pwin Privacy Policy –
Your Data, Protected Transparent & Honest Privacy You Can Trust

This Privacy Policy ("Policy") describes how pwin ("pwin," "we," "us," or "our") collects, uses, stores, and protects the personal data of individuals ("you," "your," or "Player") who access or use the pwin online gaming platform at pwin.asia ("the Platform"). This Policy applies to all pwin services, including account registration, gaming activity, customer support interactions, and marketing communications.

pwin is committed to protecting the privacy and personal data of all Filipino players in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations ("IRR"). By registering a pwin account or using any pwin service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read alongside pwin's Terms and Conditions, which govern the overall relationship between you and pwin. In the event of any conflict between this Policy and the Terms and Conditions with respect to data privacy matters, this Policy shall prevail.

pwin acts as the data controller in respect of the personal data collected through the Platform. As data controller, pwin determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law.

pwin has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and with the DPA. If you have any questions or concerns about how pwin handles your personal data, you may contact the DPO using the details provided in Section 14 of this Policy.

pwin collects the following categories of personal data from players:

pwin does not intentionally collect sensitive personal information as defined under the DPA (such as health data, religious beliefs, or political affiliations) unless specifically required by law or with your explicit consent.

pwin collects personal data through the following means:

• Direct Collection: Information you provide when registering a pwin account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-Party Sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment data from GCash, Maya, and banking partners as part of transaction processing.
• Regulatory Sources: Information received from PAGCOR or other Philippine regulatory bodies in connection with licensing, compliance, or investigation requirements.

pwin processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing required to perform the contract between you and pwin, including account management, game delivery, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering obligations under RA 9160, PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and business analytics, where such interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

pwin uses your personal data for the following purposes:

• To create, verify, and manage your pwin account;
• To process deposits and withdrawals via GCash, Maya, and Philippine bank transfer;
• To verify your identity and age (21+) in compliance with Philippine gaming regulations;
• To deliver gaming services, including live casino, slots, bingo, and sports betting;
• To monitor gaming activity for responsible gaming purposes and to enforce self-exclusion or deposit limit requests;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To comply with PAGCOR licensing requirements and other applicable Philippine regulatory obligations;
• To provide customer support and resolve disputes;
• To send you transactional communications (account notices, security alerts, withdrawal confirmations);
• To send you promotional communications about pwin offers and new games, where you have consented to receive such communications;
• To analyze Platform usage and improve pwin's services, features, and user experience;
• To enforce pwin's Terms and Conditions.

pwin 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.

pwin does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other Philippine payment partners, for the purpose of processing deposits and withdrawals.
• KYC and Identity Verification Providers: Third-party identity verification services used to confirm player identity and age in compliance with regulatory requirements.
• Anti-Fraud and Security Partners: Service providers that assist pwin in detecting and preventing fraudulent activity, money laundering, and unauthorized account access.
• Game Software Providers: Licensed game developers and platform providers whose software powers pwin's casino, slot, and sports betting offerings.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law or regulation.
• IT and Cloud Service Providers: Hosting, infrastructure, and analytics providers who process data on pwin's behalf under strict data processing agreements.
• Professional Advisers: Legal, accounting, and auditing firms, where disclosure is necessary for the conduct of pwin's business.

All third parties with whom pwin shares personal data are required to maintain appropriate technical and organizational security measures and to process personal data only in accordance with pwin's instructions and applicable Philippine data protection law.

pwin 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. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your pwin account and for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering record-keeping requirements.
• Financial Transaction Data: Retained for a minimum of five (5) years from the date of the transaction, in accordance with RA 9160 and applicable tax regulations.
• Gaming Activity Data: Retained for a minimum of three (3) years from the date of the gaming session, for regulatory compliance and dispute resolution purposes.
• Customer Support Communications: Retained for two (2) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of lawful processing.

Upon expiry of the applicable retention period, pwin will securely delete or anonymize your personal data in accordance with its data disposal procedures.

pwin uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the Platform. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as language settings and game display options, to provide a more personalized experience.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping pwin identify areas for improvement. These are only set with your consent.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and bot traffic 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 pwin Platform. pwin does not use cookies to track your browsing activity on unrelated third-party websites.

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and pwin's servers;
• Encryption of sensitive data at rest, including financial data and identity documents;
• Multi-factor authentication options for player accounts;
• Regular security audits and penetration testing of the Platform;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Staff training on data protection and information security obligations;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While pwin takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in serious harm to affected players, pwin will notify the National Privacy Commission and affected players within the timeframes required by the DPA.

Under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by pwin:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right to Access: The right to request a copy of the personal data pwin holds about you and information about how it is processed.
• Right to Correction: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary, subject to pwin's legal retention obligations.
• Right to Object: The right to object to processing based on legitimate interests or for direct marketing purposes.
• Right to Data Portability: The right to receive your personal data in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw consent at any time without affecting prior lawful processing.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe pwin has violated your data privacy rights.

To exercise any of these rights, please contact pwin's Data Protection Officer using the contact details in Section 14. pwin will respond to all data rights requests within thirty (30) days of receipt, in accordance with the DPA's requirements.

21+ The pwin Platform is strictly intended for adults aged 21 years and above. pwin does not knowingly collect personal data from individuals under the age of 21. If pwin becomes aware that personal data has been collected from a person under 21, it will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered a pwin account or provided personal data to pwin, please contact our Data Protection Officer immediately using the details in Section 14 so that we can take appropriate action.

pwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. Where changes are material, pwin will provide reasonable advance notice to registered players via email or a prominent notice on the Platform.

The date of the most recent revision is displayed at the top of this page. Your continued use of the pwin Platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. If you do not agree to the revised Policy, you should cease using the Platform and may request closure of your account.

If you have any questions, concerns, or requests regarding this Privacy Policy or pwin's handling of your personal data, please contact our Data Protection Officer:

• Data Protection Officer: pwin DPO
• Email: [email protected]
• General Support: [email protected]
• Response Time: Within 30 days of receipt of your request

If you are not satisfied with pwin's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). For more information about your rights and how to file a complaint, visit the NPC's official channels.

For responsible gaming concerns, please visit our Responsible Gaming page. For general legal questions, please review our Terms & Conditions.