33bmm Privacy Policy

1. Who We Are

This Privacy Policy applies to the 33bmm platform, operated by 33bmm ("the Company," "we," "us," or "our"), accessible at 33bmm.org. 33bmm is an online gaming platform serving players in the Philippines, offering casino games, live dealer tables, slots, bingo, online sabong, and sports betting.

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, 33bmm acts as the Personal Information Controller (PIC) in respect of the personal data collected through the 33bmm platform. We are responsible for ensuring that personal data is processed lawfully, fairly, and transparently.

2. Personal Data We Collect

33bmm collects personal data that is necessary to operate a regulated online gaming platform and to comply with applicable Philippine law and PAGCOR requirements. The categories of personal data we collect include:

We do not collect sensitive personal data as defined under RA 10173 (such as health, genetic, or biometric data) unless specifically required for identity verification under applicable regulatory mandate, in which case we will seek explicit prior consent.

3. How We Collect Your Data

33bmm collects personal data through the following methods:

• Direct registration: Data you voluntarily provide when creating a 33bmm account, including name, mobile number, date of birth, and chosen credentials.
• Account activity: Data generated through your use of the platform, including game play, deposits, withdrawals, and customer support interactions.
• KYC submissions: Identity documents and verification data submitted in response to KYC requirements.
• Payment processors: Transaction reference data passed to 33bmm by GCash, PayMaya, BPI, BDO, and Metrobank during deposit and withdrawal processing.
• Automated technical collection: Cookies, server logs, and device fingerprinting data collected automatically when you access the 33bmm platform.
• Third-party verification providers: Identity verification and AML screening data returned by compliance service providers engaged by 33bmm.

4. Legal Basis for Processing

33bmm processes your personal data on the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

1. Contractual necessity: Processing required to fulfil the 33bmm Terms and Conditions agreement you entered into upon registration, including account management, game delivery, and payment processing.
2. Legal obligation: Processing required to comply with applicable Philippine law, PAGCOR regulatory requirements, AML obligations under Republic Act No. 9160 (Anti-Money Laundering Act) as amended, and other applicable Philippine statutes.
3. Legitimate interests: Processing conducted in the legitimate interests of 33bmm, including fraud prevention, platform security, responsible gaming monitoring, and business analytics — where such interests are not overridden by your data protection rights.
4. Consent: Processing based on your freely given, specific, informed, and explicit consent where required under RA 10173, including for direct marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

5. How We Use Your Personal Data

33bmm uses the personal data we hold about you for the following purposes:

• Creating and managing your 33bmm account and verifying your identity (21+ age verification)
• Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank
• Delivering casino games, live dealer tables, bingo, slots, online sabong, and sports betting services
• Administering bonuses, promotions, and the 33bmm VIP loyalty programme
• Detecting, preventing, and investigating fraud, account abuse, and platform security threats
• Conducting AML screening and fulfilling regulatory reporting obligations under Philippine law
• Operating responsible gaming tools and monitoring accounts for signs of problem gambling
• Providing customer support, resolving disputes, and responding to regulatory enquiries
• Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts) via SMS or the mobile number on your account
• Sending promotional communications where you have provided consent or where permitted under applicable law — you may opt out at any time
• Improving the 33bmm platform through aggregated analytics and performance monitoring

33bmm will not use your personal data for any purpose materially different from those listed above without providing you with prior notice and, where required by law, obtaining your consent.

6. Sharing of Personal Data

6.1 We do not sell your personal data. 33bmm does not sell, rent, or trade your personal information to third parties for their own marketing purposes.

6.2 Service Providers. We share personal data with carefully selected third-party service providers who process data on 33bmm's behalf under contractual data processing agreements, including: payment processors (GCash/PayMaya/banks), KYC and identity verification providers, game software providers, fraud detection and AML screening services, and cloud infrastructure providers. All such providers are bound by appropriate data protection obligations.

6.3 Regulatory Disclosure. 33bmm may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), Philippine law enforcement agencies, or other competent authorities where required by law, court order, or regulatory direction.

6.4 Business Transfers. In the event of a merger, acquisition, or sale of all or part of 33bmm's business, personal data held by 33bmm may be transferred to the relevant acquiring entity, subject to equivalent data protection commitments.

