnel on a strict need-to-know basis, enforced through role-based access control (RBAC), multi-factor authentication, and privileged access management (PAM) solutions.
• Intrusion detection and monitoring: 24phdream operates continuous monitoring systems that detect and alert on unauthorized access attempts, unusual data access patterns, and potential security incidents in real time.
• Regular security assessments: The Platform undergoes periodic vulnerability assessments and penetration testing conducted by independent third-party security specialists.
• Data minimization: 24phdream collects only the personal data strictly necessary for the stated processing purposes, in compliance with the data minimization principle under RA 10173.
• Employee training: All 24phdream personnel with access to personal data receive regular data privacy and security training, and are bound by confidentiality obligations in their employment contracts.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to personal data held by 24phdream:

• Right to be Informed: You have the right to be informed of how your personal data is collected, used, shared, and protected — which is the purpose of this Privacy Policy.
• Right to Access: You have the right to request a copy of the personal data 24phdream holds about you, together with information about how it is being processed. Requests will be responded to within 15 business days.
• Right to Correction: You have the right to request correction of inaccurate, incomplete, or outdated personal data. Corrections to core account data (name, date of birth) require supporting documentary evidence.
• Right to Erasure (Right to be Forgotten): You may request deletion of your personal data where: (a) it is no longer necessary for the purpose for which it was collected; (b) you withdraw consent and there is no other legal basis for processing; or (c) processing is unlawful. This right is subject to 24phdream's legal retention obligations, which may require retention of certain data regardless of an erasure request.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to other processing based on legitimate interests, subject to 24phdream demonstrating compelling legitimate grounds that override your rights.
• Right to Data Portability: Where technically feasible, you may request that 24phdream provide your personal data in a structured, commonly used, machine-readable format.
• Right to File a Complaint: If you believe 24phdream has not processed your personal data in accordance with RA 10173, you may file a complaint directly with the National Privacy Commission of the Philippines.

To exercise any of these rights, contact 24phdream's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request — [Right Being Exercised]." You will be asked to verify your identity before any request is processed. 24phdream will not charge a fee for reasonable data subject requests.

The 24phdream Platform is strictly intended for adults aged 21 years and older, in accordance with PAGCOR regulations governing online gaming in the Philippines. 24phdream does not knowingly collect, process, or store personal data from individuals under the age of 21.

Mandatory KYC verification requiring a valid Philippine government-issued ID is conducted prior to processing any withdrawal, specifically to enforce age verification. Where 24phdream identifies or reasonably suspects that an account has been created by or on behalf of an individual under 21 years of age, the account will be suspended immediately, all pending bets voided, and deposited funds returned to the original payment source. The personal data associated with such accounts will be handled in accordance with applicable law and deleted at the earliest opportunity permitted by any applicable legal retention obligations.

Parents and guardians who believe a minor may have accessed the 24phdream Platform or created an account should contact 24phdream support immediately via live chat or email at [email protected] for prompt investigation and remediation.

With your consent provided during registration or updated in your account settings, 24phdream may send you promotional communications regarding bonuses, promotions, new game releases, special events (such as the Sunday Mega Bingo jackpot events), sports betting promotions, and other Platform offers.

Marketing communications may be delivered through: promotional emails to your registered address, SMS messages to your registered Philippine mobile number, and in-Platform notifications visible in your account dashboard.

You may withdraw consent to receive marketing communications at any time through any of the following means, free of charge and without affecting your ability to use the Platform:

• Updating your communication preferences in the Account Settings section of your 24phdream dashboard.
• Clicking the "Unsubscribe" link included at the bottom of every marketing email from 24phdream.
• Contacting 24phdream support via live chat or email at [email protected] with the request to cease marketing communications.

Withdrawal of marketing consent does not affect your receipt of service-essential communications — such as account security alerts, transaction confirmations, responsible gaming notifications, and policy update notices — which are sent based on contractual necessity and legal obligation rather than consent.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, 24phdream will comply fully with the notification obligations under RA 10173 and the NPC's data breach notification guidelines. Specifically:

• 24phdream will notify the National Privacy Commission of the Philippines of a qualifying personal data breach within 72 hours of becoming aware of it, where feasible, in accordance with the NPC's breach notification requirements.
• Where a breach is likely to result in a high risk to the rights and freedoms of affected players, 24phdream will notify those players directly as soon as reasonably practicable, providing: a description of the nature of the breach; contact details of the Data Protection Officer; likely consequences of the breach; and measures taken or proposed to address the breach and mitigate its effects.
• 24phdream maintains an internal data breach response plan that is reviewed regularly and tested through tabletop exercises.

Some of 24phdream's third-party service providers — including game content providers, cloud infrastructure partners, and KYC verification services — may process personal data in jurisdictions outside the Philippines. Where such cross-border data transfers occur, 24phdream ensures that:

• The receiving country provides an adequate level of protection for personal data, as assessed under the standards of RA 10173 and NPC guidelines.
• Where the receiving country does not provide an adequate level of protection, appropriate safeguards are in place through contractual data transfer agreements that impose data protection obligations equivalent to those under Philippine law.
• The transfer is necessary for the performance of the contract between 24phdream and the player, or is otherwise permitted under applicable Philippine law.

By using the 24phdream Platform, you acknowledge and consent to the cross-border transfer of your personal data to third-party service providers in other countries as described in this section, subject to the safeguards outlined above.

24phdream may update this Privacy Policy periodically to reflect changes in our data processing practices, legal obligations, Platform features, or applicable Philippine regulations. The effective date of the current version is displayed at the top of this page.

When we make material changes to this Policy — changes that significantly affect the nature, purpose, or scope of personal data processing — we will notify registered players by: sending an email notice to your registered email address, and/or displaying a prominent notice on the Platform, no less than 14 days before the updated Policy takes effect.

For non-material changes (such as clarifications, corrections, or updates to contact information), we will update the Policy and revise the effective date without direct notification. We encourage you to periodically review this Policy to stay informed of how 24phdream protects your personal data.

Continued use of the 24phdream Platform following the effective date of an updated Privacy Policy constitutes your acceptance of the updated terms.

For any questions, concerns, or requests relating to this Privacy Policy, your personal data rights under RA 10173, or 24phdream's data processing practices, please contact our Data Protection Officer (DPO) through the following channels:

• Email: [email protected] — use the subject line "Privacy / DPO Inquiry" or "Data Subject Rights Request" as appropriate. The DPO will acknowledge receipt within 2 business days and provide a substantive response within 15 business days.
• Live Chat: Available 24 hours a day, 7 days a week through the Platform dashboard. Live chat is recommended for urgent privacy concerns or immediate account security issues requiring prompt action.

If you are not satisfied with how 24phdream has handled a privacy concern, or if you believe that your personal data rights under RA 10173 have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) through NPC's official complaint process.