phwine Privacy Policy

1 Introduction

phwine ("we," "us," or "our") operates the online gaming platform accessible at phwine.net. We are committed to protecting the privacy and personal data of all individuals who interact with our platform, including registered players, visitors, and prospective users.

This Privacy Policy ("Policy") explains what personal data phwine collects, why we collect it, how we use and protect it, and what rights you have in relation to your personal data. This Policy applies to all personal data collected through the phwine website, mobile platform, customer support channels, and any other touchpoints associated with the phwine brand.

This Policy is issued in compliance 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) of the Philippines. phwine is registered as a personal information controller with the NPC in accordance with applicable requirements.

2 Personal Data We Collect

phwine collects personal data that is necessary to provide our gaming services, comply with legal obligations, and improve the player experience. The categories of personal data we collect include:

phwine does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive personal information is collected (such as government ID details), it is handled with additional safeguards in accordance with the Data Privacy Act of 2012.

3 How We Use Your Personal Data

phwine uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your phwine player account, including identity verification and KYC compliance;
• Service Delivery: To provide access to phwine's gaming products, process bets and wagers, and deliver winnings and bonuses;
• Financial Transactions: To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card, and to maintain accurate financial records;
• Legal and Regulatory Compliance: To comply with PAGCOR licensing requirements, Philippine anti-money laundering (AML) laws, and the Data Privacy Act of 2012, including mandatory reporting obligations;
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and administer responsible gaming tools such as deposit and loss limits;
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the phwine platform;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time;
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features and performance of the phwine platform.

4 Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to provide the phwine gaming services you have registered for;
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including the Data Privacy Act of 2012, PAGCOR regulations, and anti-money laundering legislation;
• Legitimate Interests: Processing is necessary for phwine's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms;
• Consent: For certain processing activities, such as marketing communications and the use of non-essential cookies, phwine relies on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 Sharing Your Personal Data

phwine does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary and permitted by law:

• Payment Service Providers: We share financial data with payment processors such as GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) solely to facilitate deposits and withdrawals on your behalf;
• Identity Verification Providers: We engage third-party KYC and identity verification service providers to assist with age verification (21+) and anti-money laundering checks as required by PAGCOR and Philippine law;
• Technology and Infrastructure Partners: We work with cloud hosting, data storage, and platform technology providers who process data on our behalf under strict data processing agreements that require them to protect your data in accordance with the Data Privacy Act of 2012;
• Regulatory and Law Enforcement Authorities: We may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other Philippine government authorities where required by law or in response to a valid legal order;
• Professional Advisers: We may share data with our legal, financial, and compliance advisers where necessary for the conduct of our business, subject to professional confidentiality obligations;
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of phwine's business, your personal data may be transferred to the relevant successor entity, subject to the same privacy protections described in this Policy.

6 Cookies and Tracking Technologies

phwine uses cookies and similar tracking technologies on its platform to enhance your experience, maintain session security, and gather analytics data. The types of cookies we use include:

• Strictly Necessary Cookies: These cookies are essential for the phwine platform to function correctly. They enable core features such as secure login, session management, and fraud prevention. These cookies cannot be disabled without affecting platform functionality;
• Performance and Analytics Cookies: These cookies collect anonymized information about how players use the phwine platform, such as which pages are visited most frequently and how long sessions last. This data helps us improve platform performance and user experience;
• Functional Cookies: These cookies remember your preferences, such as your preferred language and display settings, to provide a more personalized experience on the phwine platform;
• Marketing Cookies: With your consent, we may use cookies to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. You may withdraw consent for marketing cookies at any time through your browser settings or our cookie preference center.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the phwine platform. For more information on managing cookies, refer to your browser's help documentation.

7 Data Security

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

• SSL/TLS Encryption: All data transmitted between your device and the phwine platform is encrypted using industry-standard Secure Sockets Layer (SSL) / Transport Layer Security (TLS) protocols;
• Access Controls: Access to personal data within phwine's systems is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations;
• Two-Factor Authentication: phwine offers two-factor authentication (2FA) for player accounts to provide an additional layer of protection against unauthorized access;
• Regular Security Audits: phwine conducts regular security assessments and penetration testing to identify and address potential vulnerabilities in our platform infrastructure;
• Data Breach Response: In the event of a personal data breach that poses a risk to your rights and freedoms, phwine will notify the National Privacy Commission and affected individuals in accordance with the timelines and requirements of the Data Privacy Act of 2012 and NPC regulations.

8 Data Retention

phwine retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention principles apply:

• Active Accounts: Personal data associated with active phwine accounts is retained for the duration of the account relationship and for a period thereafter as required by law;
• Closed Accounts: Following the closure of a phwine account, personal data is retained for a minimum of five (5) years in accordance with PAGCOR record-keeping requirements and Philippine AML regulations under Republic Act No. 9160, as amended;
• Financial Records: Transaction records and financial data are retained for the periods required by applicable Philippine tax and financial regulations;
• Marketing Data: Personal data used for marketing purposes is retained until you withdraw your consent or opt out of marketing communications, after which it is deleted or anonymized within a reasonable period;
• Support Records: Customer support communications are retained for a period sufficient to resolve disputes and for quality assurance purposes, typically not exceeding three (3) years from the date of the last interaction.

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

9 Your Data Subject Rights

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

• Right to Be Informed: You have the right to be informed about how phwine collects and processes your personal data, as described in this Privacy Policy;
• Right of Access: You have the right to request a copy of the personal data phwine holds about you and information about how it is being processed;
• Right to Rectification: You have the right to request the correction of any inaccurate or incomplete personal data phwine holds about you;
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phwine's legal retention obligations;
• Right to Object: You have 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: You have 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: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that phwine has violated your data privacy rights.

To exercise any of these rights, please contact phwine's Data Protection Officer using the contact details provided in Section 13 of this Policy. phwine will respond to all data subject requests within the timeframes required by the Data Privacy Act of 2012 and NPC regulations.

10 Children's Privacy

The phwine platform is strictly intended for individuals who are at least 21 years of age. phwine does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the phwine registration and KYC process to enforce this requirement.

If phwine becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the phwine platform, please contact our Data Protection Officer immediately using the details in Section 13.

11 International Data Transfers

phwine 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, where phwine uses cloud infrastructure or technology partners with operations in other countries.

Where personal data is transferred outside the Philippines, phwine ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012. These safeguards may include:

• Contractual clauses that require the recipient to protect personal data to the same standard as required under Philippine law;
• Transfers to countries that have been assessed as providing an adequate level of data protection;
• Other legally recognized transfer mechanisms as approved by the National Privacy Commission.

You may request further information about the safeguards applicable to international transfers of your personal data by contacting our Data Protection Officer.

12 Updates to This Privacy Policy

phwine reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made to this Policy, phwine will notify registered players via the email address associated with their account and by posting a prominent notice on the phwine platform.

The date of the most recent revision to this Privacy Policy is indicated at the top of this page. We encourage you to review this Policy periodically to stay informed about how phwine protects your personal data. Your continued use of the phwine platform following the posting of any changes constitutes your acknowledgment of the updated Policy.

13 Contact Us & Data Protection Officer

phwine has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO:

Please note that all email addresses on this page are displayed as plain text for reference only and are not clickable links. When submitting a data subject request, please include your registered phwine username, a clear description of your request, and a copy of a valid Philippine government-issued ID for identity verification purposes.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with phwine's response to your data privacy concern. Information about the NPC's complaint process is available on the NPC's official website.