PHWin21 Privacy Policy – How We Protect Your Data

This Privacy Policy applies to all personal data processed by PHWin21 in connection with the operation of the phwin21.net platform, including its sportsbook, casino, poker room, card games section, and all related services accessible to Filipino and international players.

PHWin21 takes privacy seriously. We only collect the data we genuinely need, we use it only for the purposes stated in this Policy, and we never sell your personal information to third-party advertisers. The sections below explain each aspect of our data practices clearly and specifically.

This Policy should be read alongside our Terms and Conditions and our Responsible Gaming Policy. Together, these three documents form the complete framework that governs your relationship with PHWin21.

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal data is the operator of PHWin21, the online betting and gaming platform accessible at phwin21.net.

PHWin21 has appointed a Data Protection Officer (DPO) who oversees compliance with applicable data privacy laws and handles player privacy enquiries and rights requests. You can reach our DPO directly at privacy@phwin21.net.

When PHWin21 uses third-party service providers to process data on our behalf – such as payment processors, KYC verification services, or game studios – those providers act as data processors under the instruction of PHWin21 and are contractually bound to process your data only as directed by us and in accordance with applicable law.

PHWin21 collects different categories of personal data depending on how you interact with the platform. The table below gives a clear picture of what we collect and why.

PHWin21 does not intentionally collect any sensitive personal information – such as religious beliefs, political affiliations, health data, or biometric data – unless specifically required for regulatory compliance and with your explicit consent.

PHWin21 collects personal data through several channels. Understanding each channel helps you know exactly what data is flowing to us at any given time.

• Direct input: Information you provide when registering an account, completing KYC verification, updating your profile, contacting customer support, or filling in any form on the PHWin21 platform.
• Automated collection: Technical and usage data collected automatically when you access phwin21.net through your browser or mobile device. This includes IP addresses, session data, and click-path behaviour captured via standard web analytics tools.
• Payment processors: When you deposit or withdraw via GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, InstaPay/PESONet, or Visa/Mastercard, those payment providers share transaction confirmation data with PHWin21 to credit or debit your wallet correctly.
• KYC verification partners: Third-party identity verification services may return structured data about your submitted ID documents to PHWin21 as part of the KYC process.
• Cookies and tracking technologies: As described in Section 10, PHWin21 uses cookies and similar technologies to maintain your session, remember your preferences, and collect anonymous analytics. See Section 10 for full details and opt-out instructions.
• Referral programme: If you were referred to PHWin21 by another player through the refer-a-friend programme, PHWin21 receives basic referral attribution data to credit the referring player appropriately.

PHWin21 uses your personal data for the following specific purposes. We do not use your data for any purpose beyond what is listed here without your prior consent.

• Account management: Creating, maintaining, and securing your PHWin21 account. This includes processing login requests, resetting passwords, and managing account settings.
• Payment processing: Crediting deposits to your wallet, processing withdrawal requests, verifying payment method ownership, and maintaining accurate transaction records.
• KYC and regulatory compliance: Verifying your identity and age in accordance with Philippine anti-money laundering (AML) laws and PAGCOR regulatory requirements. PHWin21 is legally required to identify players before processing significant withdrawals.
• Platform delivery: Providing access to sports betting markets, casino games, poker tables, virtual sports, and all other PHWin21 features. Game and bet history is required to settle markets and maintain your wallet balance accurately.
• Fraud prevention and security: Detecting and preventing fraudulent account activity, bonus abuse, multi-accounting, collusion, and money laundering. Technical and transaction data are essential for this purpose.
• Customer support: Responding to your enquiries, resolving disputes, and processing responsible gaming requests such as deposit limits and self-exclusion.
• Responsible gaming monitoring: Analysing usage patterns to identify potential problem gambling behaviour and trigger appropriate interventions in accordance with PHWin21's Responsible Gaming Policy.
• Platform improvement: Using aggregated, anonymised usage data to understand how players interact with PHWin21 and to make the platform faster, more useful, and easier to navigate.
• Marketing communications: Sending promotional emails, SMS, or push notifications about PHWin21 offers, bonuses, and new features – only to players who have opted in to receive such communications. See Section 14 for opt-out instructions.

Under the Philippine Data Privacy Act of 2012, PHWin21 must have a valid legal basis for processing your personal data. The bases we rely on are as follows:

• Contract performance: Processing necessary to create and operate your PHWin21 account, process deposits and withdrawals, settle bets, and deliver the platform services you have signed up for. This is the primary basis for most of our data processing.
• Legal obligation: Processing required to comply with applicable Philippine law, including anti-money laundering (AML) obligations, PAGCOR regulatory reporting, and tax record-keeping requirements. PHWin21 must retain certain records regardless of your preferences in these cases.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregate analytics where PHWin21's interest in protecting the integrity of the platform and the safety of players does not outweigh your privacy interests.
• Consent: Processing for marketing communications and non-essential cookies, where PHWin21 relies on your freely given, specific, and informed consent. You may withdraw this consent at any time.

PHWin21 does not sell your personal data to third-party advertisers or data brokers. We share your data only with the categories of recipients listed below, and only to the extent necessary for the stated purpose.

