pwinh Privacy Policy

1. Who We Are

pwinh ("pwinh", "we", "us", "our") operates the online casino and sports betting platform accessible at pwinh.net. pwinh serves Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond. As the operator of the pwinh platform, pwinh acts as the data controller in respect of all personal data collected from registered players and website visitors.

pwinh is committed to complying with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. This Privacy Policy sets out the basis on which any personal data collected from you — or that you provide to us — will be processed by pwinh.

2. Personal Data We Collect

pwinh collects the following categories of personal data, depending on how you interact with the platform:

2.1 Account Registration Data

• Full legal name
• Date of birth (for age verification — players must be 21 or older)
• Email address
• Mobile number (Philippine-registered)
• Username and encrypted password
• Residential address

2.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine passport, UMID, SSS ID, driver's licence, PhilSys ID)
• Proof of address documentation
• Selfie or liveness check images where required
• Source of funds documentation where required for high-value transactions

2.3 Financial Data

• Payment method details (e.g., GCash account number, PayMaya account, bank account details for BPI, BDO, Metrobank)
• Deposit and withdrawal transaction history
• Account balance and wagering history

2.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration and login timestamps
• Pages visited and features used on the pwinh platform
• Game play history and wagering patterns

2.5 Communications Data

• Records of live chat conversations with pwinh support
• Email correspondence with the pwinh team
• Survey responses and feedback submissions

Data Category	Examples	Purpose
Registration	Name, email, DOB, mobile	Account creation, identity verification
KYC Documents	Gov't ID, proof of address	Regulatory compliance, fraud prevention
Financial	GCash / BPI details, transactions	Payment processing, AML compliance
Technical	IP address, device, session data	Security, platform improvement
Communications	Chat logs, email records	Customer support, dispute resolution

3. How We Collect Your Data

pwinh collects personal data through the following means:

• Direct provision by you — when you register a pwinh account, complete identity verification, make a deposit or withdrawal, contact support, or respond to a survey;
• Automated collection — through cookies, web beacons, and similar tracking technologies as you browse and use the pwinh platform (see Section 7 for full details);
• Third-party sources — from identity verification service providers, payment processors, fraud prevention services, and, where applicable, public databases used for KYC and anti-money laundering (AML) compliance checks.

4. How We Use Your Personal Data

pwinh uses the personal data we collect for the following purposes:

1. Account management — creating, maintaining, and securing your pwinh player account;
2. Identity and age verification — confirming that all players are 21 years of age or older as required under Philippine gaming regulations;
3. Payment processing — facilitating deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods in Philippine Peso;
4. Regulatory and legal compliance — meeting our obligations under PAGCOR guidelines, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act;
5. Fraud prevention and security — detecting, investigating, and preventing fraudulent activity, unauthorised account access, and abuse of promotional offers;
6. Responsible gaming — monitoring gaming behaviour to identify potential problem gambling indicators and enabling player-controlled tools such as deposit limits and self-exclusion;
7. Customer support — responding to your enquiries, resolving disputes, and improving our service quality;
8. Platform improvement — analysing aggregated usage data to improve game offerings, site performance, and user experience;
9. Marketing communications — sending you promotional offers, bonus notifications, and pwinh news, where you have opted in to receive such communications. You may opt out at any time.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act (RA 10173), pwinh processes your personal data on the following legal bases:

• Consent — for marketing communications and non-essential cookies, where you have provided clear, affirmative consent;
• Contractual necessity — for data processing required to create and maintain your pwinh account and fulfil our obligations to you as a player;
• Legal obligation — for data processing required to comply with PAGCOR regulations, AMLA requirements, and NPC directives;
• Legitimate interests — for fraud prevention, security monitoring, and platform analytics, where our legitimate interests do not override your fundamental rights and freedoms.

6. Sharing Your Personal Data

pwinh does not sell your personal data. We may share your data with the following categories of recipients only where necessary and with appropriate safeguards in place:

6.1 Service Providers

pwinh engages trusted third-party service providers to support the delivery of our platform, including identity verification services, payment processors (including GCash and PayMaya operators), cloud hosting providers, fraud detection services, and customer support technology providers. These providers process data only on pwinh's instructions and are bound by data processing agreements.

