1 Scope and Data Controller
This Privacy Policy applies to all personal data collected, processed, stored, and used by 33bmm in connection with the online casino and sports betting platform operated at 33bmm.vip, including all associated mobile-accessible interfaces, customer support channels, and promotional communications.
For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, 33bmm is the personal information controller responsible for determining the means and purposes of processing personal data obtained through your use of the Platform.
This Privacy Policy should be read in conjunction with the 33bmm Terms & Conditions. Defined terms used here carry the same meaning as in the Terms & Conditions unless otherwise stated.
By registering an account on 33bmm or continuing to use the Platform after the effective date of this Policy, you acknowledge that you have read and understood how 33bmm handles your personal data as described below. If you do not agree with any aspect of this Policy, you should not create or continue to use a 33bmm account.
2 Personal Data We Collect
33bmm collects personal data from you directly, automatically through your use of the Platform, and in certain cases from third parties such as payment processors and identity verification providers. The categories of personal data collected include:
2.1 Identity and Contact Data
- Full legal name as it appears on your government-issued identification;
- Date of birth (used to verify compliance with the 21+ age requirement);
- Residential address, including barangay, city, province, and ZIP code;
- Philippine mobile number registered to your account;
- Email address, where provided during registration or support contact.
2.2 Financial and Transaction Data
- GCash mobile number and relevant account identifiers for deposit and withdrawal processing;
- PayMaya account details where used as a payment method;
- BPI, BDO, Metrobank, or other bank account details submitted for withdrawal purposes;
- Complete transaction history including deposits, withdrawals, bets placed, game results, and bonus activations;
- Source of funds declarations submitted in connection with KYC or AMLA compliance obligations.
2.3 Identity Verification Documents
- Copies of government-issued photo identification (e.g., Philippine National ID, SSS, GSIS, driver's license, or passport);
- Proof of address documentation where required for enhanced due diligence;
- Selfie or liveness check images submitted during KYC verification processes.
2.4 Technical and Device Data
- IP address at the time of login and during active sessions;
- Device type, operating system, and browser identifier;
- Session timestamps, page interaction data, and game play logs;
- Geolocation data at the point of login, where permitted by your device settings.
2.5 Communications Data
- Content of customer support enquiries submitted via live chat or email;
- Records of notifications sent to your registered contact details;
- Feedback, complaint, or dispute correspondence submitted to 33bmm.
| Data Category | Examples | Collected At |
|---|---|---|
| Identity & Contact | Name, DOB, mobile, address | Registration |
| Financial | GCash number, bank details, transactions | Deposit / withdrawal |
| KYC Documents | Gov't ID, proof of address, selfie | Verification steps |
| Technical | IP address, device, session data | Continuous use |
| Communications | Support chats, emails | Contact with support |
3 Lawful Basis for Processing
33bmm processes your personal data on the following lawful bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:
Contractual Necessity
Processing required to create and maintain your 33bmm account, execute deposits and withdrawals, settle bets and game outcomes, and deliver the core services you have contracted for under the Terms & Conditions.
Legal Obligation
Processing required to comply with the Anti-Money Laundering Act of 2001 (RA 9160 as amended), PAGCOR regulatory reporting requirements, the Cybercrime Prevention Act of 2012 (RA 10175), and other applicable Philippine statutes that impose mandatory data retention or disclosure obligations on 33bmm.
Legitimate Interests
Processing carried out in pursuit of 33bmm's legitimate interests in fraud prevention, platform security, responsible gaming enforcement, and improvement of service quality — provided these interests are not overridden by your fundamental rights and freedoms.
Consent
Processing of personal data for direct marketing communications (such as bonus offers and promotional emails) is undertaken only where you have given clear, freely given, specific, and informed consent. You may withdraw marketing consent at any time without affecting the lawfulness of prior processing.
4 How 33bmm Uses Your Personal Data
33bmm uses the personal data collected from you for the following specific purposes:
- Account administration: Creating, maintaining, and managing your 33bmm account, processing login authentication, and applying account settings preferences;
- Transaction processing: Receiving GCash and bank deposits, processing withdrawal requests to your registered payment accounts, and maintaining accurate transaction records in Philippine Peso;
- Identity and age verification: Confirming that you meet the 21+ age requirement and that your identity matches the registered account information, in compliance with PAGCOR and AMLA obligations;
- Fraud detection and prevention: Monitoring account activity for patterns indicative of identity fraud, money laundering, bonus abuse, collusion, or other prohibited conduct as defined in the Terms & Conditions;
- Responsible gaming: Monitoring play patterns to identify potentially problematic gambling behaviour, enforcing deposit limits and self-exclusion requests, and facilitating access to responsible gaming tools within your account dashboard;
- Customer support: Responding to queries, processing complaints, and resolving disputes relating to your 33bmm account or game outcomes;
- Regulatory compliance: Fulfilling mandatory reporting obligations to PAGCOR and the Anti-Money Laundering Council (AMLC) as required by Philippine law;
- Platform improvement: Analysing aggregated, anonymised usage data to improve game performance, user interface design, and the overall 33bmm player experience;
- Marketing communications: Sending promotional offers, bonus notifications, and platform updates to your registered contact details where you have provided and not withdrawn consent.
