WinPHApp Privacy Policy

1 Introduction

WinPHApp ("WinPHApp," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the WinPHApp online gaming platform, accessible at winphapp.app and through any associated mobile application (collectively, the "Platform"). This Privacy Policy describes how WinPHApp collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform.

This Privacy Policy applies to all registered players, visitors, and any other individuals who interact with the WinPHApp Platform. It should be read together with our Terms & Conditions, which govern your use of the Platform.

WinPHApp operates in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC"). As a data controller, WinPHApp is responsible for ensuring that your personal data is handled lawfully, fairly, and transparently.

2 Personal Data We Collect

WinPHApp collects only the personal data that is necessary to provide, operate, and improve the Platform. The categories of personal data we collect include:

3 How We Collect Your Data

WinPHApp collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting our support team, or participating in promotions on WinPHApp.
• Automated technologies: Technical and usage data collected automatically when you access the WinPHApp Platform, including through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Identity and financial verification data received from payment processors (such as GCash and PayMaya), identity verification service providers, and fraud prevention agencies, where you have consented to such sharing or where we are legally required to verify your identity.
• Publicly available sources: Information from public databases or government registries where necessary for compliance with anti-money laundering or know-your-customer obligations.

WinPHApp will always inform you at the point of collection what data is being collected and for what purpose, unless an exception applies under the DPA.

4 How We Use Your Personal Data

WinPHApp uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your WinPHApp account, including verifying your identity and age (21+ requirement) and processing your registration.
• Service delivery: To provide access to games, process deposits and withdrawals in Philippine Peso (₱), and deliver the full range of WinPHApp platform features.
• Legal and regulatory compliance: To comply with anti-money laundering (AML) obligations, know-your-customer (KYC) requirements, and any other applicable Philippine laws and regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, cheating, money laundering, and other illegal or prohibited activities on the WinPHApp Platform.
• Responsible gaming: To monitor gaming behaviour, identify signs of problem gambling, and apply responsible gaming tools such as deposit limits and self-exclusion where appropriate.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Platform improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of WinPHApp.
• Marketing communications: To send you promotional offers, bonuses, and updates about WinPHApp, where you have provided your consent to receive such communications. You may withdraw consent at any time.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, WinPHApp processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — including account registration, game access, and payment processing — is necessary for the delivery of WinPHApp services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, KYC requirements, and gaming regulations.
• Legitimate interests: Processing carried out for WinPHApp's legitimate business interests, such as 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, informed, and unambiguous consent — for example, for marketing communications or the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Sharing Your Personal Data

WinPHApp does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your financial transactions on WinPHApp.
• Identity verification providers: Third-party KYC and age verification service providers engaged to verify your identity and confirm that you meet the 21+ age requirement.
• Fraud prevention agencies: Organisations that assist WinPHApp in detecting and preventing fraudulent activity, money laundering, and other illegal conduct.
• Technology service providers: Cloud hosting, data storage, analytics, and customer support platform providers who process data on WinPHApp's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Government agencies, regulators, and law enforcement bodies in the Philippines where WinPHApp is legally required or permitted to disclose your data.
• Professional advisers: Lawyers, auditors, and other professional advisers where necessary for WinPHApp's legal, compliance, or business operations.

All third parties with whom WinPHApp shares personal data are required to handle such data in accordance with applicable privacy laws and WinPHApp's data protection standards. WinPHApp remains responsible for ensuring that any third-party processing of your data is lawful and secure.

7 Data Retention

WinPHApp retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following general retention periods apply:

• Account data: Retained for the duration of your active WinPHApp account and for a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• KYC and identity verification documents: Retained for the period required by applicable AML and gaming regulations, typically five (5) years from the end of the business relationship.
• Customer support communications: Retained for up to three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing consent records: Retained until you withdraw your consent or for three (3) years from the date of consent, whichever is earlier.

