wi1win Privacy Policy

1 Introduction

wi1win ("we," "us," "our") is committed to protecting the privacy and personal data of all individuals who use the wi1win platform ("Platform"). This Privacy Policy describes how wi1win collects, uses, stores, shares, and protects personal data in connection with the operation of the Platform, which provides online casino gaming, sports betting, bingo, slot games, live dealer games, and related services to players in the Philippines.

This Privacy Policy applies to all personal data processed by wi1win in connection with your use of the Platform, including data collected through the wi1win website, mobile site, and any associated applications. It applies to registered players, prospective players who browse the Platform without registering, and individuals who contact wi1win's customer support team.

wi1win processes personal data in accordance with the 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. Where applicable, wi1win also complies with the Anti-Money Laundering Act (AMLA) and PAGCOR's data handling requirements.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, wi1win is the Personal Information Controller (PIC) in respect of the personal data it collects and processes in connection with the Platform. This means wi1win determines the purposes and means of processing your personal data.

wi1win has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data privacy laws. You may contact the DPO directly for any privacy-related concerns using the contact details provided in Section 16 of this Policy.

3 Personal Data We Collect

wi1win collects the following categories of personal data in connection with the operation of the Platform:

wi1win does not intentionally collect sensitive personal information as defined under the Data Privacy Act (such as health data, religious beliefs, or political affiliations) unless specifically required for responsible gaming assessments or as mandated by applicable law.

4 How We Collect Your Data

wi1win 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 Platform, including through cookies, web beacons, and server logs. See Section 7 for details on our cookie practices.
• Third-party sources: Identity and fraud-check data received from KYC verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), and credit reference or AML screening agencies where required by law.
• Publicly available sources: Information from public records or databases where relevant to fraud prevention or regulatory compliance obligations.

5 How We Use Your Personal Data

wi1win uses your personal data for the following purposes:

• Account management: Creating, maintaining, and administering your wi1win account, including processing your registration and verifying your identity.
• Platform operation: Enabling you to access and use all features of the Platform, including placing bets, participating in games, and claiming bonuses.
• Financial transactions: Processing deposits and withdrawals via your chosen payment method, and maintaining accurate financial records.
• Regulatory compliance: Fulfilling our obligations under PAGCOR regulations, the Anti-Money Laundering Act, and other applicable Philippine laws, including mandatory reporting of suspicious transactions.
• KYC and age verification: Verifying that you meet the minimum age requirement of 21 years and confirming your identity as required by PAGCOR and AML regulations.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviour and administering self-exclusion, deposit limit, and cooling-off requests.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, and other prohibited conduct on the Platform.
• Customer support: Responding to your enquiries, resolving disputes, and providing technical assistance.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: Analysing usage patterns and technical data to improve the performance, features, and user experience of the Platform.
• Legal proceedings: Establishing, exercising, or defending legal claims in connection with the Platform or your account.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, wi1win processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and wi1win — that is, to operate your account and provide the gaming services you have requested.
• Legal obligation: Processing required to comply with wi1win's obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for wi1win's legitimate interests in fraud prevention, platform security, and business analytics, where those interests are not overridden by your data privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Cookies & Tracking Technologies

wi1win uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled without affecting your ability to use the Platform.
• Functional cookies: Remember your preferences such as language settings and display options to personalise your experience.
• Analytics cookies: Collect anonymised data about how players use the Platform to help us understand usage patterns and improve performance.
• Marketing cookies: Used to deliver relevant promotional content based on your interests and gaming activity. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no consent is required as they are essential to the service you have requested.

8 Data Sharing & Disclosure

wi1win 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, to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist wi1win in verifying your identity and age as required by PAGCOR and AML regulations.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or regulatory obligation.
• Fraud prevention and security services: Third-party providers that assist wi1win in detecting and preventing fraudulent activity and ensuring platform security.
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers who process data on wi1win's behalf under strict data processing agreements.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers where necessary for legal compliance, dispute resolution, or business operations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of wi1win's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party processors engaged by wi1win are contractually required to implement appropriate technical and organisational security measures and to process personal data only in accordance with wi1win's instructions and applicable Philippine law.

9 Data Security

wi1win implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform
• Encryption at rest for sensitive personal data stored in wi1win's databases
• Multi-factor authentication for access to internal systems containing personal data
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis
• Regular security audits and penetration testing conducted by qualified third-party security professionals
• Intrusion detection and monitoring systems operating continuously to identify and respond to security threats
• Staff training on data privacy and security obligations conducted on a regular basis

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, wi1win will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay where required by the Data Privacy Act.

10 Data Retention

wi1win retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following retention principles:

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• KYC and identity documents: Retained for a minimum of five (5) years from the date of account closure or the last transaction, whichever is later, in compliance with AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• Customer support communications: Retained for three (3) years from the date of the communication, or longer if related to an ongoing dispute or legal proceeding.
• Marketing consent records: Retained for the duration of your consent plus three (3) years to demonstrate compliance with consent requirements.
• Technical and usage data: Retained for up to twelve (12) months for analytics purposes, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with wi1win's data disposal procedures.

11 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by wi1win:

To exercise any of these rights, please contact wi1win's Data Protection Officer using the contact details in Section 16. wi1win will respond to all data subject rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with notice provided to you.

Please note that certain rights are subject to limitations under the Data Privacy Act. For example, the right to erasure does not apply where wi1win is required to retain data to comply with a legal obligation, such as AML record-keeping requirements.

If you are not satisfied with wi1win's response to a data subject rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

12 Children's Privacy

The wi1win Platform is strictly intended for adults aged 21 years and older, in accordance with the minimum legal age for casino-style gambling in the Philippines as prescribed by PAGCOR regulations. wi1win does not knowingly collect personal data from individuals under the age of 21.

Age verification is conducted as part of the account registration and KYC process. Any account found to belong to an individual under the age of 21 will be immediately suspended, all balances will be frozen pending investigation, and any personal data collected will be deleted in accordance with applicable law.

If you believe that wi1win has inadvertently collected personal data from a minor, please contact our Data Protection Officer immediately using the contact details in Section 16 so that appropriate action can be taken without delay.

13 Cross-Border Data Transfers

wi1win primarily processes personal data within the Philippines. However, certain third-party service providers engaged by wi1win — such as cloud infrastructure providers or international KYC verification services — may process personal data outside the Philippines.

Where personal data is transferred outside the Philippines, wi1win 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 NPC
• Implementing contractual clauses that impose data protection obligations on the recipient equivalent to those under the Data Privacy Act
• Conducting due diligence on all international data processors to verify their security and compliance standards

By using the wi1win Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

14 Third-Party Links

The wi1win Platform may contain links to third-party websites or services, such as payment provider portals. This Privacy Policy applies solely to the wi1win Platform and does not cover the privacy practices of any third-party websites or services.

wi1win is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party services you access through links on the Platform before providing any personal data to those services.

15 Changes to This Privacy Policy

wi1win reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, wi1win will provide reasonable advance notice via email to your registered address or via a prominent notice on the Platform.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgement of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how wi1win protects your personal data. The most current version of this Policy is always available on this page.

16 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by wi1win, please contact our Data Protection Officer:

If you are not satisfied with wi1win's handling of your personal data or your data subject rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

For matters relating to gaming regulation and PAGCOR compliance, you may also contact the Philippine Amusement and Gaming Corporation (PAGCOR) through their official channels.