wi1win Privacy Policy

1 Who We Are

wi1win is an online gaming platform accessible at wi1win.net, operated under PAGCOR oversight and designed specifically for Filipino players across the Philippines — from Metro Manila and Cebu to Davao, Quezon City, and beyond. For the purposes of this Privacy Policy, wi1win acts as the Personal Information Controller (as defined under Republic Act No. 10173, the Data Privacy Act of 2012) in respect of all personal data collected through the wi1win platform.

This Privacy Policy applies to all personal data collected through the wi1win website, mobile platform, customer support channels, and any other touchpoint through which you interact with wi1win. It should be read together with our Terms & Conditions.

2 Personal Data We Collect

wi1win collects the following categories of personal data, depending on how you interact with our platform:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., PhilSys ID, passport, driver's license, SSS/GSIS number).
• Contact Data: Philippine mobile number, email address, and residential address.
• Account Data: Username, encrypted password, account preferences, and communication history with wi1win support.
• Financial Data: GCash number, PayMaya/Maya account details, bank account details (for bank transfer transactions), transaction history, deposit and withdrawal records. wi1win does not store full payment card numbers.
• Gaming Data: Game history, wagering activity, session duration, win/loss records, and responsible gaming tool usage (e.g., deposit limits set, self-exclusion requests).
• Technical Data: IP address, device type, operating system, browser type and version, time zone, and platform access logs.
• Usage Data: Pages visited, features used, click-through data, and session recordings (where applicable and disclosed).
• Verification Data: Copies of government-issued ID, selfie photographs, and proof of address documents submitted during KYC verification.

3 How We Collect Your Data

wi1win collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the wi1win platform, including through cookies, server logs, and analytics tools.
• Third-party sources: Identity verification data from licensed KYC service providers; fraud prevention data from anti-money laundering screening services; payment data from GCash, PayMaya, and banking partners (limited to transaction confirmation and account validation).

4 Legal Basis for Processing

wi1win processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable PAGCOR regulations:

• Contractual necessity: Processing required to create and manage your wi1win account, process deposits and withdrawals, and deliver gaming services pursuant to our Terms & Conditions.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5 How We Use Your Personal Data

wi1win uses your personal data for the following purposes:

• To create, verify, and manage your wi1win account.
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP).
• To verify your identity and age (21+) in compliance with PAGCOR requirements and Philippine law.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities.
• To monitor gaming activity for responsible gaming purposes, including identifying signs of problem gambling and applying player-requested limits or exclusions.
• To provide customer support and respond to your inquiries.
• To send you transactional communications (account confirmations, withdrawal notifications, security alerts) — these are not optional as they are necessary for account operation.
• To send you promotional communications about wi1win offers and new games, where you have consented to receive such communications.
• To improve the wi1win platform through aggregate usage analysis and A/B testing.
• To comply with our legal and regulatory obligations under Philippine law.

6 Sharing Your Personal Data

wi1win does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances:

• Service providers: Trusted third-party vendors who assist us in operating the wi1win platform, including KYC/identity verification providers, payment processors (GCash, PayMaya, banking partners), cloud hosting providers, and customer support platforms. All service providers are bound by data processing agreements requiring them to protect your data and use it only for the specified purpose.
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where disclosure is required by law, court order, or regulatory directive.
• Fraud prevention: Licensed fraud prevention and anti-money laundering screening services, where sharing is necessary to protect wi1win and its players from financial crime.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of wi1win's business, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.

7 Cookies & Tracking Technologies

wi1win uses cookies and similar tracking technologies to enhance your experience on 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 without affecting platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display options, so you do not need to re-enter them on each visit.
• Analytics cookies: Used to collect aggregate, anonymized data about how players use the wi1win platform — such as which pages are visited most frequently and where users encounter errors. This data helps us improve the platform. No personally identifiable information is included in analytics reports.

wi1win does not use third-party advertising or tracking cookies. You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling certain cookies may affect the functionality of some platform features.

We may also use web beacons (small transparent image files) in transactional emails to confirm that emails have been received and opened. This helps us ensure that important account communications are reaching you.

8 Data Security

wi1win implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption in transit: All data transmitted between your device and wi1win's servers is protected by TLS 1.3 encryption.
• Encryption at rest: Sensitive data stored on wi1win's servers — including identity documents and financial records — is encrypted using AES-256.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. wi1win staff with access to personal data are subject to confidentiality obligations and regular security training.
• Two-factor authentication: Available for all player accounts and mandatory for administrative access to wi1win's internal systems.
• Regular security audits: wi1win's infrastructure and data handling practices are subject to periodic third-party security assessments and penetration testing.
• Incident response: wi1win maintains a documented data breach response plan. In the event of a breach affecting your personal data, we will notify the National Privacy Commission and affected players in accordance with the timelines prescribed under RA 10173 and its Implementing Rules and Regulations.

While wi1win takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your wi1win account credentials and for notifying us immediately of any suspected unauthorized access.

9 Data Retention

wi1win retains your personal data for as long as is necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction and gaming records: Retained for a minimum of five (5) years from the date of the transaction, as required by PAGCOR and AMLC regulations.
• KYC verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer support records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for as long as you remain subscribed to marketing communications, plus three (3) years thereafter as evidence of consent.
• Technical and usage data: Retained in aggregate, anonymized form for up to two (2) years for platform analytics purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with wi1win's data disposal procedures.

10 Your Data Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in respect of your personal data held by wi1win:

• Right to be informed: The right to know what personal data wi1win collects about you, how it is used, and with whom it is shared — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data wi1win holds about you, together with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to wi1win's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on wi1win's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller, where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe wi1win has processed your personal data in violation of RA 10173.

To exercise any of the above rights, please contact wi1win's Data Protection Officer using the contact details in Section 15. wi1win will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11 Children's Privacy

The wi1win platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming law and PAGCOR regulations. wi1win does not knowingly collect personal data from individuals under the age of 21.

If wi1win becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data, and report the matter to the appropriate regulatory authorities where required.

If you are a parent or guardian and believe that a minor has registered on the wi1win platform, please contact our support team immediately so that we can take prompt action.

12 International Data Transfers

wi1win's primary data processing infrastructure is located within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines — for example, cloud hosting or KYC verification services — wi1win ensures that such transfers are conducted in compliance with the Data Privacy Act of 2012 and NPC regulations.

Specifically, wi1win ensures that any international transfer of personal data is subject to one or more of the following safeguards:

• A data processing agreement incorporating standard contractual clauses approved by the NPC or equivalent data protection authority.
• Transfer to a jurisdiction recognized by the NPC as providing an adequate level of data protection.
• Your explicit consent to the transfer, where required.

13 Third-Party Links

The wi1win platform may contain links to third-party websites or services, including game providers and payment processors. This Privacy Policy applies solely to data collected by wi1win and does not cover the privacy practices of any third-party websites or services.

wi1win is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party services you access through or in connection with the wi1win platform.

14 Updates to This Privacy Policy

wi1win 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, wi1win will provide advance notice to registered players via email or a prominent notice on the platform prior to the changes taking effect.

The "Last Updated" date at the top of this page will always reflect the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how wi1win protects your personal data. Your continued use of the wi1win platform following any update constitutes your acknowledgment of the revised Policy.

15 Contact & Data Protection Officer

wi1win has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-01. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO:

• Data Protection Officer, wi1win
• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the wi1win platform

If you are not satisfied with wi1win's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.