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

8 Cookies & Tracking Technologies

WinPHApp uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and support security functions. The types of cookies we use include:

• Strictly necessary cookies: Essential for the operation of the WinPHApp Platform, including maintaining your login session and enabling secure transactions. These cannot be disabled.
• Performance and analytics cookies: Used to collect anonymised information about how visitors use WinPHApp, helping us identify areas for improvement. These are only set with your consent.
• Functionality cookies: Used to remember your preferences and settings on WinPHApp, such as language and display preferences.
• Security cookies: Used to detect and prevent fraudulent activity, protect your account, and maintain the integrity of the WinPHApp Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the WinPHApp Platform. For more information on managing cookies, refer to your browser's help documentation.

9 Data Security

WinPHApp takes the security of your personal data seriously and implements a range of technical and organisational measures to protect it against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the WinPHApp Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Multi-factor authentication options for WinPHApp account access.
• Regular security assessments, penetration testing, and vulnerability scanning of the WinPHApp Platform.
• Strict access controls ensuring that only authorised WinPHApp personnel can access personal data, on a need-to-know basis.
• Real-time fraud detection and monitoring systems to identify and respond to suspicious activity.
• Staff training on data protection and information security best practices.

While WinPHApp employs industry-standard security measures, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, WinPHApp will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

10 Your Data Rights

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

• Right to be informed: The right to be told how your personal data is being collected and used, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data WinPHApp holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data WinPHApp holds 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 WinPHApp'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 WinPHApp's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe WinPHApp has violated your data privacy rights.

To exercise any of these rights, please contact WinPHApp's Data Protection Officer using the contact details provided in Section 15 of this Privacy Policy. WinPHApp will respond to all verified requests within thirty (30) days, as required by the DPA.

11 Children's Privacy

The WinPHApp Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. WinPHApp does not knowingly collect personal data from individuals under the age of 21.

If WinPHApp discovers or is notified that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete such data and close the associated account. Any winnings accrued on an underage account will be forfeited in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that your child has registered on WinPHApp, please contact our support team immediately so that we can take appropriate action.

12 International Data Transfers

WinPHApp primarily stores and processes your personal data within the Philippines. However, some of our technology service providers and data processors may be located in other countries. Where personal data is transferred outside the Philippines, WinPHApp 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.
• Implementing contractual clauses that require overseas recipients to handle your data in accordance with the Data Privacy Act of 2012 and this Privacy Policy.
• Conducting due diligence on all overseas data processors to ensure compliance with applicable data protection standards.

By using the WinPHApp Platform, you acknowledge and consent to the transfer of your personal data to overseas service providers where necessary for the delivery of WinPHApp services, subject to the safeguards described above.

13 Third-Party Services

The WinPHApp Platform may contain links to or integrations with third-party services, including payment gateways such as GCash and PayMaya. This Privacy Policy applies only to the WinPHApp Platform and does not cover the privacy practices of any third-party services.

When you interact with a third-party service through WinPHApp — for example, when making a deposit via GCash — you will be subject to that third party's own privacy policy and terms of service. WinPHApp is not responsible for the privacy practices or content of any third-party services.

WinPHApp recommends that you review the privacy policies of any third-party services you use in connection with your WinPHApp account before providing them with your personal data.

14 Updates to This Privacy Policy

WinPHApp reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the features of the WinPHApp Platform. When material changes are made, WinPHApp will notify registered players by posting a prominent notice on the Platform or by sending a notification to the email address associated with your account.

The updated Privacy Policy will take effect on the date specified in the notice. Your continued use of the WinPHApp Platform after the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. If you do not agree to the revised Privacy Policy, you must cease using WinPHApp and may request account closure.

The date of the most recent update to this Privacy Policy is displayed at the top of this page. WinPHApp recommends that you review this Privacy Policy periodically to stay informed of any changes.

15 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way WinPHApp handles your personal data, please contact our Data Protection Officer. WinPHApp is committed to resolving all privacy-related enquiries promptly and fairly.

If you are not satisfied with WinPHApp's response to your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the independent authority responsible for enforcing the Data Privacy Act of 2012. Information on how to file a complaint with the NPC is available through official Philippine government channels.