Privacy Policy

1.1 This Privacy Policy ("Policy") describes how phwin1 ("phwin1," "we," "us," "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," "Player") who access or use the phwin1 platform at phwin1.app and any associated mobile applications (collectively, the "Platform").

1.2 phwin1 is committed to protecting your privacy and handling your personal data in a transparent, lawful, and responsible manner. This Policy is drafted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the data governance requirements of PAGCOR.

1.3 By registering an account, accessing the Platform, or otherwise providing your personal information to phwin1, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

1.4 If you do not agree with any part of this Policy, you should discontinue use of the Platform and may request closure of your account in accordance with our Terms & Conditions.

2.1 phwin1 collects the following categories of personal data, depending on how you interact with the Platform:

2.2 Sensitive Personal Information. Where required for identity verification or responsible gaming purposes, phwin1 may collect sensitive personal information as defined under the Philippine Data Privacy Act, including government ID numbers and financial account details. Such data is handled with heightened security controls and is accessed only by authorised personnel on a strict need-to-know basis.

3.1 phwin1 collects personal data through the following means:

• Direct Interactions: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or participating in promotions.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment data from GCash, Maya, and banking partners; and publicly available information where relevant to fraud prevention or regulatory compliance.
• Regulatory Sources: Information shared by PAGCOR or other regulatory bodies in connection with licensing, compliance, or investigation requirements.

4.1 phwin1 uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your phwin1 player account, including processing your registration and verifying your identity.
• Service Delivery: To provide access to games, process deposits and withdrawals, award bonuses, and deliver the full range of phwin1 Platform features.
• Legal & Regulatory Compliance: To comply with PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, the Philippine Data Privacy Act, and other applicable laws and regulations.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other security threats.
• Responsible Gaming: To monitor gaming behaviour, identify players who may be at risk, and administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where permitted by applicable law. You may opt out at any time.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the performance, features, and user experience of the phwin1 Platform.

5.1 phwin1 processes your personal data on the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform our contract with you, including operating your account, processing transactions, and delivering gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including PAGCOR licensing conditions, AMLA reporting obligations, and tax requirements.
• Legitimate Interests: Processing necessary for phwin1's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly in relation to marketing communications and the use of non-essential cookies.

6.1 phwin1 does not sell, rent, or trade your personal data to third-party marketers. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other government bodies where required by law or regulatory directive.
• Payment Service Providers: GCash, Maya, and banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals.
• Identity Verification Partners: KYC and age verification service providers engaged to assist with player identity checks.
• Fraud Prevention Services: Third-party fraud screening and anti-money laundering service providers.
• Technology Partners: Cloud hosting providers, platform infrastructure partners, and game software providers who process data on phwin1's behalf under strict data processing agreements.
• Professional Advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.
• Law Enforcement: Philippine law enforcement agencies where phwin1 is legally required or reasonably believes disclosure is necessary to prevent or investigate criminal activity.

6.2 All third parties with whom phwin1 shares personal data are required to handle such data in accordance with applicable privacy laws and phwin1's data protection standards.

7.1 phwin1 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather analytics data. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymised data about how players use the Platform, helping us identify areas for improvement. These are only set with your consent.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to personalise your experience.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your explicit consent and can be withdrawn at any time.

7.2 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phwin1 Platform.

8.1 phwin1 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC & Identity Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer Support Records: Retained for three (3) years from the date of the interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing Data: Retained until you withdraw consent or opt out of marketing communications, after which it is deleted or anonymised.

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with phwin1's data disposal procedures.

9.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phwin1:

10.1 The phwin1 Platform is strictly intended for individuals who are twenty-one (21) years of age or older, in accordance with Philippine gaming regulations. phwin1 does not knowingly collect personal data from individuals under the age of 21.

10.2 If phwin1 becomes aware that personal data has been collected from a person under the age of 21, it will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the phwin1 Platform, please contact our support team immediately.

10.3 phwin1 employs age verification procedures during the registration process and reserves the right to request documentary proof of age at any time.

11.1 phwin1 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and phwin1 servers;
• Encryption of sensitive data at rest, including financial account details and identity documents;
• Multi-factor authentication options for player accounts;
• Role-based access controls limiting data access to authorised personnel only;
• Regular security audits, vulnerability assessments, and penetration testing;
• Intrusion detection and prevention systems monitoring for suspicious activity;
• Comprehensive staff training on data protection and information security practices.

11.2 While phwin1 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. phwin1 cannot guarantee absolute security but is committed to promptly addressing any security incidents that may arise.

11.3 You are responsible for maintaining the security of your phwin1 account credentials. phwin1 recommends using a strong, unique password and enabling any available multi-factor authentication features.

12.1 The phwin1 Platform may contain references to third-party services, such as payment providers and game software suppliers. phwin1 is not responsible for the privacy practices of these third parties, and this Policy does not apply to their data collection activities.

12.2 phwin1 encourages you to review the privacy policies of any third-party services you interact with in connection with your use of the Platform. phwin1 selects its third-party partners carefully and requires them to maintain data protection standards consistent with applicable Philippine law.

13.1 phwin1 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

13.2 Where changes to this Policy are material, phwin1 will notify registered players via email or an in-platform notification prior to the changes taking effect. Your continued use of the phwin1 Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

13.3 We encourage you to review this Policy periodically to stay informed about how phwin1 protects your personal information.

14.1 phwin1 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection laws. If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact:

• Data Protection Officer, phwin1
• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 through the phwin1 Platform

14.2 phwin1 will acknowledge receipt of your request within five (5) business days and will endeavour to resolve all privacy-related enquiries within thirty (30) days.

14.3 If you are not satisfied with phwin1's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.