• Payment processors: GCash (G-Xchange Inc.), Paymaya Philippines Inc., GrabPay, Coins.ph, BDO Unibank, Bank of the Philippine Islands (BPI), UnionBank of the Philippines, InstaPay/PESONet clearing operators, and Visa/Mastercard card networks. These providers receive only the transaction data required to process your deposit or withdrawal.
• KYC and identity verification providers: Certified third-party identity verification services that process your submitted ID documents and return a verification result to PHWin21. These providers are contractually bound to process your data exclusively for identity verification purposes.
• Game technology providers: Casino game studios and live dealer providers whose games are available on PHWin21. These providers may receive a session token and bet data to operate their game software. They do not receive your full personal profile.
• IT infrastructure and cloud service providers: Server hosting and cloud infrastructure providers used to operate the PHWin21 platform. These providers act as processors under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other competent Philippine authorities, where disclosure is required by law or valid legal process.
• Fraud prevention networks: Industry fraud prevention services used to identify flagged IP addresses, devices, or payment methods associated with fraudulent activity. Only technical identifiers are shared with these services.

PHWin21 retains your personal data for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The general retention periods are as follows:

• Account and identity data: Retained for the duration of your active account and for a minimum of five (5) years after account closure, in accordance with Philippine AML record-keeping requirements.
• Financial and transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by AMLC regulations and BIR record-keeping rules.
• KYC documents: Retained for a minimum of five (5) years after account closure or the date of the last transaction, whichever is later.
• Customer support communications: Retained for three (3) years from the date of the interaction, or for the duration of any related dispute, whichever is longer.
• Technical and usage data (logs): Retained for twelve (12) months from collection, unless required for ongoing fraud or security investigations.
• Marketing consent records: Retained for the duration of your account and for two (2) years after you withdraw consent, to demonstrate compliance with consent requirements.

When retention periods expire, PHWin21 securely deletes or anonymises the relevant data so it can no longer be attributed to an identifiable individual.

PHWin21 takes the security of your personal data seriously and has implemented a layered set of technical and organisational measures designed to protect your information against unauthorised access, disclosure, alteration, and destruction.

While PHWin21 applies industry-standard security measures, no online platform can guarantee 100% security. You can help protect your account by using a strong, unique password and not sharing your login credentials with anyone. If you suspect your account has been compromised, contact PHWin21 support immediately.

PHWin21 uses cookies and similar tracking technologies on phwin21.net to keep the platform running properly, remember your preferences, and understand how players use the site. Here's a plain breakdown of the cookies we use.

You can manage your cookie preferences through the cookie settings panel accessible from the footer of any PHWin21 page. You can also control cookies through your browser settings, though blocking necessary cookies will prevent you from logging into your PHWin21 account.

Some of PHWin21's technology providers and game studios are based outside the Philippines. As a result, your personal data may be transferred to and processed in countries other than the Philippines in the course of operating the platform.

Where PHWin21 transfers personal data internationally, we ensure that appropriate safeguards are in place to protect your data to a standard at least equivalent to what is required under the Philippine Data Privacy Act. These safeguards include:

• Data processing agreements with all international processors that incorporate the required data protection obligations.
• Transfers to countries or organisations recognised as providing an adequate level of data protection.
• Binding corporate rules or equivalent contractual clauses where transfers are to jurisdictions without a formal adequacy finding.

If you would like more information about the specific safeguards in place for any international transfer of your data, please contact our DPO at privacy@phwin21.net.

As a PHWin21 player and a data subject under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal data. PHWin21 is committed to responding to all valid rights requests within 30 days of receipt.

PHWin21 is strictly an 18+ platform. We do not knowingly collect or process personal data from individuals under 18 years of age. Age verification is a mandatory step in the PHWin21 registration and KYC process.

If PHWin21 discovers or has reason to believe that personal data has been collected from a minor, we will take immediate steps to verify the situation, suspend the account concerned, delete the minor's data, and refuse any associated financial transactions. If you believe a minor has created a PHWin21 account using false information, please contact us immediately at support@phwin21.net.

PHWin21 will only send you marketing emails, SMS messages, or push notifications if you have explicitly opted in to receive them during registration or through your account settings. We will not send unsolicited marketing to players who have not consented.

You can opt out of marketing communications at any time through any of the following methods:

• Clicking the "Unsubscribe" link in any PHWin21 marketing email.
• Updating your notification preferences in your PHWin21 account settings.
• Contacting PHWin21 customer support via live chat and requesting to be removed from marketing lists.
• Emailing privacy@phwin21.net with the subject line "Marketing Opt-Out".

Opting out of marketing communications does not affect transactional communications – PHWin21 will still send you essential account notifications such as deposit confirmations, withdrawal approvals, and security alerts, as these are required to operate your account properly.

PHWin21 may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or the platform itself. Where changes are significant, PHWin21 will notify registered players via email and/or a prominent notice on phwin21.net at least 7 days before the revised Policy takes effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of PHWin21 after the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to a revised Policy, please close your account before the changes take effect and contact privacy@phwin21.net with any questions.

The current version of this Privacy Policy is always accessible at phwin21.net/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way PHWin21 handles your personal data, please get in touch. We are committed to responding to all privacy-related enquiries promptly and transparently.

• Data Protection Officer: privacy@phwin21.net – for all rights requests, data enquiries, and privacy complaints. Our DPO aims to respond to all emails within 3 business days.
• General support: support@phwin21.net – for account-related questions that touch on data privacy.
• Live chat: Available 24/7 on any PHWin21 page for immediate assistance.
• FAQ: Our FAQ page covers common questions about accounts, data, and payments.

If you are not satisfied with PHWin21's response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the regulatory body responsible for enforcing the Data Privacy Act of 2012.