PHWinner Privacy Policy — Your Data, Your Rights, Our Responsibility

This Privacy Policy is issued by PHWinner and applies to all personal information collected through the PHWinner website at phwinner.net, our mobile gaming interface, customer support channels, and any other point at which you provide us with personal data in connection with your use of PHWinner's services.

PHWinner is committed to protecting the privacy and personal data of every Filipino player on our platform. This policy is written to comply with the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its implementing rules and regulations, which govern how organisations in the Philippines collect, use, and protect personal information.

By registering a PHWinner account and using our platform, you acknowledge that you have read and understood this Privacy Policy. If you have any questions about how your data is handled, you are encouraged to contact PHWinner's Data Protection Officer (DPO) using the contact details in Section 13 of this policy.

PHWinner collects personal data from you in three ways: information you provide directly, information generated automatically through your use of the platform, and information received from third parties in connection with identity verification and payment processing.

Data you provide directly:

• Full legal name, date of birth, and gender (collected at registration for identity verification purposes)
• Mobile number and email address (used for account access, notifications, and support communications)
• Residential address (collected as part of Know Your Customer / KYC verification)
• Government-issued ID details — ID type, ID number, and images of your ID document — submitted during identity verification
• Payment method details, including your registered GCash or Maya mobile number, bank account details, or card details as required for deposit and withdrawal processing
• Correspondence you send to PHWinner's support team via live chat or email

Data collected automatically:

• IP address and approximate geographic location at login
• Device type, operating system, and browser version
• Session timestamps — when you log in, how long you stay, and when you log out
• Gameplay data — game types played, bet amounts, outcomes, and transaction history
• Clickstream data — pages viewed, features used, and navigation patterns within the platform
• Cookie and similar tracking technology data (see Section 6 for full details)

Data received from third parties:

• Identity verification results from third-party KYC providers — whether your submitted documents match the records held by the issuing authority
• Payment transaction references and status updates from GCash, Maya, BDO, BPI, UnionBank, and other payment providers
• Fraud and AML (anti-money laundering) screening results from financial compliance service providers

PHWinner uses the personal data we collect for the following specific purposes. We do not use your data for any purpose incompatible with the ones listed here without first obtaining your explicit consent.

• Account registration and management: To create and maintain your PHWinner account, verify your identity, enable login access, and administer your account balance and preferences.
• Transaction processing: To process deposits, withdrawals, and refunds securely through your chosen Philippine payment method, and to maintain an accurate transaction history in your account.
• Identity verification (KYC/AML): To verify that you are who you say you are, to confirm you meet the minimum age requirement of 18 years, and to comply with our anti-money laundering obligations under Philippine law.
• Service delivery and platform operation: To provide you with access to games, sports betting markets, live dealer tables, promotions, VIP benefits, and all other PHWinner platform features.
• Customer support: To respond to your enquiries, resolve disputes, investigate complaints, and provide technical assistance.
• Security and fraud prevention: To detect, investigate, and prevent fraudulent transactions, account takeovers, bonus abuse, and other activities that violate PHWinner's Terms and Conditions.
• Responsible gaming: To monitor gaming patterns that may indicate problem gambling behaviour, to administer deposit limits and self-exclusion requests, and to provide appropriate support and information.
• Regulatory compliance: To comply with reporting obligations to gaming regulators, tax authorities, and law enforcement agencies as required by applicable Philippine law.
• Platform improvement: To analyse aggregated, anonymised usage data to understand how players use PHWinner and to improve the platform's features, performance, and user experience.
• Marketing communications (with consent): To send you information about PHWinner promotions, bonuses, and new features — only if you have opted in to receive such communications. You can withdraw consent for marketing messages at any time.

Under the Philippine Data Privacy Act, PHWinner must have a valid legal basis for processing your personal data. PHWinner relies on the following legal bases:

• Contract performance: Processing your registration data, transaction data, and gameplay data is necessary to perform the contract between you and PHWinner — specifically, to provide the gaming and betting services you have signed up for.
• Legal obligation: Processing data for KYC/AML verification, age verification, tax reporting, and regulatory compliance is required by Philippine law and gaming regulations. PHWinner cannot operate its platform without fulfilling these obligations.
• Legitimate interests: Processing data for fraud prevention, security monitoring, platform improvement, and responsible gaming monitoring is based on PHWinner's legitimate interest in operating a safe, fair, and sustainable platform — provided that this interest does not override your fundamental privacy rights.
• Consent: Processing your data for marketing communications, optional personalisation features, and non-essential cookies is based on your freely given, specific, and informed consent. You can withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

PHWinner does not sell your personal data. We share personal data with third parties only in the circumstances listed below, and only to the extent necessary for the stated purpose.

