42vip Privacy Policy
— Your Data, Protected

1 Introduction and Scope

This Privacy Policy ("Policy") describes how 42vip ("42vip," "we," "us," or "our"), the operator of the online gaming platform accessible at https://42vip.cam, collects, uses, stores, shares, and protects the personal data of individuals who register for and use the 42vip Platform ("you" or "Player").

This Policy applies to all personal data processed in connection with your use of the 42vip Platform, including the website at https://42vip.cam, the mobile web application, and all associated support channels including live chat and email. It covers data collected from players located in the Philippines and from any person who interacts with our Platform regardless of their location, to the extent permitted by applicable law.

This Policy is issued in compliance with Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines. By creating a 42vip account or continuing to use the Platform after this Policy has been published, you acknowledge that you have read and understood this Policy.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference into this document.

2 Data Controller Information

42vip acts as the Data Controller for personal data collected through the Platform. As Data Controller, 42vip determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out in accordance with applicable data protection laws.

42vip has appointed a dedicated Data Privacy Officer (DPO) who oversees compliance with data protection obligations, handles data subject rights requests, and serves as the point of contact for the National Privacy Commission. Contact details for the DPO are provided in Section 15 of this Policy.

Where third-party service providers process personal data on 42vip's behalf, those providers act as Data Processors and are required by contract to process data only on documented instructions from 42vip, implement appropriate security measures, and comply with the Data Privacy Act of 2012.

3 Personal Data We Collect

42vip collects the following categories of personal data in the course of operating the Platform and maintaining your player account:

42vip does not intentionally collect special categories of personal data (such as health data, religious beliefs, or political opinions) unless specifically required for a responsible gaming intervention or legal compliance purpose, in which case explicit consent will be sought separately.

4 How We Collect Your Data

42vip collects personal data through the following channels and methods:

• Direct collection: Data you actively provide during account registration, KYC verification, deposit and withdrawal requests, support interactions, and promotion opt-ins.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, server logs, and session tracking technologies described in Section 10.
• Third-party sources: Identity verification and fraud screening data from licensed KYC and AML service providers, and transaction data from payment processors (GCash, Maya, BPI, BDO) in connection with deposits and withdrawals made to or from your 42vip account.
• Publicly available sources: Where permitted by law, we may supplement our records with information from publicly available registries or regulatory watchlists for AML and fraud prevention purposes.

You are under no statutory obligation to provide personal data to 42vip; however, certain categories of data are necessary to create and maintain your account, process transactions, and comply with regulatory requirements. Failure to provide required data may result in 42vip being unable to offer you access to all or part of the Platform.

5 Lawful Bases for Processing

Under the Data Privacy Act of 2012, 42vip processes your personal data on one or more of the following lawful bases:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you have agreed to, including account management, game provision, and payment processing.
• Legal obligation: Processing necessary to comply with applicable law, including PAGCOR gaming regulations, Anti-Money Laundering Act (AMLA) obligations, and the Data Privacy Act of 2012 itself.
• Legitimate interests: Processing carried out in pursuit of 42vip's legitimate interests in fraud prevention, Platform security, service improvement, and responsible gaming monitoring — where those interests are not overridden by your rights and interests.
• Consent: Where required by law, 42vip will seek your explicit consent before processing specific categories of data or sending direct marketing communications. You may withdraw consent at any time by contacting our Data Privacy Officer.

6 How We Use Your Personal Data

42vip uses the personal data we collect for the following purposes:

