Privacy Policy

01 Introduction

phwin9 ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all users who access or register on the phwin9 online gaming platform at phwin9.net. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

This policy is drafted in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. It also reflects our obligations under PAGCOR's regulatory framework for licensed online gaming operators.

By accessing the phwin9 platform, creating a player account, or using any of our 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 any part of this policy, you should discontinue use of the phwin9 platform.

This Privacy Policy should be read together with the phwin9 Terms & Conditions, which govern your use of the platform.

02 Data Controller

For the purposes of the Data Privacy Act of 2012, phwin9 acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players and website visitors.

As the Personal Information Controller, phwin9 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.

phwin9 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. Contact details for the DPO are provided in Section 15 of this policy.

03 Personal Data We Collect

phwin9 collects the following categories of personal data from players and website visitors:

04 How We Collect Your Data

phwin9 collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the phwin9 platform, including through cookies, web beacons, and server logs.
• Third-Party Sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank.
• Regulatory Sources: Information received from PAGCOR or other regulatory authorities in connection with licensing, compliance, or investigation requirements.

05 How We Use Your Personal Data

phwin9 uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your player account, including processing registrations, verifying your identity, and managing account settings.
• Transaction Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods in Philippine Peso (₱).
• Regulatory Compliance: To fulfil our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012, including KYC verification and suspicious transaction reporting.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the platform.
• Responsible Gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyse usage patterns and improve the functionality, performance, and user experience of the phwin9 platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have opted in to receive such communications. You may opt out at any time.
• Legal Proceedings: To establish, exercise, or defend legal claims in connection with your use of the phwin9 platform.

06 Legal Basis for Processing

phwin9 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and phwin9 — specifically, to operate your player account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act of 2012.
• Legitimate Interests: Processing is necessary for phwin9's legitimate interests in fraud prevention, platform security, and business improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

07 Data Sharing & Disclosure

phwin9 does not sell, rent, or trade your personal data. We may share your 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.
• KYC & Identity Verification Providers: Third-party identity verification services used to fulfil our KYC obligations under PAGCOR regulations and the AMLA.
• Fraud Prevention Services: Anti-fraud and risk management partners who assist phwin9 in detecting and preventing fraudulent activity on the platform.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory obligation.
• Legal and Professional Advisers: Lawyers, auditors, and other professional advisers engaged by phwin9 in connection with legal proceedings or compliance activities, subject to confidentiality obligations.
• IT and Platform Service Providers: Cloud hosting, data storage, and platform infrastructure providers who process data on phwin9's behalf under strict data processing agreements.

08 Data Retention

phwin9 retains your 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 Data: Retained for the duration of your active account, plus a minimum of 5 years following account closure, in accordance with PAGCOR record-keeping requirements and the AMLA.
• Transaction Records: Retained for a minimum of 5 years from the date of each transaction, as required by the Anti-Money Laundering Act.
• KYC Documents: Retained for a minimum of 5 years following the end of the business relationship, or longer if required by regulatory authorities.
• Support Communications: Retained for 2 years from the date of the last communication, unless required for ongoing legal proceedings.
• Technical and Usage Data: Retained for up to 12 months for security and analytics purposes, after which it is anonymised or deleted.
• Marketing Preferences: Retained until you withdraw consent or request deletion, whichever is earlier.

When personal data is no longer required, phwin9 will securely delete or anonymise it in accordance with our data disposal procedures.

09 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phwin9:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed — which this Privacy Policy fulfils.
• Right of Access: The right to request a copy of the personal data phwin9 holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by phwin9.
• 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 phwin9'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 legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and 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 phwin9 has violated your data privacy rights.

10 Cookies & Tracking Technologies

phwin9 uses cookies and similar tracking technologies to operate and improve 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.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Analytics Cookies: Used to collect anonymised data about how players use the phwin9 platform, helping us identify areas for improvement. No personally identifiable information is collected through analytics cookies.

phwin9 does not use third-party advertising or tracking cookies. You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the phwin9 platform.

11 Data Security

phwin9 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• SSL/TLS Encryption: All data transmitted between your device and the phwin9 platform is encrypted using industry-standard SSL/TLS protocols.
• Secure Data Storage: Personal data is stored on secure servers with restricted access controls, firewalls, and intrusion detection systems.
• Access Controls: Access to personal data within phwin9 is restricted to authorised personnel on a need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-Factor Authentication: phwin9 supports two-factor authentication (2FA) for player accounts to provide an additional layer of security.
• Regular Security Audits: phwin9 conducts regular security assessments and penetration testing to identify and address potential vulnerabilities.
• Incident Response: In the event of a personal data breach, phwin9 will notify affected players and the National Privacy Commission within the timeframes required by the Data Privacy Act of 2012.

While phwin9 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying phwin9 immediately if you suspect any unauthorised access to your account.

12 Children's Privacy

The phwin9 platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations and Philippine law governing real-money gaming activities.

phwin9 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately suspend the associated account, delete the data, and return any deposits in accordance with applicable regulations.

If you are a parent or guardian and believe that a minor has registered on the phwin9 platform, please contact our support team immediately so that we can take appropriate action.

13 International Data Transfers

phwin9 primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international KYC verification services.

Where personal data is transferred outside the Philippines, phwin9 ensures that appropriate safeguards are in place to protect your data, including:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission.
• Entering into data processing agreements with international service providers that incorporate the standard contractual clauses approved by the NPC.
• Conducting due diligence on all international data processors to ensure compliance with applicable data protection standards.

14 Changes to This Privacy Policy

phwin9 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email or a prominent notice on the phwin9 platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed of how phwin9 protects your personal data.

Your continued use of the phwin9 platform following the publication of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with any changes, you should discontinue use of the platform and may request account closure by contacting our support team.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by phwin9, please contact our Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.