• Payment processors: GCash, Maya, GrabPay, BDO, BPI, UnionBank, and card payment providers receive the transaction data necessary to process your deposits and withdrawals. These providers are independently bound by financial data protection standards.
• Identity verification providers: Third-party KYC service providers receive copies of your submitted identity documents and personal details to perform identity checks against government records. These providers operate under strict data processing agreements with PHWinner.
• AML screening providers: Financial compliance service providers may receive limited personal data (name, date of birth, ID details) to perform anti-money laundering and sanctions screening as required by Philippine law.
• Gaming platform technology providers: Game software providers and live dealer studio operators may receive session-level data (device type, IP, game preferences) to deliver game content. These providers do not receive your financial or full identity data.
• Regulatory and law enforcement authorities: PHWinner will disclose personal data to the Philippine Amusement and Gaming Corporation (PAGCOR), the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and law enforcement agencies where required by law or valid legal process.
• Professional advisors: Legal, accounting, and audit firms engaged by PHWinner may access personal data as necessary in connection with professional services, subject to professional confidentiality obligations.

PHWinner uses cookies and similar tracking technologies to operate the platform, remember your preferences, maintain your login session, and understand how players use the site. A cookie is a small text file stored on your device by your web browser when you visit a website.

Essential cookies cannot be disabled — they are required for the platform to function. You can manage optional cookies through the cookie preferences panel accessible from the platform's settings menu. Blocking optional cookies will not affect your ability to play games, deposit, or withdraw.

PHWinner does not use third-party advertising or retargeting cookies that track you across other websites.

PHWinner implements a layered security architecture to protect personal data against unauthorised access, disclosure, alteration, and destruction. Our key security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and PHWinner's servers
• AES-256 encryption at rest for all personal and financial data stored in PHWinner's databases
• Two-factor authentication (2FA) available for all player accounts and mandatory for administrative access
• Role-based access controls ensuring that PHWinner staff can only access personal data to the extent required by their specific role
• Regular security audits and penetration testing conducted by qualified third-party security firms
• Intrusion detection and anomaly monitoring running continuously on PHWinner's infrastructure
• Secure data centre facilities with physical access controls, environmental monitoring, and redundant systems

PHWinner retains your personal data only for as long as it is needed for the purpose for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account and identity data (name, date of birth, ID documents): Retained for the duration of your account and for a minimum of 5 years after account closure, as required by AML regulations.
• Transaction records (deposit and withdrawal history): Retained for a minimum of 5 years after each transaction, as required by tax and financial reporting regulations.
• Gameplay records (bets placed, game results): Retained for 3 years from the date of the gaming session.
• Support correspondence (live chat logs, emails): Retained for 2 years from the date of the last message in the thread.
• Marketing preferences (consent records): Retained for as long as your account is active, plus 1 year.
• Analytics data: Anonymised after 24 months and retained in aggregate form indefinitely.

When the applicable retention period expires, personal data is securely deleted from PHWinner's systems or anonymised so that it can no longer be linked to an individual. Anonymised data may be retained for statistical and research purposes without time limit.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by PHWinner. PHWinner is committed to honouring all of these rights promptly and without unnecessary barriers.

To exercise any of the rights listed above, contact PHWinner's Data Protection Officer at privacy@phwinner.net. PHWinner will respond to all data rights requests within 30 calendar days of receipt. Complex requests may take up to 60 days, in which case PHWinner will notify you of the extension.

PHWinner's services are strictly for adults aged 18 and over. PHWinner does not knowingly collect personal data from individuals under 18 years of age. Age verification is a mandatory step during account registration, and PHWinner employs additional checks to detect and prevent underage access.

If PHWinner becomes aware that personal data has been collected from an individual who is under 18, the account will be immediately closed, the data deleted from our systems, and any deposits returned to the payment source used. If you are a parent or guardian and believe your child may have registered a PHWinner account, please contact PHWinner support immediately at support@phwinner.net.

PHWinner's primary data infrastructure is located in data centres serving the Philippine market. However, certain service providers — including game software providers and cloud infrastructure partners — may process data in server environments outside the Philippines.

Where personal data is transferred outside the Philippines, PHWinner ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required by the Philippine Data Privacy Act. These safeguards include contractual protections (Standard Contractual Clauses), adequacy assessments of the receiving country's data protection framework, and binding corporate rules where applicable.

PHWinner will not transfer your personal data to any country or jurisdiction that does not provide an adequate level of data protection without first obtaining your explicit consent or implementing appropriate contractual safeguards.

PHWinner may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, applicable law, or regulatory guidance. When we make material changes, we will notify active members via email to their registered address or via an in-platform notification, at least 14 days before the updated policy takes effect.

The current version of this Privacy Policy will always be available at phwinner.net/privacy-policy, with the effective date shown at the top of the page. We recommend checking this page periodically to stay informed about how PHWinner handles your personal data.

Your continued use of the PHWinner platform after the effective date of any updated policy constitutes your acknowledgement of the changes. If you do not agree with the updated policy, you should stop using the platform and contact PHWinner to close your account.

PHWinner has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions about your personal data, wish to exercise a data right, or have a privacy concern, please contact:

• Data Protection Officer: privacy@phwinner.net
• General Support: support@phwinner.net
• Live Chat: Available 24/7 from any page on the PHWinner platform
• FAQ: Common privacy questions are answered at phwinner.net/faq

PHWinner's DPO will acknowledge your enquiry within 3 business days and provide a full response within 30 calendar days. For urgent security concerns — such as suspected unauthorised access to your account — please use the 24/7 live chat for the fastest response.