44spinph
Privacy Policy

1. Introduction

44spinph ("44spinph," "we," "us," or "our") is committed to protecting the privacy and personal data of every individual who uses the 44spinph website, mobile application, and associated gaming services (collectively, the "Platform"). This Privacy Policy ("Policy") describes how 44spinph collects, uses, stores, shares, and protects personal information in connection with your use of the Platform.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). By registering an account on 44spinph or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read together with the 44spinph Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and 44spinph.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, 44spinph acts as the personal information controller in respect of the personal data it collects from players and users of the Platform. 44spinph determines the purposes and means of processing personal data collected through the Platform.

Where 44spinph engages third-party service providers to process personal data on its behalf — such as payment processors, game providers, and identity verification services — those parties act as personal information processors and are bound by data processing agreements that require them to handle personal data only in accordance with 44spinph's instructions and applicable law.

3. Personal Data We Collect

44spinph collects the following categories of personal data from players and users of the Platform:

44spinph does not intentionally collect sensitive personal information as defined under the DPA (such as health data, religious beliefs, or political affiliations) unless specifically required for responsible gaming assessments or as mandated by applicable law.

4. How We Collect Personal Data

44spinph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions on 44spinph.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; payment confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank; fraud detection signals from security service providers.
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with licensing compliance, responsible gaming obligations, or anti-money laundering requirements.

5. Purpose and Legal Basis for Processing

44spinph processes personal data only for specified, legitimate purposes. The table below sets out the primary purposes for which 44spinph processes personal data and the corresponding legal basis under the Data Privacy Act of 2012:

Where 44spinph relies on your consent as the legal basis for processing — such as for marketing communications — you have the right to withdraw that consent at any time by updating your communication preferences in your account settings or by contacting our support team.

6. Data Sharing and Disclosure

6.1 Service Providers

44spinph shares personal data with carefully selected third-party service providers who assist in operating the Platform. These include payment processors (GCash, PayMaya, BPI, BDO , Metrobank), identity verification providers, game software suppliers, cloud hosting providers, and customer support platform operators. All service providers are bound by contractual obligations to process personal data only as instructed by 44spinph and in compliance with applicable data protection law.

6.2 Regulatory and Law Enforcement Authorities

44spinph may disclose personal data to PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission, or other competent government authorities where required by law, court order, or regulatory directive. Such disclosures are made only to the extent strictly necessary to comply with the applicable legal obligation.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 44spinph's business, personal data held by 44spinph may be transferred to the acquiring entity as part of that transaction. Affected players will be notified of any such transfer and any material changes to this Policy that result from it.

6.4 No Sale of Personal Data

44spinph does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Personal data is shared only as described in this Policy or with your explicit consent.

7. Data Retention

44spinph retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Gaming history: Retained for a minimum of three (3) years from the date of the gaming session.
• Support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution.
• Marketing consent records: Retained for the duration of the consent and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 44spinph's data disposal procedures.

8. Data Security

44spinph implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption of data in transit using industry-standard TLS protocols.
• Encryption of sensitive data at rest, including financial account details and identity documents.
• Role-based access controls limiting access to personal data to authorised personnel only.
• Regular security assessments, vulnerability scanning, and penetration testing of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Staff training on data protection obligations and secure data handling practices.

While 44spinph takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the security of your own account credentials. If you suspect that your 44spinph account has been compromised, please contact our support team immediately.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 44spinph will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

9. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 44spinph:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data that 44spinph holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held by 44spinph. You may update certain account details directly through your account settings.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 44spinph's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data where 44spinph relies on legitimate interest as the legal basis, and where your interests override those of 44spinph.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe that 44spinph has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact the 44spinph Data Protection Officer using the contact details provided in Section 14 of this Policy. 44spinph will respond to all verified data subject requests within fifteen (15) business days of receipt.

10. Cookies and Tracking Technologies

44spinph uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain session state, analyse Platform usage, and support security functions. The following types of cookies are used:

• Strictly necessary cookies: Required for the Platform to function correctly, including session management and security tokens. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and account display options.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the Platform, helping 44spinph improve its services.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorised access attempts.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 44spinph Platform. 44spinph does not use cookies to serve third-party advertising.

11. Minors and Age Restriction

The 44spinph Platform is strictly intended for individuals who are 21 years of age or older. 44spinph does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the account registration process, and 44spinph reserves the right to request documentary proof of age at any time.

If 44spinph becomes aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, that data will be deleted promptly and the associated account will be closed. If you believe that a minor has registered an account on 44spinph, please contact our support team immediately.

12. International Data Transfers

Some of 44spinph's third-party service providers — including cloud infrastructure providers and game software suppliers — may process personal data outside of the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that afforded under Philippine law, 44spinph ensures that appropriate safeguards are in place, such as contractual clauses approved by the National Privacy Commission or equivalent data transfer mechanisms.

By using the 44spinph Platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the operation of the Platform, subject to the safeguards described above.

13. Changes to This Policy

44spinph 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 changes will be communicated to registered players via the email address associated with their 44spinph account and/or via a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the 44spinph Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how 44spinph protects your personal data.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 44spinph, please contact our Data Protection Officer:

Data Protection Officer — 44spinph
Email: privacy@44spinph.com

For general support enquiries, you may also reach our customer support team at: support@44spinph.com

44spinph will acknowledge all data privacy requests within three (3) business days and will provide a substantive response within fifteen (15) business days of receipt. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.