phwin99 Privacy Policy

1Introduction

This Privacy Policy ("Policy") describes how phwin99 ("phwin99," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the phwin99 website at phwin99.org and all associated services, features, and content (collectively, the "Platform").

phwin99 is committed to protecting your privacy and handling your personal data with transparency, integrity, and respect. This Policy is drafted in compliance with Republic Act No. 10173, the Philippine Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC").

By registering an account on phwin99 or continuing to use the Platform, 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, please discontinue use of the Platform and contact us to close your account.

2Data Controller

phwin99 is the personal information controller ("PIC") in respect of the personal data collected through the Platform. As PIC, phwin99 determines the purposes and means of processing your personal information and is responsible for ensuring that such processing complies with the DPA and all applicable regulations.

phwin99 has appointed 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 13 of this Policy.

3Personal Data We Collect

phwin99 collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected. The categories of personal data we collect include:

phwin99 does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly required for identity verification and AML compliance. Where sensitive personal information is collected, it is processed with heightened security measures and only for the specific purpose for which it was obtained.

4How We Use Your Personal Data

phwin99 uses your personal data for the following purposes:

• Account Management — To create, verify, maintain, and administer your phwin99 account, including processing deposits and withdrawals in Philippine Peso (PHP).
• Identity Verification (KYC) — To verify your identity and age (21+) as required by PAGCOR regulations and to prevent underage gambling and fraud.
• Anti-Money Laundering (AML) — To monitor transactions, detect suspicious activity, and comply with the Anti-Money Laundering Act of 2001 (Republic Act No. 9160, as amended) and PAGCOR AML guidelines.
• Platform Operation — To deliver, maintain, and improve the phwin99 Platform, including game delivery, customer support, and technical troubleshooting.
• Responsible Gaming — To monitor gaming behaviour, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling.
• Communications — To send you account notifications, security alerts, promotional offers (where you have opted in), and responses to your support enquiries.
• Legal Compliance — To comply with applicable Philippine laws, PAGCOR regulations, court orders, and lawful requests from government authorities.
• Analytics & Improvement — To analyse aggregated, anonymised usage data to improve Platform performance, game selection, and user experience.

phwin99 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your separate consent.

5Legal Basis for Processing

phwin99 processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity — Processing is necessary to perform our obligations under the phwin99 Terms and Conditions, including operating your account and processing transactions.
• Legal Obligation — Processing is required to comply with applicable Philippine laws, including the DPA, the Anti-Money Laundering Act, and PAGCOR regulatory requirements.
• Legitimate Interests — Processing is necessary for phwin99's legitimate interests in fraud prevention, platform security, and responsible gaming enforcement, provided these interests are not overridden by your rights and freedoms.
• Consent — For certain processing activities, such as sending marketing communications, we rely on your consent, which you may withdraw at any time by updating your communication preferences in your phwin99 account settings.

6Data Sharing and Disclosure

phwin99 does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data only in the following circumstances:

• Service Providers — We engage trusted third-party service providers (personal information processors) to assist in operating the Platform, including payment processors (GCash, Maya, Philippine banks), identity verification providers, cloud hosting services, and customer support platforms. These providers are contractually bound to process your data only on phwin99's instructions and in compliance with the DPA.
• Regulatory Authorities — phwin99 is required to disclose certain player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities where required by law or regulation.
• Law Enforcement — We may disclose personal data to law enforcement agencies in response to a valid court order, subpoena, or other lawful legal process.
• Business Transfers — In the event of a merger, acquisition, or sale of all or substantially all of phwin99's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.
• With Your Consent — We may share your data with third parties where you have given your explicit, informed consent to such sharing.

Where personal data is shared with third parties outside the Philippines, phwin99 ensures that appropriate safeguards are in place to protect your data in accordance with the DPA's cross-border transfer requirements.

7Data Retention

phwin99 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations.

• Active Accounts — Personal data is retained for the duration of your phwin99 account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Transaction Records — Financial transaction records are retained for a minimum of five (5) years as required under the Anti-Money Laundering Act.
• Support Communications — Customer support records are retained for three (3) years from the date of the last interaction.
• Marketing Data — Where you have opted in to marketing communications, your contact details for this purpose are retained until you withdraw your consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with phwin99's data disposal procedures.

8Cookies and Tracking Technologies

phwin99 uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how the Platform is used.

We use the following categories of cookies:

• Strictly Necessary Cookies — Essential for the Platform to function, including maintaining your login session and processing transactions. These cannot be disabled.
• Functional Cookies — Remember your preferences such as language settings and game display options to personalise your phwin99 experience.
• Analytics Cookies — Help us understand how players use the Platform so we can improve performance and game offerings. Data collected is aggregated and anonymised.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the phwin99 Platform. phwin99 does not use cookies to serve third-party advertising or build profiles for external marketing networks.

9Security Measures

phwin99 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• TLS (Transport Layer Security) encryption for all data transmitted between your device and the phwin99 Platform.
• AES-256 encryption for sensitive data stored at rest on phwin99 servers.
• Multi-factor authentication (MFA) options for player accounts.
• Regular independent penetration testing and security audits.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Incident response procedures to detect, report, and address personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phwin99 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where required by the DPA.

10Your Data Privacy Rights

Under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by phwin99:

• Right to be Informed — You have the right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of Access — You may request a copy of the personal data phwin99 holds about you, along with information about how it is being processed.
• Right to Rectification — You may request correction of any inaccurate or incomplete personal data we hold about you.
• 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 phwin99's 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 interests.
• Right to Data Portability — You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint — You have the right to lodge a complaint with the National Privacy Commission if you believe phwin99 has violated your data privacy rights.

To exercise any of these rights, please contact phwin99's Data Protection Officer using the contact details in Section 13. We will respond to all verified requests within fifteen (15) business days, as required under the DPA.

11Children's Privacy and Age Restriction

The phwin99 Platform is strictly intended for individuals aged 21 years and above, in compliance with Philippine law and PAGCOR regulations governing online gaming. phwin99 does not knowingly collect personal data from individuals under the age of 21.

If phwin99 becomes aware that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, void any transactions, and securely delete the personal data in question. If you believe a minor has registered on phwin99, please contact our support team immediately.

phwin99 recommends that parents and guardians install parental control software on shared devices to prevent underage access to online gambling platforms.

12Changes to This Privacy Policy

phwin99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Where changes are material, phwin99 will notify registered players via email or an in-platform notification prior to the changes taking effect.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the phwin99 Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically.

13Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by phwin99, please contact our Data Protection Officer:

phwin99 aims to acknowledge all privacy-related enquiries within 5 business days and to resolve them within 15 business days. If you are not satisfied with our response, you may escalate your complaint to the National Privacy Commission of the Philippines.