1. Account Registration and Management: Creating and maintaining your player account, verifying your identity and eligibility, and managing your account settings and preferences.
2. Payment Processing: Processing deposits from and withdrawals to your registered GCash, Maya, or bank accounts; reconciling transaction records; and managing currency-related matters.
3. KYC and Regulatory Compliance: Meeting PAGCOR licensing requirements, AMLA obligations, and mandatory player identity verification standards. This includes verifying that all players are at least 21 years of age in accordance with Philippine gaming regulations.
4. Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent transactions, money laundering, bonus abuse, account takeovers, and other prohibited activities.
5. Game Provision and Sports Betting: Delivering the games, live dealer tables, bingo rooms, and sportsbook markets you access, and maintaining accurate records of your gameplay activity.
6. Responsible Gaming: Monitoring gaming activity patterns for signs of problem gambling, enabling and managing responsible gaming tools (deposit limits, self-exclusion, session reminders), and complying with responsible gaming obligations under PAGCOR regulations.
7. Customer Support: Responding to inquiries, resolving disputes, and maintaining records of support interactions for quality assurance purposes.
8. Platform Improvement: Analyzing aggregate usage data (in anonymized or pseudonymized form) to improve Platform performance, user experience, and game selection.
9. Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You can opt out at any time through your account settings or by contacting support.

7 Sharing Your Data with Third Parties

42vip shares personal data with third parties only to the extent necessary and only under appropriate contractual safeguards. We do not sell your personal data. The categories of third parties with whom we share data include:

• Payment Processors: GCash, Maya, BPI, BDO, UnionBank, 7-Eleven CLiQQ, GrabPay, and USDT TRC20 gateway providers receive the transaction and account data necessary to process your deposits and withdrawals.
• KYC and AML Providers: Licensed identity verification and anti-money laundering screening partners receive your identity documents and personal details to perform mandatory regulatory checks.
• Game and Content Providers: Providers such as Pragmatic Play, Evolution Gaming, and Microgaming receive the technical session data necessary to deliver their games through the 42vip Platform. These providers do not receive your financial or identity documents.
• IT Infrastructure and Cloud Providers: Server hosting and cloud infrastructure partners who process data on our behalf under strict data processing agreements that prohibit independent use.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and Philippine law enforcement agencies, where disclosure is required by law, court order, or regulatory mandate.
• Professional Advisors: Lawyers, auditors, and accountants who require access to personal data in the course of providing professional services to 42vip, subject to strict confidentiality obligations.

All third-party data processors engaged by 42vip are required by contract to implement security measures at least equivalent to those maintained by 42vip, to process data only on documented instructions, and to comply with the Data Privacy Act of 2012 and any other applicable data protection law.

8 International Data Transfers

Some of 42vip's third-party service providers, including certain cloud infrastructure and game content providers, may be located in jurisdictions outside the Philippines. Where personal data is transferred internationally, 42vip ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that required under the Data Privacy Act of 2012.

These safeguards include: contractual data processing agreements incorporating the standard data protection clauses recognized by the National Privacy Commission; transfers only to countries or territories that the NPC has determined provide an adequate level of data protection; or implementation of approved binding corporate rules where applicable.

If you would like further information about the specific safeguards applied to international data transfers involving your personal data, please contact our Data Privacy Officer using the details in Section 15.

9 Data Retention

42vip retains personal data for no longer than is necessary to fulfill the purposes for which it was collected, subject to the following retention guidelines:

• Account and Identity Data: Retained for the duration of your active account, plus a minimum of five (5) years following account closure, as required by PAGCOR regulations and AMLA record-keeping obligations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with AMLA requirements applicable to covered persons in the gaming sector.
• Gaming Activity Data: Retained for a minimum of three (3) years from the date of each gaming session, to satisfy PAGCOR regulatory reporting requirements and to support any potential disputes.
• Support and Communications Records: Retained for two (2) years from the date of the last interaction, to facilitate any follow-up queries, audits, or dispute resolution proceedings.
• Marketing Preferences: Retained until you withdraw your consent to receive marketing communications or close your account, whichever occurs first.

Upon expiry of the applicable retention period, personal data will be securely deleted or rendered permanently anonymous. Where deletion is not technically feasible (for example, data stored in backup archives), 42vip will isolate the data from active processing until deletion is possible.