6.2 Regulatory and Law Enforcement Authorities

pwinh may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent authorities where required by law, court order, or regulatory direction. Such disclosures are made only to the extent required and in accordance with applicable legal procedures.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a substantial portion of pwinh's assets, your personal data may be transferred to the acquiring entity. You will be notified in advance of any such transfer and your rights under this Privacy Policy will be maintained.

7. Cookies & Tracking Technologies

pwinh uses cookies and similar tracking technologies on the pwinh platform to provide core functionality, improve user experience, and analyse usage patterns. The following types of cookies may be used:

• Essential cookies — required for the platform to function, including session management, login state, and security tokens. These cannot be disabled without affecting core functionality.
• Analytics cookies — used to collect aggregated, anonymised data about how players navigate the pwinh platform, which helps us identify areas for improvement.
• Preference cookies — used to remember your language, display settings, and other personalisation choices.
• Marketing cookies — used, where you have consented, to deliver relevant promotional content and measure the effectiveness of pwinh's marketing activities.

You may manage your cookie preferences at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the pwinh platform. For more information on managing cookies in your browser, refer to your browser's help documentation.

8. Data Security

pwinh implements a comprehensive set of technical and organisational measures to protect your personal data, including:

• SSL/TLS encryption for all data transmitted between your device and the pwinh platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular vulnerability assessments and penetration testing by qualified security professionals;
• Two-factor authentication options available for all pwinh player accounts;
• Incident response procedures ensuring prompt action and notification in the event of a data breach.

9. Data Retention

pwinh retains personal data for the following periods, after which data is securely deleted or fully anonymised:

• Account and KYC data — retained for the duration of your active pwinh account plus a minimum of five (5) years following account closure, as required by AMLA and PAGCOR regulations;
• Financial transaction records — retained for a minimum of five (5) years in compliance with applicable financial record-keeping regulations;
• Customer support communications — retained for three (3) years following the resolution of the relevant interaction;
• Technical and usage data — retained for up to twenty-four (24) months, after which it is aggregated and anonymised for analytical purposes;
• Marketing consent records — retained for the duration of your consent plus two (2) years, to demonstrate compliance with consent requirements.

Where pwinh is required by law or regulation to retain data for longer periods, those legal requirements will take precedence over the standard retention periods above.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act (RA 10173), you have the following rights in respect of your personal data held by pwinh. To exercise any of these rights, contact pwinh's Data Privacy Officer using the details in Section 14.

11. Children's Privacy

pwinh is strictly an adult platform. The minimum age to register and use pwinh is 21 years old, in line with PAGCOR regulatory requirements for casino-style gaming in the Philippines. pwinh does not knowingly collect personal data from individuals under the age of 21. If pwinh becomes aware that a registered account belongs to a person under 21 years of age, that account will be immediately closed and all associated data reviewed and handled in accordance with applicable law. If you believe a minor has registered on pwinh, please notify us immediately at [email protected].

12. Cross-Border Data Transfers

pwinh's primary data processing infrastructure is located within the Philippines. In limited circumstances, personal data may be transferred to or processed by service providers operating in other jurisdictions — for example, cloud hosting providers or identity verification platforms with international operations. Where such transfers occur, pwinh ensures that appropriate safeguards are in place, including contractual obligations that require the recipient to handle your data in a manner consistent with the Philippine Data Privacy Act and this Privacy Policy.

pwinh will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without ensuring that appropriate protective measures are in place and, where required, obtaining your consent.

13. Updates to This Privacy Policy

pwinh may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory guidance. When material changes are made, pwinh will notify registered players via the email address on record and display a prominent notice on the pwinh platform. The updated Privacy Policy will take effect on the date specified in the notice.

The "Effective Date" at the top of this document indicates the date of the most recent revision. We encourage you to review this Privacy Policy periodically. Your continued use of pwinh following the effective date of any update constitutes acceptance of the revised Privacy Policy. The current version of this policy is always available at pwinh.net/privacy-policy.

14. Contact & Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by pwinh, please contact our Data Privacy Officer (DPO) through the following channels:

• Email: [email protected] (subject line: "Data Privacy Request")
• Live Chat: Available 24/7 directly on the pwinh platform

pwinh's support team operates on Philippine Standard Time (PST), 24 hours a day, 7 days a week. We aim to acknowledge all data subject requests within five (5) business days and to resolve them within the timeframes prescribed by the NPC.

If you are not satisfied with pwinh's response to a data privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines at privacy.gov.ph.