Privacy Policy

1. Introduction

Welcome to win1win. We understand that your privacy matters, and we take our responsibility to protect your personal information seriously. This Privacy Policy describes how win1win ("we," "us," or "our") collects, uses, stores, shares, and protects the personal data of users ("you" or "your") who access or use the win1win online gaming platform at win1win.org.

By registering an account, accessing the win1win Platform, or using any of our Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately.

This Policy should be read together with our Terms & Conditions, which govern your use of the win1win Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), win1win acts as the Personal Information Controller (PIC) in respect of the personal data collected through the Platform. This means win1win determines the purposes and means of processing your personal information.

Where win1win engages third-party service providers to process personal data on its behalf (for example, payment processors or KYC verification providers), those parties act as Personal Information Processors (PIPs) and are bound by data processing agreements that require them to handle your data in accordance with this Policy and applicable law.

If you have any questions or concerns about how win1win handles your personal data, please contact our Data Protection Officer (DPO) using the details provided in Section 15 of this Policy.

3. Personal Data We Collect

win1win collects the following categories of personal data from users of the Platform:

3.1 Identity & Contact Information

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Gender
• Nationality and country of residence
• Email address
• Mobile phone number
• Residential address (including city, province, and postal code)

3.2 Identity Verification (KYC) Documents

• Government-issued photo ID (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID)
• Proof of address (e.g., utility bill, bank statement dated within 3 months)
• Selfie or live photo for facial verification, where required
• Source of funds documentation, where required by AML regulations

3.3 Financial Information

• GCash or Maya account details (mobile number linked to the e-wallet)
• Bank account details (account name, account number, bank name) for bank transfer transactions
• Debit card details (card number, expiry date — stored in tokenized form only)
• Transaction history, including deposit and withdrawal records

3.4 Gaming Activity Data

• Game play history, including games played, bets placed, wins, and losses
• Session duration and frequency of play
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status)

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Unique device identifiers
• Login timestamps and session data
• Cookies and similar tracking technologies (see Section 9)

3.6 Communications Data

• Records of communications between you and win1win customer support
• Feedback, survey responses, and complaint records
• Email and in-platform notification preferences

4. How We Collect Your Data

win1win collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC/AML service providers; fraud prevention data from risk management partners; payment confirmation data from payment processors such as GCash, Maya, and banking partners.
• Publicly available sources: Where permitted by law, win1win may supplement your profile with information from publicly available sources for fraud prevention and compliance purposes.

5. Purpose & Legal Basis for Processing

win1win processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

win1win will not process your personal data for purposes incompatible with those listed above without first obtaining your explicit consent or establishing a new lawful basis.

6. Data Sharing & Disclosure

win1win does not sell, rent, or trade your personal data. 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:

6.1 Service Providers (Personal Information Processors)

• Payment processors: GCash, Maya, and banking partners, to process your deposits and withdrawals in Philippine Peso;
• KYC / identity verification providers: To verify your identity and age in compliance with PAGCOR and AML requirements;
• Fraud prevention and risk management providers: To detect and prevent fraudulent activity on the Platform;
• Cloud hosting and IT infrastructure providers: To store and process data securely;
• Customer support platform providers: To manage and respond to your support inquiries.

6.2 Regulatory and Law Enforcement Authorities

win1win may disclose your personal data to PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), or other competent Philippine government authorities where required by law, court order, or regulatory directive.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of win1win's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer via email or a prominent notice on the Platform.

7. Data Retention

win1win retains your personal data for as long as 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 retention periods apply as a general guide:

• Account and identity data: Retained for the duration of your account and for a minimum of 5 years after account closure, in compliance with PAGCOR and AMLC record-keeping requirements;
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction, as required by the Anti-Money Laundering Act;
• Gaming activity data: Retained for a minimum of 3 years after account closure;
• Customer support communications: Retained for 2 years from the date of the last communication;
• Marketing consent records: Retained until you withdraw consent, plus 1 year thereafter for compliance purposes.

When personal data is no longer required, win1win will securely delete or anonymize it in accordance with our data disposal procedures.

8. Data Security

win1win implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the win1win Platform;
• Encryption at rest for sensitive personal and financial data stored on our servers;
• Payment card tokenization — debit card details are never stored in plain text;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Multi-factor authentication for internal systems and, where available, for user accounts;
• Regular security audits and penetration testing of the Platform infrastructure;
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC notification requirements.

While win1win takes all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for keeping your account credentials confidential and for notifying us immediately at [email protected] if you suspect any unauthorized access to your account.

9. Cookies & Tracking Technologies

win1win uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit a website. The following types of cookies are used on the win1win Platform:

• Strictly necessary cookies: Essential for the Platform to function, including session management and security. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, display settings) to improve your experience.
• Analytics cookies: Collect anonymized data about how users interact with the Platform to help us improve performance and usability.
• Fraud prevention cookies: Help detect and prevent fraudulent activity and unauthorized access.

You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. win1win does not use third-party advertising or behavioral tracking cookies.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by win1win:

• Right to be informed: You have the right to know what personal data win1win collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: You may request a copy of the personal data win1win holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interest.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will respond to your request within 15 business days in accordance with NPC guidelines. We may need to verify your identity before processing your request.

11. Minors & Age Policy

win1win requires all users to verify their age during the registration and KYC process. If win1win discovers that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, void any transactions, and delete the personal data in question as soon as practicable.

If you are a parent or guardian and believe that your child under 21 has registered on the win1win Platform, please contact us immediately at [email protected] so we can take appropriate action.

12. Cross-Border Data Transfers

win1win primarily stores and processes personal data within the Republic of the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines (for example, cloud hosting providers), win1win ensures that such transfers are made in compliance with the Data Privacy Act of 2012 and NPC regulations, including by:

• Entering into data processing agreements with recipient parties that impose data protection obligations equivalent to those under Philippine law;
• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the NPC;
• Obtaining your consent for transfers where required by applicable law.

13. Third-Party Links & Services

The win1win Platform may contain references to third-party payment services (such as GCash and Maya) that have their own privacy policies. win1win is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you use in connection with your win1win account.

win1win does not embed third-party advertising networks, social media tracking pixels, or external analytics services that would share your personal data with third parties for advertising purposes.

14. Changes to This Privacy Policy

win1win reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. When material changes are made, we will notify you by:

• Posting a prominent notice on the win1win Platform;
• Sending an email notification to your registered email address at least 7 days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated Policy, you must cease using the Platform and may close your account in accordance with our Terms & Conditions.

15. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by win1win, please contact our Data Protection Officer (DPO):

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have not been adequately addressed by win1win.