winp Privacy Policy

winp ("we", "us", "our") operates the online gaming platform accessible at winp.one. We are committed to protecting the personal data of all players, visitors, and users of the winp platform in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

This Privacy Policy applies to all personal information collected through the winp website, mobile platform, customer support channels, and any other service operated under the winp brand. It describes:

• What categories of personal data winp collects and processes;
• The purposes for which that data is used;
• The legal bases on which winp relies to process your data;
• How long winp retains your data and how it is protected;
• Your rights as a data subject under Philippine law; and
• How to contact winp's Data Protection Officer (DPO).

winp collects personal data through several channels: directly from you during registration and account use, automatically through your interaction with the platform, and from third parties such as payment processors and identity verification providers. The categories of data we collect are set out below.

winp uses the personal data it collects for the following purposes. Each purpose is linked to a legal basis described in Section 4.

• Account creation and management: To register your winp account, verify your identity, and maintain your account in good standing.
• Service delivery: To provide access to winp games, process bets, credit winnings, and operate all platform features.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay, and to maintain accurate financial records.
• KYC and fraud prevention: To verify your identity and age (21+), detect and prevent fraudulent activity, money laundering, and other prohibited conduct.
• Regulatory compliance: To meet winp's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and NPC regulations.
• Responsible gaming: To monitor gaming behaviour, apply responsible gaming tools (deposit limits, self-exclusion), and identify players who may need support.
• Customer support: To respond to your queries, complaints, and requests through live chat and email.
• Platform improvement: To analyse usage patterns, fix technical issues, and improve the winp platform experience for all players.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your consent, and subject to your right to opt out at any time.
• Security: To detect and investigate unauthorised access, protect the integrity of the platform, and safeguard player accounts.

winp processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform the contract between you and winp — including account registration, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing conditions, AMLA reporting obligations, and NPC data privacy requirements.
• Legitimate interests: Processing necessary for winp's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

winp does not sell, rent, or trade your personal data. We share your data with third parties only in the following limited circumstances, and only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay receive the financial data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are bound by data processing agreements with winp.
• Identity verification providers: winp uses third-party KYC service providers to verify government-issued IDs and conduct age verification. These providers process identity data solely for verification purposes.
• Regulatory authorities: winp is required to share certain data with PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission as required by law. winp will comply with valid legal orders and regulatory requests.
• Technology and hosting providers: winp uses cloud infrastructure and software providers to operate the platform. These providers act as data processors under winp's instruction and are contractually prohibited from using your data for their own purposes.
• Professional advisers: winp may share data with lawyers, auditors, and compliance consultants where necessary for legal proceedings, audits, or regulatory matters, subject to professional confidentiality obligations.

winp uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse usage patterns. The types of cookies used on winp.one are as follows:

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the winp platform. For detailed information on the specific cookies in use, please contact winp's Data Protection Officer.

winp retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following 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 accordance with PAGCOR licensing requirements and AMLA obligations.
• Financial and transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• KYC documents: Retained for the duration of your account and for five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Gaming and session logs: Retained for a minimum of two (2) years from the date of each session, for dispute resolution and regulatory audit purposes.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless the matter is subject to ongoing legal proceedings.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of compliance.

Upon expiry of the applicable retention period, winp will securely delete or anonymise your personal data in accordance with NPC guidelines.

winp implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Encryption in transit: All data transmitted between your device and winp servers is encrypted using TLS 1.2 or higher (256-bit SSL).
• Encryption at rest: Sensitive personal data stored on winp servers is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data is restricted to winp personnel and authorised processors who require it to perform their duties. All access is logged and audited.
• Two-factor authentication: winp supports two-factor authentication (2FA) for player accounts to reduce the risk of unauthorised access.
• Penetration testing: winp conducts regular security assessments and penetration tests to identify and remediate vulnerabilities.
• Staff training: All winp personnel with access to personal data receive regular data privacy and security training.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by winp. winp is committed to facilitating the exercise of these rights promptly and without undue burden.

To exercise any of the above rights, contact winp's Data Protection Officer using the details in Section 13. winp will respond to all data subject requests within fifteen (15) business days of receipt. In complex cases, this period may be extended by a further fifteen (15) business days, with notice provided to you.

The winp platform is strictly intended for individuals aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. winp does not knowingly collect personal data from persons under the age of 21.

winp employs age verification technology during the registration process to prevent underage access. If winp discovers that personal data has been collected from a person under 21, that account will be immediately suspended, all data will be deleted (subject to any legal retention obligations), and any deposited funds will be returned to the source payment method.

winp primarily stores and processes personal data within the Philippines. In certain circumstances — for example, where winp uses cloud infrastructure or third-party service providers with servers located outside the Philippines — your personal data may be transferred to and processed in other countries.

Where such transfers occur, winp ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised by the NPC;
• Entering into data processing agreements with all third-party processors that include standard contractual clauses approved by the NPC; and
• Conducting due diligence on all third-party processors to verify their data security practices prior to engagement.

By using the winp platform, you acknowledge that your personal data may be transferred outside the Philippines in the circumstances described above, subject to the safeguards set out in this section.

winp may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material — for example, where we introduce a new purpose for processing your data or change the categories of third parties with whom we share your data — winp will notify registered players by email and/or by a prominent notice on the platform at least fourteen (14) days before the changes take effect.

Your continued use of the winp platform following the effective date of any update constitutes your acknowledgement of the revised Privacy Policy. If you do not agree with the updated Policy, you may request account closure by contacting winp support.

winp has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data, please contact the winp DPO through the following channels:

• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through the winp platform after logging in to your account.

winp's DPO will acknowledge all privacy-related enquiries within two (2) business days and provide a substantive response within fifteen (15) business days. For complex data subject requests, this period may be extended as described in Section 9.

If you are not satisfied with winp's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act.