Privacy Policy

This Privacy Policy ("Policy") describes how www .winph ("we," "us," "our," or "the Platform") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the www.winph website, mobile interface, games, and all related services (collectively, the "Services").

www.winph is committed to protecting the privacy and security of your personal data. This Policy has been prepared in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC").

By registering an account on www.winph or otherwise using the Services, 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. If you do not agree with this Policy, you must not register an account or use the Services.

For the purposes of the Data Privacy Act of 2012 and this Policy, www.winph acts as the personal information controller ("PIC") in respect of the personal data it collects and processes in connection with the Services.

As a personal information controller, www.winph determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently in accordance with the DPA and its IRR.

www.winph has designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data privacy laws. Contact details for the DPO are provided in Section 14 of this Policy.

www.winph collects the following categories of personal data in connection with the provision of the Services:

Identity & Contact Data

• Full legal name, date of birth, and gender.
• Residential address, including city (e.g., Manila, Cebu, Davao, Quezon City, Makati) and province.
• Email address and mobile number.
• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license) submitted for identity verification purposes.

Account & Transaction Data

• Username, encrypted password, and account preferences.
• Deposit and withdrawal history, including payment method details (e.g., GCash account reference, PayMaya reference, BPI or BDO account details).
• Bonus and promotion redemption history.
• Game play history, wagering records, and session data.

Technical & Usage Data

• IP address, device type, operating system, and browser type.
• Pages visited, features used, and time spent on the platform.
• Geolocation data (country and region level) for regulatory compliance purposes.
• Cookie identifiers and similar tracking technologies as described in Section 9.

Communications Data

• Records of communications between you and the www.winph support team, including live chat transcripts and email correspondence.
• Feedback, survey responses, and complaints submitted through the platform.

www.winph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, log files, and similar technologies when you access and interact with the platform.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank.
• Regulatory sources: Information received from PAGCOR, the AMLC, or other Philippine regulatory bodies in connection with compliance obligations.

www.winph processes your personal data only for specified, explicit, and legitimate purposes. The following table summarizes the primary purposes for which your data is processed and the corresponding legal basis under the Data Privacy Act of 2012:

Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent for marketing communications, you may use the unsubscribe link in any marketing email or contact the www.winph support team.

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

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers engaged to assist with player verification and fraud prevention.
• Game software providers: Licensed game developers and providers whose games are available on the www.winph platform, to the extent necessary for game delivery and fairness auditing.
• 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 regulatory directive.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a valid legal process, court order, or to protect the rights, property, or safety of www.winph, its players, or the public.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by www.winph, subject to confidentiality obligations.

All third parties with whom www.winph shares personal data are required to process such data in accordance with applicable data privacy laws and are bound by appropriate data processing agreements or equivalent contractual safeguards.

www.winph retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations.

• Account and transaction data is retained for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements under Philippine law.
• Identity verification documents are retained for the period required by PAGCOR licensing conditions and AML regulations.
• Customer support communications are retained for a period of three (3) years from the date of the last interaction.
• Marketing consent records are retained for as long as you remain a registered player and for a reasonable period thereafter to demonstrate compliance.
• Technical and usage data collected via cookies and analytics tools is retained in accordance with the cookie retention periods described in Section 9.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with www.winph's data disposal procedures.

www.winph implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the www.winph platform.
• Encryption of sensitive data at rest, including payment information and government ID data.
• Role-based access controls limiting access to personal data to authorized personnel on a need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of platform infrastructure.
• Audit logging of access to personal data systems, with regular review by the security team.
• Staff training on data privacy obligations and information security best practices.

www.winph uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and support security and fraud prevention functions. A cookie is a small text file placed on your device when you visit the platform.

• Strictly necessary cookies: Required for the platform to function correctly, including session management, authentication, and security. These cannot be disabled.
• Functional cookies: Remember your preferences and settings (e.g., language, display preferences) to provide a more personalized experience.
• Analytics cookies: Collect aggregated, anonymized data about how players use the platform, helping www.winph improve its Services. Retained for up to 13 months.
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the www.winph platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the Services.

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 www.winph:

To exercise any of the above rights, please contact the www.winph Data Protection Officer using the contact details provided in Section 14. www.winph will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with NPC guidelines.

The www.winph platform is strictly intended for individuals who are 21 years of age or older. www.winph does not knowingly collect, process, or retain personal data from individuals under the age of 21.

If www.winph becomes aware that personal data has been collected from a person under 21 years of age, it will take immediate steps to delete such data and close the associated account. Any funds deposited by an underage player will be handled in accordance with applicable PAGCOR regulations and Philippine law.

If you are a parent or guardian and believe that your child under the age of 21 has registered an account or provided personal data to www.winph, please contact the Data Protection Officer immediately using the details in Section 14.

In the course of providing the Services, www.winph may transfer your personal data to recipients located outside the Philippines — for example, to game software providers or technology infrastructure partners operating in other jurisdictions.

Where such cross-border transfers occur, www.winph ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the NPC.
• Implementing contractual clauses or data processing agreements that impose data protection obligations on the recipient equivalent to those required under Philippine law.
• Obtaining your explicit consent for transfers where required by the DPA and NPC guidelines.

www.winph will not transfer your personal data to any jurisdiction or recipient that does not provide adequate protections consistent with the Data Privacy Act of 2012.

www.winph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The "Last Updated" date at the top of this page will be revised accordingly whenever material changes are made.

Where changes are material — meaning they significantly affect your rights or the way we process your personal data — www.winph will provide advance notice to registered players via email or an on-platform notification prior to the changes taking effect.

Your continued use of the www.winph platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated Policy, you must cease using the Services and may request account closure in accordance with the Terms & Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how www.winph protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by www.winph, please contact our Data Protection Officer. Our DPO is available to assist with all data privacy matters, including data subject rights requests and privacy complaints.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available through official Philippine government channels.