Privacy Policy

1. Introduction

phwin.com ("phwin.com," "we," "us," or "our") is committed to protecting the privacy and personal data of all users who access or use our online gaming platform at phwincom.org (the "Platform"). This Privacy Policy describes how we collect, use, store, share, and protect your personal information in connection with your use of the Platform and our associated services.

This Privacy Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations (IRR), as administered by the National Privacy Commission (NPC). By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

If you do not agree with any part of this Privacy Policy, you must discontinue use of the Platform immediately. This policy should be read alongside our Terms & Conditions.

2. Data Controller Information

The data controller responsible for your personal information collected through phwin.com is the operating entity behind the phwin.com Platform. For all privacy-related inquiries, requests, and complaints, you may contact our designated Data Protection Officer (DPO) using the contact details provided in Section 15 of this policy.

3. Information We Collect

phwin.com collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

3.1 Identity and Registration Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (to verify you are 21 years of age or older);
• Gender;
• Nationality and country of residence;
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license).

3.2 Contact Data

• Email address;
• Mobile phone number;
• Residential address (barangay, city/municipality, province, ZIP code).

3.3 Financial Data

• GCash or PayMaya (Maya) account details used for deposits and withdrawals;
• Bank account details (bank name, account number) for bank transfer transactions;
• Transaction history including deposit amounts, withdrawal amounts, and dates;
• Debit card details where applicable.

3.4 Account and Gaming Data

• Username and encrypted password;
• Gaming history, wager amounts, game preferences, and session durations;
• Bonus and promotion usage history;
• Responsible gaming settings and self-exclusion records.

3.5 Technical and Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Cookies and session identifiers;
• Log data including access times, pages visited, and error reports.

3.6 Communications Data

• Records of your communications with phwin.com customer support;
• Feedback, survey responses, and complaints submitted to us.

4. How We Collect Your Data

phwin.com collects your personal data through the following means:

• Directly from you — when you register an account, complete identity verification, make a deposit or withdrawal, contact support, or participate in promotions;
• Automatically — through cookies, web beacons, and server logs when you browse or use the Platform;
• From third parties — including payment processors (e.g., GCash, Maya, banks), identity verification service providers, and fraud prevention partners, where necessary to verify your identity or process transactions;
• From regulatory bodies — where required by PAGCOR or other competent Philippine authorities.

5. How We Use Your Information

phwin.com processes your personal data for the following purposes:

Purpose	Description
Account Management	To create, maintain, and manage your phwin.com player account.
Identity Verification	To verify your age (21+) and identity in compliance with PAGCOR and AML regulations.
Payment Processing	To process deposits and withdrawals via GCash, Maya, and Philippine bank transfers.
Regulatory Compliance	To comply with anti-money laundering (AML), know-your-customer (KYC), and PAGCOR reporting obligations.
Customer Support	To respond to your inquiries, resolve disputes, and provide technical assistance.
Responsible Gaming	To monitor gaming behavior and enforce responsible gaming tools including deposit limits and self-exclusion.
Platform Improvement	To analyze usage patterns and improve the functionality, security, and content of the Platform.
Marketing	To send you promotional offers and updates about phwin.com, subject to your marketing preferences.
Fraud Prevention	To detect, investigate, and prevent fraudulent activity, cheating, and money laundering.

6. Legal Bases for Processing

Under the Data Privacy Act of 2012, phwin.com processes your personal data on the following legal bases:

• Consent — where you have given explicit consent, such as for marketing communications;
• Contractual necessity — where processing is necessary to perform our obligations under the Terms & Conditions you have agreed to;
• Legal obligation — where processing is required to comply with applicable Philippine laws, including AML regulations and PAGCOR licensing requirements;
• Legitimate interests — where processing is necessary for our legitimate business interests, such as fraud prevention and platform security, provided these interests are not overridden by your rights.

7. Sharing and Disclosure of Data

phwin.com does not sell your personal data. We may share your information with the following categories of recipients only where necessary and lawful:

• Payment service providers — GCash, PayMaya (Maya), and Philippine banks, for the purpose of processing your financial transactions;
• Identity verification providers — third-party KYC service providers engaged to verify your identity documents;
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government bodies, where required by law;
• IT and security service providers — cloud hosting, cybersecurity, and fraud detection partners who process data on our behalf under strict data processing agreements;
• Legal and professional advisors — lawyers, auditors, and compliance consultants, subject to professional confidentiality obligations;
• Law enforcement — where we are legally compelled to disclose information in response to a valid court order, subpoena, or government request.

All third parties with whom phwin.com shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and our contractual requirements.

8. Data Retention

phwin.com retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with AML and PAGCOR record-keeping requirements;
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Customer support communications are retained for three (3) years from the date of the interaction;
• Marketing consent records are retained until you withdraw consent or for three (3) years from the last interaction, whichever is earlier.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

9. Data Security

phwin.com implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data in transit;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in harm to affected individuals, phwin.com will notify the National Privacy Commission and affected data subjects in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

10. Cookies and Tracking Technologies

phwin.com uses cookies and similar tracking technologies to enhance your experience on the Platform. The types of cookies we use are as follows:

• Strictly necessary cookies — essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies — remember your preferences such as language settings and game display options.
• Analytics cookies — collect anonymized data about how users interact with the Platform to help us improve performance and content.
• Marketing cookies — used to deliver relevant promotional content based on your interests and browsing behavior on the Platform.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

11. Your Rights Under Philippine Law

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phwin.com:

• Right to be informed — you have the right to be informed of how your personal data is being collected and processed;
• Right of access — you may request a copy of the personal data we hold about you;
• Right to rectification — you may request correction of inaccurate or incomplete personal data;
• Right to erasure — you may 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 — you may object to the processing of your personal data for direct marketing purposes at any time;
• Right to data portability — you may request a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint — you have the right to file a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified requests within thirty (30) days in accordance with NPC guidelines.

12. Children and Minors

phwin.com is strictly an adult platform. We do not knowingly collect personal data from individuals under the age of 21 years. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on phwin.com, please contact us immediately at the details provided in Section 15.

13. International Data Transfers

Where phwin.com transfers personal data outside the Philippines — for example, to cloud infrastructure providers or technology partners located in other countries — we ensure that such transfers are carried out in compliance with the Data Privacy Act of 2012. This includes implementing appropriate safeguards such as contractual clauses that require the recipient to protect your personal data to a standard equivalent to Philippine law.

14. Changes to This Policy

phwin.com reserves the right to update or amend this Privacy Policy at any time. When we make material changes, we will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect. The "Last Updated" date at the top of this policy will always reflect the most recent revision. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

15. Contact and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by phwin.com, please contact our Data Protection Officer:

Data Protection Officer — phwin.com

Email: privacy@phwincom.org

This email address is displayed as plain text for informational purposes only and is not a clickable link.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph (please type this address manually into your browser).