10 Cookies and Tracking Technologies

42vip uses cookies and similar tracking technologies on the Platform to enable essential functionality, improve performance, analyze usage patterns, and (where you have consented) serve relevant promotional content. The categories of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security cookies. They cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: Remember your preferences (such as preferred language and display settings) to enhance your experience across sessions.
• Analytics Cookies: Collect anonymized or pseudonymized data about how players use the Platform, helping us identify performance issues and improve game loading times and navigation flows.
• Session Management Cookies: Track your current gaming session duration to support responsible gaming features such as session time reminders.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from using core Platform features including account login and gameplay. 42vip does not use third-party advertising cookies or cross-site tracking technologies for commercial advertising networks.

11 Security Measures

42vip maintains a comprehensive information security programme designed to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our technical and organizational security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• AES-256 encryption for sensitive personal data stored in our databases.
• Multi-factor authentication options for player accounts and mandatory multi-factor authentication for all administrative access to systems containing personal data.
• Role-based access controls ensuring that 42vip staff can only access personal data necessary for their specific job function.
• Regular third-party penetration testing and vulnerability assessments conducted by qualified cybersecurity professionals.
• Automated intrusion detection and real-time monitoring of system logs for suspicious activity.
• Data minimization practices ensuring that only necessary personal data is collected and retained.
• Staff data protection training conducted at onboarding and on a regular ongoing basis.

While 42vip takes all reasonable steps to protect your data, no system connected to the internet can guarantee absolute security. In the event of a personal data breach, 42vip will respond in accordance with the notification obligations described in the Data Privacy Act of 2012 and communicate with affected players promptly.

12 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you hold the following rights with respect to your personal data processed by 42vip:

• Right to be Informed: The right to be notified about how your personal data is collected and processed — fulfilled through this Privacy Policy.
• Right to Access: The right to request a copy of the personal data we hold about you and information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You can update basic account information directly in your account settings.
• Right to Erasure: 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 our legal retention obligations.
• Right to Object: The right to object to processing of your personal data for direct marketing purposes or where processing is based on legitimate interests, in circumstances where your interests override those legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe that 42vip has processed your personal data in violation of the Data Privacy Act of 2012. The NPC can be reached through its official channels at privacy.gov.ph.

To exercise any of these rights, please contact our Data Privacy Officer using the contact details set out in Section 15. 42vip will respond to all data subject rights requests within fifteen (15) business days of receipt, as required by the Implementing Rules and Regulations of the Data Privacy Act.

13 Children's Privacy

The 42vip Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations enforced by PAGCOR. 42vip does not knowingly collect personal data from individuals under the age of 21.

Age verification is performed during account registration, and 42vip reserves the right to request additional age-confirming identity documents at any time. Where 42vip becomes aware that an account has been created by or on behalf of an individual under 21 years of age, the account will be immediately suspended, all associated balances will be held pending investigation, and the matter will be reported to the relevant regulatory authority.

If you are a parent or guardian and believe that a minor has accessed the 42vip Platform and provided personal data to us, please contact our Data Privacy Officer immediately. We will take prompt action to delete the data and close the account.

14 Changes to This Privacy Policy

42vip may update this Privacy Policy from time to time to reflect changes in our data processing practices, new regulatory requirements, or improvements to our privacy programme. Where changes are material, we will provide at least seven (7) days' prior notice by posting the updated Policy on the Platform and notifying registered players via email or in-platform notification.

The current version of this Policy, including the effective date and version number, is always accessible at https://42vip.cam/privacy-policy. We encourage you to review this Policy periodically to stay informed about how we handle your personal data. Your continued use of the Platform after the effective date of any amendment constitutes acknowledgment of the updated Policy.

15 Contact Our Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by 42vip, please contact our Data Privacy Officer through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week through the Platform.
• Email: [email protected] — please include "Data Privacy Request" in the subject line so your message is directed to the DPO team.

Our Data Privacy Officer will acknowledge receipt of your query within two (2) business days and provide a substantive response within fifteen (15) business days. For complex requests (such as large-scale data access requests), we may extend this period by an additional fifteen (15) business days, in which case we will inform you of the extension and the reasons for it.

If you are not satisfied with 42vip's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. The NPC provides guidance, investigates complaints, and enforces the Data Privacy Act of 2012 across the Philippines.