pphwin Privacy Policy

1 Introduction

pphwin is an online gaming platform serving Filipino players across the Philippines. We understand that your personal information is important to you, and we take our obligations as a personal information controller seriously under Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations.

This Policy applies to all personal data collected in connection with your use of pphwin, whether you are visiting the site as a guest, registering as a player, conducting financial transactions, or interacting with our customer support team. It covers data collected online through the pphwin website as well as any data provided directly by you through other means of communication with pphwin.

We encourage you to read this Policy in full. If you have questions about any section, please contact our Data Protection Officer using the details provided in Section 16 of this Policy.

2 Data Controller Information

For the purposes of the Data Privacy Act of 2012 and this Policy, the data controller responsible for your personal information is pphwin, operating the online gaming platform accessible at pphwin.cam.

As the personal information controller, pphwin determines the purposes and means of processing your personal data. We have designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with data privacy regulations and for handling data subject requests. The DPO can be reached via the contact details provided in Section 16 of this Policy.

3 Personal Data We Collect

pphwin collects the following categories of personal data, depending on the nature of your interaction with the Platform:

4 How We Collect Your Data

pphwin collects personal data through the following means:

• Direct submission: Information you provide when registering a pphwin account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access pphwin.cam, including IP addresses, device identifiers, browser information, and session activity via cookies and server logs;
• Payment processors: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard when you conduct financial transactions on pphwin;
• Third-party verification services: Identity and fraud verification data obtained from authorized KYC service providers in connection with your account verification.

5 Purposes of Processing

pphwin processes your personal data for the following purposes:

1. Account creation and management: To register, maintain, and administer your pphwin player account;
2. Identity and age verification: To confirm that you are at least 21 years of age and that you are who you claim to be, in compliance with PAGCOR requirements;
3. Payment processing: To facilitate deposits, process withdrawal requests, and maintain accurate transaction records;
4. Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal conduct;
5. Regulatory compliance: To fulfill our obligations under the Data Privacy Act, PAGCOR licensing conditions, and applicable anti-money laundering regulations;
6. Responsible gaming: To monitor gaming patterns, enforce deposit and session limits, and administer self-exclusion requests;
7. Customer support: To respond to your inquiries, resolve disputes, and provide assistance via live chat and email;
8. Service improvement: To analyze platform usage and improve game offerings, user interface, and overall player experience;
9. Marketing communications: To send promotional offers, bonus notifications, and updates about pphwin — only where you have provided consent and subject to opt-out at any time.

6 Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our obligations under the pphwin Terms & Conditions, including account management and payment processing;
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, anti-money laundering laws, and tax reporting requirements;
• Legitimate interests: Processing for fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your data privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided freely given, specific, informed, and unambiguous consent.

7 Data Sharing & Disclosure

pphwin does not sell, rent, or trade your personal information. We may share your data with the following categories of recipients only to the extent strictly necessary:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing your financial transactions;
• KYC and identity verification providers: Authorized third-party services engaged to verify your identity and age in connection with pphwin account registration;
• Game providers: Software providers whose games are accessible through the pphwin platform, to the extent necessary to deliver gaming services and resolve technical issues;
• Regulatory and law enforcement authorities: Philippine government bodies, courts, PAGCOR, the National Privacy Commission, and law enforcement agencies where required by law or court order;
• Professional advisors: Legal counsel, auditors, and compliance consultants engaged by pphwin, subject to strict confidentiality obligations.

All third parties with whom pphwin shares personal data are required to maintain appropriate data protection standards and to process your data solely for the purposes specified by pphwin.

8 International Data Transfers

Some of pphwin's service providers and game software partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, pphwin takes steps to ensure that such transfers comply with the Data Privacy Act of 2012, including by requiring receiving parties to maintain data protection standards equivalent to those required under Philippine law.

Before any cross-border data transfer is made, pphwin conducts a data transfer impact assessment to evaluate the adequacy of data protection in the recipient jurisdiction and to implement appropriate safeguards, including contractual protections where necessary.

9 Data Retention

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

• Account data: Retained for the duration of the active account relationship, and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements;
• KYC documents: Retained for a minimum of five (5) years from the date of submission, subject to regulatory requirements;
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Gaming records: Retained for a minimum of two (2) years from the date of each gaming session;
• Support communications: Retained for two (2) years from the date of the last communication, unless relevant to an ongoing dispute.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with pphwin's data disposal procedures.