33bmm will not use your personal data for any purpose materially different from those listed above without providing prior notice and, where required by law, obtaining your fresh consent.
5 Data Sharing and Disclosure
33bmm does not sell, rent, or trade your personal data to third parties for commercial or marketing purposes. However, your personal data may be shared with the following categories of recipients, strictly to the extent necessary for the purposes described in this Policy:
5.1 Payment Processors
GCash (Mynt — Globe Fintech Innovations), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and other authorised payment service providers receive transaction data necessary to process deposits and withdrawals. These providers operate under their own data privacy policies and are regulated by the Bangko Sentral ng Pilipinas (BSP).
5.2 Identity Verification Providers
Third-party KYC and identity verification platforms may receive copies of government-issued identification documents and liveness check data for the purpose of verifying your identity in compliance with PAGCOR and AMLA requirements. Such providers are contractually bound to process data only for verification purposes and to maintain appropriate security standards.
5.3 Regulatory Authorities
33bmm is legally required to disclose certain player data to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities upon lawful request or as part of mandatory regulatory reporting. Such disclosures are made strictly within the scope of the legal obligation concerned.
5.4 Game Content Providers
Third-party game studios and platform providers (such as JILI, Pragmatic Play, and PG Soft) may receive technical session data — including anonymised player identifiers and game result logs — for the purposes of game performance monitoring, RNG certification auditing, and dispute resolution. These providers do not receive personally identifiable registration data.
5.5 Legal and Security Purposes
33bmm may disclose your personal data to law enforcement agencies, courts, or other authorities where such disclosure is required by a valid legal process under Philippine law, or where 33bmm reasonably believes disclosure is necessary to prevent fraud, protect the security of the Platform, or enforce the Terms & Conditions.
All third parties with whom 33bmm shares personal data are required to process that data only for the specified purpose, to maintain appropriate technical and organisational security measures, and to comply with applicable Philippine data privacy law.
6 Cookies and Technical Tracking
33bmm uses cookies and similar web technologies on the Platform. These are small text files or data identifiers placed on your device by your browser when you access the site. The types of cookies used by 33bmm include:
- Strictly Necessary Cookies: Required for the Platform to function — maintaining your login session, securing form submissions, and preserving account settings. These cannot be disabled without affecting core functionality.
- Performance and Analytics Cookies: Used to collect anonymised data about how players navigate the Platform, which pages are visited most frequently, and where technical errors occur. This data is used to improve Platform performance and user experience.
- Responsible Gaming Cookies: Used to track session duration and trigger in-session responsible gaming reminders where applicable account limits are set.
- Functionality Cookies: Used to remember user preferences such as language settings and game display preferences across sessions.
You can manage cookie settings through your browser's privacy controls. Disabling non-essential cookies will not affect your ability to access 33bmm services, though some functionality preferences may not be retained between sessions.
7 Data Retention
33bmm retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:
| Data Type | Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of account + 5 years post-closure | AMLA / PAGCOR compliance |
| Financial transaction records | 10 years from transaction date | RA 9160 (AMLA) obligation |
| KYC / identity documents | Duration of account + 5 years post-closure | AMLA / PAGCOR compliance |
| Customer support correspondence | 3 years from last interaction | Dispute resolution / legal |
| Technical / session logs | 12 months rolling | Security and fraud prevention |
| Marketing consent records | Until consent withdrawn + 2 years | Consent / legal evidence |
Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be linked to an identifiable individual, unless a specific legal obligation requires extended retention.
8 Data Security Measures
33bmm implements technical and organisational security measures appropriate to the risks associated with processing personal data in an online gaming context. These measures include, but are not limited to:
- Transport Layer Security (TLS) encryption for all data in transit between your device and 33bmm servers;
- Encryption at rest for sensitive personal and financial data stored in 33bmm's database infrastructure;
- Role-based access controls ensuring that personal data is accessible only to 33bmm personnel with a legitimate operational need;
- Multi-factor authentication requirements for administrative access to systems holding personal data;
- Brute-force login attempt detection and automatic account lockout mechanisms on all Player accounts;
- Regular security assessments and vulnerability reviews of Platform infrastructure;
- Incident response procedures designed to detect, contain, and notify data breaches in accordance with RA 10173 requirements.
In the event of a personal data breach that poses a real risk of harm to affected Players, 33bmm will notify both the National Privacy Commission (NPC) and affected individuals within the timeframes required by RA 10173 and its Implementing Rules and Regulations.
While 33bmm takes all reasonable steps to protect your personal data, no internet-based transmission or electronic storage system is completely secure. Players are encouraged to use strong, unique passwords for their 33bmm accounts and to report any suspected security incidents to support immediately.
