Privacy Policy DPA Compliant

1. Introduction

1.1 This Privacy Policy ("Policy") applies to all personal data processed by philwin ("philwin," "we," "us," "our") in connection with the philwin.vip website and all associated services, features, and content (collectively, the "Platform").

1.2 By registering for a philwin account, accessing the Platform, or otherwise providing your personal data to philwin, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

1.3 This Policy should be read alongside philwin's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

1.4 philwin is committed to the principles of transparency, legitimate purpose, and proportionality as required by the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

2. Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, philwin is the personal information controller in respect of the personal data you provide when using the Platform.

2.2 philwin has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 14 of this Policy.

2.3 philwin's data processing activities are registered with the National Privacy Commission (NPC) of the Philippines in accordance with applicable registration requirements.

3. Personal Data We Collect

3.1 philwin collects the following categories of personal data in connection with your use of the Platform:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification – you must be 21 or older);
• Nationality and country of residence;
• Residential address (including barangay, city/municipality, province);
• Mobile number registered in the Philippines;
• Email address.

3.2 Identity Verification Data

• Copies of government-issued identification documents (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys National ID);
• Proof of address documents (e.g., utility bills, bank statements);
• Selfie or facial image for liveness verification where required.

3.3 Financial Data

• GCash or PayMaya (Maya) account details linked to your philwin account;
• Bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, or other Philippine banks) for withdrawal processing;
• Debit card details where applicable;
• Transaction history including deposits, withdrawals, wagers, and winnings.

3.4 Technical and Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session logs, login timestamps, and activity records;
• Game history, betting patterns, and session duration data;
• Cookie identifiers and similar tracking data (see Section 9).

3.5 Communications Data

• Records of your communications with philwin customer support via live chat or email;
• Feedback, complaints, and dispute records.

4. How We Collect Your Data

4.1 philwin collects personal data through the following means:

• Direct collection: Information you provide when registering for a philwin account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, log files, and analytics tools;
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from GCash, PayMaya, and banking partners.

5. How We Use Your Personal Data

5.1 philwin uses your personal data for the following purposes:

5.2 philwin will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5.3 Marketing Communications. If you have opted in to receive marketing communications from philwin, we may send you promotional offers, bonus notifications, and platform updates via email or SMS. You may withdraw your consent and opt out of marketing communications at any time by updating your account preferences or contacting our support team.

6. Legal Basis for Processing

6.1 philwin processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and delivery of gaming services;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including KYC requirements, AML obligations, and PAGCOR regulatory requirements;
• Legitimate interests: Processing necessary for philwin's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications and certain cookie uses. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing and Disclosure

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

• KYC and identity verification providers: Third-party services that assist philwin in verifying your identity and age in compliance with regulatory requirements;
• Payment processors and banking partners: GCash, PayMaya (Maya), and Philippine banking institutions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals;
• Fraud prevention and security services: Third-party providers that assist philwin in detecting and preventing fraudulent activity, money laundering, and other illegal conduct;
• IT and platform service providers: Cloud hosting, data storage, and software providers that support the operation of the philwin Platform, all of whom are bound by data processing agreements;
• Regulatory and law enforcement authorities: The Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent authorities where disclosure is required by law or court order;
• Professional advisers: Legal, accounting, and auditing firms engaged by philwin, subject to professional confidentiality obligations.

7.2 All third-party service providers who process personal data on behalf of philwin are required to implement appropriate technical and organizational security measures and to process data only in accordance with philwin's instructions and applicable law.

8. Data Retention

8.1 philwin retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

8.2 The following retention periods apply as a general guide:

8.3 After the applicable retention period, personal data will be securely deleted or anonymized in accordance with philwin's data disposal procedures. Anonymized data may be retained indefinitely for statistical and analytical purposes.

8.4 Where you request account closure, philwin will deactivate your account promptly. However, certain data will be retained for the periods specified above to comply with legal and regulatory obligations.

9. Cookies and Tracking Technologies

9.1 philwin uses cookies and similar tracking technologies (such as web beacons and local storage) on the Platform. Cookies are small text files placed on your device that help us recognize you, remember your preferences, and improve your experience.

9.2 philwin uses the following categories of cookies:

9.3 You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary or security cookies may affect the functionality of the Platform and your ability to log in to your philwin account.

9.4 philwin does not use third-party advertising cookies or allow external advertisers to place cookies on the Platform.

10. Your Data Protection Rights

10.1 Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by philwin:

10.2 To exercise any of the above rights, please contact philwin's Data Protection Officer using the contact details in Section 14. philwin will respond to all verified requests within fifteen (15) business days, as required by the NPC's guidelines.

10.3 If you are not satisfied with philwin's response to your data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

11. Data Security

11.1 philwin 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 transmitted between your device and the philwin Platform;
• Encryption of sensitive data at rest, including financial data and identity documents;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Two-factor authentication (2FA) options for player accounts;
• Continuous monitoring for suspicious activity and unauthorized access attempts;
• Staff training on data protection and information security obligations.

11.2 Data Breach Response. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, philwin will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the requirements of the Data Privacy Act of 2012.

11.3 While philwin takes all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for keeping your philwin login credentials confidential and for notifying us immediately of any suspected unauthorized access to your account.

12. Children's Privacy and Age Restriction

12.1 The philwin Platform is strictly intended for persons aged twenty-one (21) years and above. philwin does not knowingly collect personal data from persons under the age of 21.

12.2 If philwin becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any winnings accrued by an underage player will be forfeited in accordance with philwin's Terms & Conditions.

12.3 If you are a parent or guardian and believe that your child has registered on the philwin Platform, please contact our Data Protection Officer immediately using the details in Section 14.

13. Changes to This Privacy Policy

13.1 philwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or platform features. The updated Policy will be posted on this page with a revised effective date.

13.2 Where changes are material, philwin will notify registered players via email or an in-platform notification prior to the changes taking effect. Your continued use of the Platform after 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 philwin protects your personal data.

14. Contact and Data Protection Officer

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or philwin's data processing practices, please contact our Data Protection Officer:

14.2 If you are not satisfied with our response, you may file a complaint with the National Privacy Commission of the Philippines. Information about how to file a complaint is available on the NPC's official website.

14.3 For general support inquiries unrelated to data privacy, please use the live chat feature available within the philwin Platform, which is staffed around the clock.