Privacy Policy

This Privacy Policy ("Policy") describes how twinph ("we", "us", "our", "the Platform") collects, uses, stores, and protects the personal information of players and visitors who access the twinph website at twinph.net and its associated services.

twinph is committed to handling personal data with transparency, integrity, and full respect for the privacy rights of every Filipino player. This Policy is drafted in compliance with Republic Act No. 10173 — the Data Privacy Act of 2012 — and the Implementing Rules and Regulations issued by the National Privacy Commission of the Philippines, as well as applicable PAGCOR regulatory requirements governing online gaming operators.

By registering an account with twinph, accessing the platform, or using any of our services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of the twinph platform and contact our support team to request account closure.

twinph collects personal data through several channels: directly from you during registration and account use, automatically through your interaction with our platform, and from third parties such as KYC verification providers and payment processors. The categories of personal data we collect include:

twinph uses your personal data only for the specific, legitimate purposes described below. We do not use your data for purposes that are incompatible with the reason it was collected without first obtaining your explicit consent:

• Account Management: Creating, verifying, and maintaining your twinph player account, including processing your registration and enabling secure login.
• Identity Verification (KYC): Fulfilling our obligation under PAGCOR regulations and Philippine Anti-Money Laundering Act (AMLA) requirements to verify the identity and age (21+) of all registered players before processing withdrawals or large deposits.
• Payment Processing: Facilitating deposits and withdrawals through GCash, PayMaya, BPI, BDO, and Metrobank, including verifying that payment instruments belong to the account holder.
• Gaming Services: Delivering the full suite of twinph games — slots, live casino, sports betting, sabong, bingo — and maintaining accurate records of your gaming activity and transaction history.
• Customer Support: Responding to enquiries, resolving disputes, processing complaints, and providing assistance through live chat, Messenger, Viber, and email in English and Tagalog.
• Regulatory Compliance: Meeting our obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine regulatory bodies, including filing required reports and responding to lawful authority requests.
• Fraud Prevention and Security: Monitoring account activity for signs of fraud, money laundering, bonus abuse, or other prohibited conduct as described in our Terms & Conditions. Protecting the integrity of our platform for all players.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviour and proactively reaching out to players who may benefit from responsible gaming tools, in line with our PAGCOR obligations.
• Service Communications: Sending you transactional communications related to your account — deposit confirmations, withdrawal approvals, security alerts, and important policy updates. These communications are not optional as they are required for account operation.
• Marketing (with consent only): Sending promotional offers, bonus notifications, and news about new games or features — but only if you have explicitly opted in to marketing communications. You may opt out at any time through your account settings or by contacting support.

Under the Philippine Data Privacy Act of 2012, twinph processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to fulfil our agreement with you — including account creation, game provision, payment processing, and customer support — is carried out on the basis that it is necessary to perform the contract between you and twinph.
• Legal Obligation: Certain processing activities, including KYC identity verification, AML transaction monitoring, PAGCOR regulatory reporting, and data retention for audit purposes, are required by Philippine law and are carried out on a legal obligation basis regardless of your consent.
• Legitimate Interests: twinph processes certain data — such as technical logs, fraud monitoring activity, and platform performance analytics — on the basis of our legitimate interests as an online gaming operator to maintain a secure, fair, and well-functioning platform for all players, provided those interests are not overridden by your privacy rights.
• Consent: For optional processing activities — particularly direct marketing communications and the use of non-essential cookies — twinph relies on your freely given, specific, and informed consent. You have the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

twinph does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We share your personal data only in the following limited and controlled circumstances:

• Game Content Providers: To deliver the games available on the twinph platform, certain gameplay data (player session identifiers, game results, bet amounts) is shared with our licensed game software providers. These providers are contractually bound to use this data only for game delivery and are prohibited from using it for any other purpose.
• Payment Processors: To process your deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, necessary financial and identity data is shared with the relevant payment service provider. All payment processors we work with are regulated entities operating under Bangko Sentral ng Pilipinas (BSP) oversight.
• KYC Verification Services: Identity verification documents and data are shared with our third-party KYC service provider for the purpose of verifying your identity and age as required by PAGCOR. KYC providers operate under strict data processing agreements and are bound to process your data solely for verification purposes.
• Regulatory and Law Enforcement Authorities: twinph is required by Philippine law to share certain data with PAGCOR, the AMLC, the National Privacy Commission, and other competent authorities upon lawful request. This includes filing Suspicious Transaction Reports (STRs) and Covered Transaction Reports (CTRs) under the Anti-Money Laundering Act.
• IT and Infrastructure Providers: Trusted third-party hosting, cybersecurity, and analytics providers who support the technical operation of the twinph platform may have access to certain data solely in the course of providing those infrastructure services, under binding data processing agreements.
• Professional Advisers: In exceptional circumstances, personal data may be disclosed to our legal advisers, auditors, or insurers on a strictly need-to-know basis and subject to professional confidentiality obligations.

All third parties with whom twinph shares personal data are required to maintain appropriate technical and organisational security measures and to process personal data only in accordance with our documented instructions and applicable Philippine data protection law.

twinph uses cookies and similar tracking technologies (including web beacons and local storage) on our platform to enable essential functionality, improve your experience, and — with your consent — deliver relevant promotional content. The following categories of cookies are used:

You can manage your cookie preferences at any time through your browser settings. Please note that disabling strictly necessary cookies will impair the functionality of the twinph platform and may prevent you from accessing your account or processing transactions.

twinph retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law and PAGCOR regulatory requirements. Our general retention schedules are as follows:

• Account and Identity Data: Retained for the duration of the active account relationship plus a minimum of five (5) years following account closure, as required by PAGCOR and AMLA regulations for gaming operator record-keeping.
• Transaction and Financial Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLC reporting and record-keeping obligations under the Anti-Money Laundering Act.
• KYC Verification Documents: Retained for a minimum of five (5) years following account closure or the last transaction date, whichever is later, as required by PAGCOR KYC requirements.
• Gaming Activity Logs: Retained for a minimum of three (3) years, used for dispute resolution, responsible gaming monitoring, and regulatory audit purposes.
• Customer Support Communications: Retained for two (2) years from the date of the last interaction, for service quality, dispute resolution, and training purposes.
• Marketing Consent Records: Retained for the duration of the consent plus two (2) years after withdrawal, as evidence of lawful processing.
• Technical Logs (IP, device, session): Retained for twelve (12) months for fraud prevention and security monitoring purposes.

At the end of each applicable retention period, personal data is securely deleted from our systems or, where deletion is not technically feasible, anonymised such that it can no longer be linked to any identifiable individual. Anonymised data may be retained indefinitely for statistical and research purposes.

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by twinph. We are committed to honouring these rights within the timelines prescribed by the National Privacy Commission:

To exercise any of these rights, please contact our Data Protection Officer (DPO) via live chat on the twinph platform, through Messenger or Viber, or by email at [email protected]. All requests will be acknowledged within 72 hours and resolved within 15 working days, or within the extended period permitted by NPC guidelines for complex requests.

twinph implements a comprehensive, multi-layered security programme to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include both technical and organisational controls, reviewed and updated on a regular basis to address evolving threats.

Key technical security measures in place at twinph include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the twinph platform is encrypted using industry-standard TLS protocols, preventing interception during transit.
• Data Encryption at Rest: Sensitive personal data stored in our databases — including identity documents, financial details, and account credentials — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within twinph's internal systems is restricted on a strict need-to-know basis, enforced through role-based access controls, multi-factor authentication for administrative accounts, and comprehensive access logging.
• Firewalls and Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls and real-time intrusion detection and prevention systems (IDS/IPS) that monitor for and block suspicious activity around the clock.
• Vulnerability Management: Regular penetration testing, vulnerability scanning, and security code reviews are conducted to identify and remediate weaknesses before they can be exploited.
• Secure Payment Processing: All financial transactions are routed through PCI-DSS compliant payment gateways. twinph does not store raw payment card data or full e-wallet credentials on its own servers.

Organisationally, twinph staff who handle personal data receive regular data privacy and security training. We maintain a documented Information Security Policy and a Data Breach Response Plan in compliance with NPC breach notification requirements.

While twinph takes every reasonable precaution to protect your data, no online system can guarantee absolute security. You also play an important role in keeping your account secure — we strongly encourage you to use a strong, unique password for your twinph account, enable two-factor authentication where available, and never share your login credentials with anyone.

