phlwin.com Privacy Policy

1. Introduction and Scope

1.1 This Privacy Policy ("Policy") describes how phlwin.com ("we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "your," or "User") who access or use the phlwin.com platform, including the website at phlwincom.vip and any associated mobile-optimized interfaces (collectively, the "Platform").

1.2 By registering an account, logging in, 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 Platform.

1.3 This Policy applies to all personal data collected through the Platform, including data collected during account registration, identity verification, deposits and withdrawals, gameplay, customer support interactions, and marketing communications.

1.4 This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform and form part of the overall agreement between you and phlwin.com.

2. Data Controller Information

2.1 For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, phlwin.com acts as the personal information controller in respect of the personal data it collects from users of the Platform.

2.2 If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy.

3. Information We Collect

3.1 phlwin.com collects the following categories of personal information from users:

3.1 Identity and Contact Information

• Full legal name as it appears on a government-issued Philippine ID
• Date of birth (to verify the 21+ age requirement)
• Registered Philippine mobile number
• Email address (where provided)
• Residential address in the Philippines

3.2 Identity Verification (KYC) Documents

• Copies of government-issued Philippine identification (e.g., PhilSys National ID, passport, driver's license, UMID, SSS ID, voter's ID)
• Selfie or live photo for facial verification purposes
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account showing registered name)

3.3 Financial Information

• GCash or PayMaya account reference (account name and number, not full credentials)
• Bank account details for InstaPay/PESONet transfers (account name and number)
• Transaction history including deposits, withdrawals, and gaming activity
• Account balance and bonus balance information

3.4 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, pages visited, and features used on the Platform
• Login timestamps and access logs
• Cookies and similar tracking technologies (see Section 10)

3.5 Communications Data

• Records of live chat conversations with customer support
• Feedback, complaints, and dispute correspondence
• Responses to surveys or promotional communications (where you have opted in)

4. How We Collect Your Data

4.1 phlwin.com collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions.
• Automatically — through cookies, web beacons, and server logs when you access and navigate the Platform.
• From third-party payment providers — GCash, PayMaya/Maya, and participating Philippine banks may share transaction confirmation data with us to verify deposits and withdrawals.
• From identity verification partners — where we engage third-party KYC service providers to assist with document verification and fraud prevention.
• From regulatory and law enforcement authorities — where we are legally required to receive or share information in connection with anti-money laundering (AML) obligations or other regulatory requirements.

5. How We Use Your Information

5.1 phlwin.com uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Name, mobile number, date of birth, email
Identity verification (KYC / AML compliance)	Government ID, selfie, proof of payment method
Processing deposits and withdrawals	Financial account details, transaction history
Fraud prevention and platform security	IP address, device data, login logs, transaction patterns
Customer support and dispute resolution	Communications data, account history
Responsible gaming monitoring	Gaming activity, deposit patterns, session data
Marketing and promotional communications	Name, mobile number, email (with consent)
Regulatory reporting and legal compliance	Identity data, financial data, transaction records
Platform improvement and analytics	Usage data, cookies, session data (aggregated/anonymized)

6. Legal Basis for Processing

6.1 Under the Data Privacy Act of 2012, phlwin.com processes your personal data on the following legal bases:

• Contractual necessity — processing required to perform our obligations under the Terms & Conditions, including account management, payment processing, and gameplay.
• Legal obligation — processing required to comply with Philippine laws, including AML regulations, PAGCOR reporting requirements, and tax obligations.
• Legitimate interests — processing for fraud prevention, platform security, and responsible gaming monitoring, where our interests do not override your rights.
• Consent — processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time by contacting support or updating your account preferences.

7. Sharing and Disclosure

7.1 phlwin.com does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data only in the following circumstances:

• Payment processors — GCash, PayMaya/Maya, and participating Philippine banks, solely to facilitate deposits and withdrawals.
• KYC and fraud prevention partners — third-party identity verification providers engaged to assist with document verification and fraud detection.
• Game content providers — where required to deliver live dealer or third-party game content, limited to session authentication data only.
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law.
• Law enforcement — where we receive a valid legal order, subpoena, or court order requiring disclosure.
• Business transfers — in the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to the same privacy protections.

8. Data Retention

8.1 phlwin.com retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law. Specifically:

• Account and KYC data — retained for a minimum of five (5) years following account closure, in compliance with AML regulations.
• Transaction records — retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications — retained for two (2) years from the date of the last interaction.
• Marketing consent records — retained until consent is withdrawn, plus one (1) year thereafter for compliance documentation.
• Technical and usage logs — retained for up to twelve (12) months, after which they are anonymized or deleted.

8.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with our internal data disposal procedures.

9. Security Measures

9.1 phlwin.com implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform
• Encryption of sensitive data at rest, including KYC documents and financial records
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Multi-factor authentication for internal systems handling personal data
• Regular security audits and vulnerability assessments
• Incident response procedures for detecting and responding to data breaches

9.2 In the event of a personal data breach that is likely to result in harm to affected users, phlwin.com will notify the National Privacy Commission (NPC) and affected users within the timeframes prescribed by the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

10. Cookies and Tracking

10.1 phlwin.com uses cookies and similar tracking technologies to enhance your experience on the Platform. The types of cookies we use are:

• Strictly necessary cookies — required for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies — remember your preferences such as language settings and display options.
• Analytics cookies — collect aggregated, anonymized data about how users interact with the Platform to help us improve performance and usability.
• Marketing cookies — used to deliver relevant promotional content. These are only set with your explicit consent.

10.2 You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

11. Your Rights Under the DPA

11.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phlwin.com:

11.2 To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified requests within thirty (30) days, as required by the DPA.

12. Minors and Age Restriction

12.1 The phlwin.com Platform is strictly intended for individuals aged 21 years and older. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.

12.2 If you believe that a minor has registered an account on the Platform, please contact our support team immediately so that we can investigate and take appropriate action.

13. Cross-Border Data Transfers

13.1 In certain circumstances, your personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or KYC technology partners. Where such transfers occur, phlwin.com ensures that appropriate safeguards are in place, including contractual data processing agreements that require the recipient to maintain standards equivalent to those required by the Data Privacy Act of 2012.

13.2 By using the Platform, you consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

14. Changes to This Policy

14.1 phlwin.com may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. The revised Policy will be published on the Platform with an updated effective date.

14.2 Where changes are material, we will notify registered users via their registered mobile number or email address prior to the changes taking effect. Your continued use of the Platform following notification constitutes acceptance of the revised Policy.

15. Contact and Complaints

15.1 For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer:

Data Protection Officer — phlwin.com
Email: [email protected]
Support: Available 24/7 via live chat on the Platform

15.2 If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.