phwin21 Privacy Policy

1. Overview

This Privacy Policy ("Policy") is issued by phwin21 ("phwin21", "we", "us", "our") and applies to all personal data collected from users ("Player", "User", "you") who access or use the phwin21 website, mobile platform, games, sportsbook, and all related services (collectively, the "Platform").

phwin21 is committed to protecting the privacy and personal data of all Filipino players in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. We process personal data only for legitimate, specified, and declared purposes, and only to the extent necessary to fulfil those purposes.

By registering an account on phwin21 or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the phwin21 Platform.

This Policy should be read together with phwin21's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data We Collect

phwin21 collects the following categories of personal data from players. We collect only what is necessary for the purposes described in this Policy.

phwin21 does not collect sensitive personal information (as defined under the Data Privacy Act of 2012) unless strictly required for identity verification or legal compliance purposes, and only with your explicit consent where required by law.

3. How We Collect Data

phwin21 collects personal data through the following means:

• Direct interactions: Data you provide when registering your phwin21 account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the phwin21 Platform, including through cookies, web beacons, log files, and similar tracking technologies.
• Third-party sources: Identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud prevention services, and analytics providers may share data with phwin21 where permitted by law.
• Publicly available sources: In limited circumstances, phwin21 may verify information against publicly available records for compliance purposes.

4. How We Use Your Data

phwin21 uses your personal data for the following purposes:

• To create, manage, and maintain your phwin21 account, including identity and age verification.
• To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank.
• To provide access to phwin21 games, sports betting, bingo, sabong, and all other Platform services.
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity.
• To comply with applicable Philippine laws, PAGCOR-regulated guidelines, and regulatory obligations.
• To monitor gaming activity for responsible gaming purposes, including identifying at-risk players and enforcing self-exclusion requests.
• To provide customer support and resolve disputes.
• To send you account-related communications, including transaction confirmations, security alerts, and policy updates.
• To send you promotional communications about phwin21 offers and bonuses, where you have consented to receive such communications.
• To improve the phwin21 Platform through analytics, testing, and research.
• To enforce phwin21's Terms & Conditions and other applicable policies.

5. Legal Basis for Processing

phwin21 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity: Processing required to fulfil our obligations under the phwin21 Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, PAGCOR regulations, anti-money laundering (AML) requirements, and other regulatory obligations.
• Legitimate interests: Processing necessary for phwin21's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications and certain cookie usage. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing

phwin21 does not sell your personal data to third parties. We may share your data with the following categories of recipients only where necessary and in accordance with this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank, to process deposits and withdrawals on your behalf.
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and eligibility to use phwin21.
• Fraud prevention and AML services: Providers that assist phwin21 in detecting and preventing fraudulent activity and money laundering.
• Analytics providers: Services that help phwin21 understand Platform usage and improve user experience. Data shared with analytics providers is aggregated or pseudonymised where possible.
• Regulatory authorities: PAGCOR and other Philippine government agencies, where phwin21 is legally required to disclose player data.
• Law enforcement: Philippine law enforcement agencies, where phwin21 is required or permitted by law to disclose data in connection with a legal investigation or proceeding.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by phwin21, subject to confidentiality obligations.

All third parties with whom phwin21 shares personal data are required to handle that data in accordance with applicable data protection laws and phwin21's data processing requirements. phwin21 does not permit third parties to use your data for their own marketing purposes.

7. Data Retention

phwin21 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general rule, phwin21 retains account data for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations and PAGCOR-regulated guidelines. Financial transaction records are retained for a minimum of five (5) years from the date of the transaction. Gaming history records are retained for a minimum of three (3) years.

Where phwin21 is required by law to retain data for a longer period, we will do so. Where data is no longer required for any legitimate purpose, phwin21 will securely delete or anonymise it.

• Active account data: Retained for the duration of your phwin21 account plus five (5) years after closure.
• KYC and identity documents: Retained for five (5) years after account closure or last transaction, whichever is later.
• Financial transaction records: Retained for five (5) years from the date of each transaction.
• Support and communications records: Retained for three (3) years from the date of the interaction.
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter.

8. Data Security

phwin21 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures are reviewed and updated regularly to reflect current best practices and the evolving threat landscape.

Security measures employed by phwin21 include, but are not limited to:

• SSL/TLS encryption for all data transmitted between your device and the phwin21 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.
• Multi-factor authentication for phwin21 account access and internal systems.
• Regular security audits, vulnerability assessments, and penetration testing.
• Incident response procedures for detecting, reporting, and managing personal data breaches.
• Staff training on data protection obligations and security best practices.

While phwin21 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 phwin21 login credentials confidential and for notifying phwin21 immediately if you suspect any unauthorised access to your account.

9. Cookies & Tracking Technologies

phwin21 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage patterns, and deliver a personalised experience. A cookie is a small text file placed on your device when you visit the phwin21 Platform.

phwin21 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in to your phwin21 account and security cookies that protect against fraud. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and game history to improve your phwin21 experience.
• Analytics cookies: Help phwin21 understand how players use the Platform, which pages are most visited, and where improvements can be made. Data collected is aggregated and does not identify individual players.
• Marketing cookies: Used to deliver relevant phwin21 promotions and offers. These are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phwin21 Platform. Strictly necessary cookies cannot be disabled as they are essential for Platform operation.

phwin21 does not use cookies to track your activity on third-party websites unrelated to the phwin21 Platform.

10. Your Rights

Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights in relation to your personal data held by phwin21. To exercise any of these rights, contact phwin21 support via live chat on the Platform or by email at [email protected].

phwin21 will respond to all data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further two (2) months, in which case phwin21 will notify you of the extension and the reasons for it. phwin21 will not charge a fee for handling data rights requests unless they are manifestly unfounded or excessive.

If you are not satisfied with phwin21's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Minors & Age Policy

phwin21 employs age verification measures during the registration process and may request additional identity documents at any time to confirm that a player meets the minimum age requirement. If you are a parent or guardian and believe that a minor has registered on phwin21, please contact our support team immediately via live chat so that we can take prompt action.

phwin21 strongly encourages parents and guardians to use parental control software to prevent minors from accessing online gaming platforms. For more information on responsible gaming tools available on phwin21, please visit our Responsible Gaming page.

12. Policy Changes

phwin21 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform services. When material changes are made, phwin21 will update the "Last updated" date at the top of this page and, where reasonably practicable, notify registered players via email or in-platform notification.

Your continued use of the phwin21 Platform after any amendments have been published constitutes your acknowledgement of the revised Policy. We encourage you to review this Policy periodically to stay informed about how phwin21 protects your personal data. The most current version of this Policy will always be available at phwin21.org/privacy-policy.

13. Contact & Data Protection Officer

phwin21 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. If you have any questions, concerns, or complaints regarding this Policy or phwin21's data practices, you may contact our DPO through the following channels:

• Live Chat: Available 24/7 directly on the phwin21 Platform — the fastest way to reach our team.
• Email: [email protected] — please include "Privacy" or "DPO" in your subject line.
• Headquarters: Manila, Philippines

phwin21 aims to respond to all privacy-related enquiries within five (5) business days. For urgent matters involving potential data breaches or unauthorised account access, please use live chat for the fastest response.

If you are not satisfied with phwin21's handling of your privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for data protection in the Philippines.