9 Exercising Your Data Subject Rights
Under the Data Privacy Act of 2012, you have the following rights with respect to the personal data 33bmm holds about you:
- Right to be Informed: The right to know what personal data 33bmm collects and how it is used — fulfilled by this Privacy Policy and any updates to it;
- Right to Access: The right to obtain confirmation of whether 33bmm holds personal data about you and to receive a copy of that data in a readily usable format;
- Right to Rectification: The right to have inaccurate or incomplete personal data corrected without undue delay;
- Right to Erasure: The right to request deletion of personal data that is no longer necessary for the purposes for which it was collected, subject to any overriding legal retention obligations;
- Right to Object: The right to object to processing based on legitimate interests, including profiling for direct marketing purposes;
- Right to Data Portability: The right to receive personal data you have provided to 33bmm in a structured, commonly used, and machine-readable format;
- Right to Damages: The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of personal data.
To exercise any of the above rights, please contact 33bmm's Data Privacy Officer (see Section 14). 33bmm will respond to verified data subject requests within thirty (30) calendar days of receipt. Complex requests may require up to an additional thirty (30) days, in which case you will be notified of the extended timeline and the reason for it.
33bmm will not charge a fee for handling data subject rights requests submitted in good faith. Requests that are manifestly unfounded or excessive may be declined with written reasons, or may attract a reasonable administrative fee in accordance with NPC guidelines.
10 Minors and Age Restrictions
33bmm does not knowingly collect personal data from individuals below the age of 21 years. Access to 33bmm is strictly prohibited for persons under 21, in compliance with PAGCOR regulations and Philippine gambling law.
Age verification is conducted at registration and may be re-verified at elevated financial thresholds or where account review identifies a potential eligibility concern. Any account found to have been registered by a person under 21 years of age will be immediately closed, and all funds associated with that account will be dealt with in accordance with applicable law.
If 33bmm becomes aware that personal data has been inadvertently collected from an individual below the 21-year threshold, that data will be deleted promptly upon discovery. Parents or guardians who believe a minor may have accessed 33bmm should contact our support team immediately.
11 Third-Party Services and Links
The 33bmm Platform incorporates third-party game content provided by licensed game studios. These studios operate their own data processing systems for game outcome generation, RNG certification, and internal quality assurance. 33bmm does not control the data practices of these third-party providers and recommends that you review their privacy policies where relevant.
33bmm does not include links to external third-party websites on the Platform. If you independently access any external site through typing a URL or through a channel other than 33bmm.vip, 33bmm accepts no responsibility for the privacy practices of those external sites.
12 Cross-Border Data Transfers
33bmm primarily processes personal data within the Philippines or through service providers operating within Philippine jurisdiction. Where technical infrastructure or third-party service providers result in personal data being processed outside the Philippines, 33bmm ensures that appropriate safeguards are in place to protect your personal data at a standard equivalent to that required by the Data Privacy Act of 2012.
Such safeguards may include contractual clauses between 33bmm and the receiving processor that impose obligations equivalent to those under RA 10173, or reliance on the recipient jurisdiction's adequacy recognition under applicable frameworks. 33bmm does not transfer personal data to jurisdictions without adequate data protection standards in the absence of such contractual safeguards.
13 Changes to This Privacy Policy
33bmm reserves the right to amend this Privacy Policy at any time to reflect changes in legal requirements, regulatory guidance, or 33bmm's data processing practices. Material changes — those affecting the nature of data collected, the purposes for which it is used, or the rights you hold — will be communicated to you via notification to your registered mobile number or email address no less than seven (7) calendar days before the effective date of the change.
The effective date of the current version of this Privacy Policy is displayed at the top of this page. Your continued use of the 33bmm Platform after a change takes effect constitutes your acceptance of the updated Privacy Policy. If you do not accept the changes, you should request account closure before the effective date.
We encourage all 33bmm players to review this Privacy Policy periodically to remain aware of how their personal data is handled. If you have questions about any change to this Policy, please contact our Data Privacy Officer before the effective date.
14 Contact and Data Privacy Officer
For all enquiries, requests, or complaints relating to 33bmm's processing of your personal data — including the exercise of your data subject rights under the Data Privacy Act of 2012 — please contact 33bmm's designated Data Privacy Officer through the following channels:
Email — Data Privacy Officer
[email protected]
Please use the subject line "Data Privacy Request — [Your Username]" to ensure your message is routed to the Data Privacy Officer promptly.
Live Chat — Account Support
Available 24/7 from within your logged-in 33bmm account dashboard. Live chat agents can log and escalate data privacy requests to the Data Privacy Officer. Initial acknowledgement of privacy requests received via live chat will be provided within two (2) business days.
If you are not satisfied with 33bmm's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the independent supervisory authority responsible for overseeing compliance with the Data Privacy Act of 2012.
National Privacy Commission (Philippines)
The NPC may be contacted through its official website at privacy.gov.ph. 33bmm fully cooperates with NPC investigations and inquiries in relation to data subject complaints.