7. Data Retention

33bmm retains personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable law and regulatory obligations. Our general retention periods are as follows:

• 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 PAGCOR and AML regulatory requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required under Philippine AML legislation.
• Gaming session logs: Retained for a minimum of two (2) years for platform integrity and dispute resolution purposes.
• Customer support communications: Retained for two (2) years from the date of the communication or resolution of the relevant matter.
• Technical and security logs: Retained for twelve (12) months unless a security investigation requires longer retention.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 33bmm's data disposal procedures.

8. Security Measures

33bmm implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption for all data in transit between your device and the 33bmm platform
• Encryption at rest for sensitive personal data and financial information stored on 33bmm servers
• Multi-factor authentication (OTP via registered Philippine mobile number) for account access
• Role-based access controls limiting internal staff access to personal data on a need-to-know basis
• Regular penetration testing and vulnerability assessments of platform infrastructure
• Incident response procedures aligned with RA 10173 notification requirements

In the event of a personal data breach that is likely to result in serious harm to your rights, 33bmm will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with NPC Circular No. 16-03.

9. Cookies and Tracking Technologies

33bmm uses cookies and similar tracking technologies to deliver and improve the platform experience. The following types of cookies are used:

• Strictly necessary cookies: Essential for platform functionality including session management, login authentication, and security features. These cannot be disabled without significantly impairing platform functionality.
• Performance cookies: Used to collect aggregated, anonymised information about how users interact with the 33bmm platform, including page load times and navigation patterns, to improve platform performance.
• Functional cookies: Used to remember your preferences such as language settings, preferred game category, and responsible gaming tool configurations.
• Analytics cookies: Used with first-party analytics tools to understand traffic patterns and platform usage — this data is aggregated and not used for individual profiling.

You may control cookie preferences through your browser settings. Disabling certain non-essential cookies may affect your 33bmm platform experience. 33bmm does not use third-party advertising or cross-site tracking cookies.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by 33bmm:

• Right to be informed: The right to know how your personal data is being collected and processed — this Privacy Policy fulfils that obligation.
• Right of access: The right to request a copy of the personal data 33bmm holds about you.
• Right to rectification: The right to have inaccurate personal data corrected or incomplete data completed.
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations and contractual requirements.
• 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.
• Right to data portability: The right to receive a structured, machine-readable copy of personal data you have provided to 33bmm.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, contact the 33bmm Data Protection Officer via Live Chat support or at [email protected]. We will respond to verified requests within the timeframes prescribed by RA 10173 and NPC regulations.

11. Children's Privacy

The 33bmm platform is strictly intended for individuals aged 21 years and older. 33bmm does not knowingly collect personal data from any person under the age of 21. Age verification is enforced at the point of registration and at the point of withdrawal through document-based KYC procedures.

If 33bmm becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, all associated data will be reviewed, and personal data belonging to the minor will be deleted in accordance with NPC guidance on the processing of personal data of children under applicable Philippine law.

If you believe a person under the age of 21 has registered a 33bmm account, please notify us immediately via Live Chat or at [email protected].

12. Cross-Border Data Transfers

In the course of providing the 33bmm platform, your personal data may be transferred to and processed in countries other than the Philippines, including countries where game software providers or cloud infrastructure providers are domiciled.

Where such transfers occur, 33bmm ensures that equivalent data protection safeguards are in place through contractual arrangements, including standard contractual clauses or equivalent measures that meet the standards required by the National Privacy Commission under RA 10173 and NPC Circular No. 17-01.

33bmm does not transfer personal data to jurisdictions unless appropriate safeguards are in place. You may request further information about cross-border transfer mechanisms applicable to your personal data by contacting our DPO.

13. Changes to This Privacy Policy

33bmm reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, platform services, applicable law, or regulatory requirements. Material changes will be communicated to registered 33bmm account holders via the mobile number or contact details on their account prior to the effective date of the change.

The current version of this Privacy Policy is always accessible at 33bmm.org/privacy-policy. The "Last Updated" date at the top of this document reflects the date of the most recent revision. Continued use of the 33bmm platform after the effective date of any update constitutes acceptance of the revised Privacy Policy.

14. Contact and Data Protection Officer

33bmm has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and with the Philippine Data Privacy Act of 2012. For all privacy-related enquiries, data subject access requests, or complaints, please contact:

• Data Protection Officer, 33bmm
• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 within the 33bmm platform — select "Privacy / Data Request" from the support topic menu

We are committed to resolving all data privacy enquiries and complaints promptly, fairly, and in full compliance with RA 10173 and the implementing rules of the National Privacy Commission. If you are not satisfied with our response, you have the right to lodge a formal complaint with the NPC.