The twinph platform is strictly intended for adults aged 21 years and older, in accordance with Philippine law governing casino-style online gaming. twinph does not knowingly collect, process, or retain personal data from any person under the age of 21.

Age verification is a mandatory step in the twinph registration and KYC process. Players are required to confirm their age at the point of registration and to submit valid government-issued identification confirming their date of birth during the verification process. Accounts that cannot be verified as belonging to an individual aged 21 or older will be suspended and any deposits held pending resolution.

If twinph becomes aware — through any means — that personal data has been collected from a person under 21 years of age, we will take immediate steps to:

• Suspend the relevant account and freeze any associated funds pending investigation.
• Delete the personal data of the minor from our active systems without undue delay.
• Notify the relevant parent or guardian where contact information is available.
• Report the matter to PAGCOR and, where legally required, to the appropriate child protection authority.

If you are a parent or guardian and have reason to believe that your child has registered on the twinph platform or submitted personal data without your knowledge, please contact our support team immediately via live chat or at [email protected]. We will treat all such reports with the utmost urgency and sensitivity.

In operating the twinph platform, certain personal data may be transferred to, stored, or processed in countries outside the Philippines — for example, by third-party game providers, cloud infrastructure providers, or KYC verification services that maintain servers in other jurisdictions.

Where personal data is transferred outside the Philippines, twinph ensures that appropriate safeguards are in place to protect that data to a standard equivalent to — or higher than — the requirements of the Philippine Data Privacy Act. These safeguards include:

• Entering into data processing agreements with all overseas data processors that incorporate the NPC's standard contractual clauses for cross-border data transfers.
• Transferring data only to countries or organisations that the NPC has recognised as providing adequate levels of data protection.
• Conducting due diligence on overseas processors' security practices, data handling policies, and regulatory compliance status before engaging them.

twinph maintains a register of all cross-border data transfers as part of its Records of Processing Activities (RoPA), which is updated whenever a new overseas processor is engaged or an existing arrangement changes. Filipino players may request information about the specific safeguards in place for cross-border transfers affecting their personal data by contacting our Data Protection Officer.

twinph reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or our service offerings. All updates will be made in good faith and with the aim of maintaining or improving the level of protection afforded to your personal data.

When we make material changes to this Policy — changes that significantly affect how your personal data is collected, used, or shared — we will notify you by:

• Displaying a prominent notice on the twinph homepage and in the account dashboard for a minimum of 14 days before the changes take effect.
• Sending an email notification to your registered email address describing the key changes and the date they will take effect.
• Updating the "Effective Date" and "Last Reviewed" fields at the top of this page.

For minor, non-material updates — such as formatting corrections, clarifications that do not alter the substance of any provision, or updates to contact details — twinph may update the Policy without advance notice, though the effective date will always reflect the most recent revision.

Your continued use of the twinph platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. If you object to any amendment, you should stop using the platform and contact our support team to request account closure and deletion of your personal data to the extent permitted by our legal retention obligations.

twinph has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act and NPC regulations. The DPO is responsible for overseeing twinph's data protection programme, handling data subject rights requests, managing data breach response, and serving as the primary point of contact with the National Privacy Commission.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by twinph, you may contact us through any of the following channels:

• Live Chat: Available directly on the twinph platform, 24 hours a day, 7 days a week. This is the fastest channel for urgent privacy matters, including suspected unauthorised access to your account.
• Messenger & Viber: Reach us through our official Messenger or Viber channels for non-urgent privacy enquiries. Our Filipino-speaking support agents are available around the clock.
• Email: [email protected] — please mark the subject line "Privacy / DPO Request" so your message is routed directly to our data protection team. Allow up to 3 business days for a response to email enquiries.

When submitting a data subject rights request, please include your registered email address, your account username, and a clear description of the right you wish to exercise or the concern you wish to raise. For identity verification purposes, we may ask you to confirm additional account details before processing your request.

If you are not satisfied with twinph's response to your privacy concern or rights request, you have the right to escalate the matter to the National Privacy Commission of the Philippines at privacy.gov.ph. We will always cooperate fully with any NPC investigation or mediation process.