10 Your Data Privacy Rights

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

• Right to be informed: The right to know whether pphwin is processing your personal data, and to receive information about how it is being used;
• Right of access: The right to request a copy of the personal data pphwin holds about you;
• Right to correction: The right to request that inaccurate or incomplete personal data be corrected or updated;
• Right to erasure: The right to request deletion of your personal data where processing is no longer necessary or where it was processed unlawfully, subject to legal retention obligations;
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format;
• Right to object: The right to object to processing based on legitimate interests, including for direct marketing purposes;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact pphwin's Data Protection Officer using the details in Section 16. pphwin will respond to verified data subject requests within fifteen (15) business days, as required under the DPA's Implementing Rules and Regulations.

11 Cookies & Tracking Technologies

pphwin uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and maintain session security. The following categories of cookies are deployed:

• Essential cookies: Required for core platform functionality, including login session management, account security, and cashier access. These cannot be disabled without affecting platform operation;
• Analytical cookies: Used to collect anonymized data on how players navigate pphwin, which helps us identify and fix technical issues and improve the user experience;
• Preference cookies: Used to remember your language preference, game lobby settings, and other personalization choices.

pphwin does not deploy third-party advertising or cross-site tracking cookies without your prior consent. You may manage cookie preferences through your browser settings. Please note that disabling essential cookies will impair your ability to use certain features of the pphwin platform.

12 Children's Privacy & Age Restriction

pphwin is strictly intended for individuals who are at least 21 years of age, in accordance with PAGCOR regulations governing online gaming in the Philippines. pphwin does not knowingly collect personal data from individuals under the age of 21.

If pphwin discovers that personal data has been collected from an individual under 21 years of age, the relevant account will be immediately closed, all associated data will be deleted (subject to any mandatory retention requirements under applicable law), and the matter may be referred to relevant Philippine authorities.

If you are a parent or guardian and believe that a person under 21 has created a pphwin account, please contact us immediately at [email protected] so we can take appropriate action.

13 Security Measures

pphwin implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit Transport Layer Security (TLS) encryption for all data transmitted between your device and pphwin servers;
• Encryption of sensitive data at rest using industry-standard algorithms;
• Role-based access controls limiting data access to authorized pphwin personnel on a need-to-know basis;
• Two-factor authentication for pphwin account login;
• Regular security audits and penetration testing of pphwin systems;
• Automated anomaly detection to identify unusual account activity and potential unauthorized access;
• Incident response procedures to address and notify affected parties in the event of a personal data breach, in accordance with NPC notification requirements.

While pphwin maintains robust security measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your pphwin login credentials and for notifying us immediately of any suspected unauthorized access to your account.

14 Third-Party Links

The pphwin platform may contain references to third-party services, including payment processors and game software providers. This Privacy Policy applies solely to personal data collected and processed by pphwin. pphwin is not responsible for the privacy practices of third-party services, and we encourage you to review the privacy policies of any third parties with whom you interact in connection with your use of pphwin.

15 Updates to This Policy

pphwin may update this Privacy Policy from time to time to reflect changes in applicable law, our data processing practices, or the nature of our services. Where material changes are made, pphwin will provide reasonable advance notice to registered players via the email address or mobile number on file, or by posting a prominent notice on the Platform.

The effective date at the top of this Policy will be updated each time a revised version is published. Your continued use of pphwin following the effective date of any update constitutes acceptance of the revised Policy. If you do not agree to the updated Policy, you must stop using pphwin and request account closure.

16 Contact & Complaints

For questions about this Privacy Policy, to exercise your data privacy rights, or to raise a concern about pphwin's data handling practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject line: Data Privacy Request — [Your pphwin Username]
• Live Chat: Available 24/7 within your pphwin account dashboard
• Languages: English and Filipino (Tagalog)

pphwin will acknowledge receipt of a data subject request within three (3) business days and will provide a substantive response within fifteen (15) business days, subject to identity verification requirements.

If you are not satisfied with pphwin's response to a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent body responsible for administering and enforcing the Data Privacy Act of 2012.