winph35 Privacy Policy

Last Updated: January 2026  |  Effective Date: January 1, 2026  |  Version: 2.4

This Privacy Policy ("Policy") describes how winph35 ("winph35," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("Player," "User," or "you") who access or use the winph35 online gaming platform available at winph35.org and any associated mobile interfaces (collectively, the "Platform"). This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. By registering for or using the winph35 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

1. Introduction and Scope

1.1 winph35 is committed to protecting the privacy and personal data of all players who use our Platform. This Policy applies to all personal data collected through the winph35 website, mobile interface, customer support channels, and any other touchpoints through which you interact with winph35.

1.2 This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference.

1.3 winph35 acts as the data controller in respect of the personal data you provide to us. As data controller, winph35 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws.

2. Personal Data We Collect

2.1 winph35 collects the following categories of personal data from players:

Category	Examples	Purpose
Identity Data	Full name, date of birth, government-issued ID number	Account registration, KYC verification, age verification
Contact Data	Email address, mobile number, home address	Account communication, support, notifications
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank)	Processing deposits and withdrawals
Technical Data	IP address, device type, browser type, operating system	Platform security, fraud prevention, analytics
Usage Data	Games played, bet history, session duration, login timestamps	Service improvement, responsible gaming monitoring
Communications Data	Live chat transcripts, support emails, feedback submissions	Customer support, dispute resolution, quality assurance

2.2 winph35 does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive data is required, we will seek your explicit consent prior to collection.

3. How We Collect Your Data

3.1 winph35 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Data collected automatically when you use the Platform, including cookies, web beacons, log files, and similar tracking technologies;
• Third-party sources: Data received from payment processors (such as GCash and PayMaya), identity verification providers, fraud prevention services, and analytics partners, where permitted by law;
• Publicly available sources: Information from public databases or registries where relevant to fraud prevention or regulatory compliance.

4. How We Use Your Personal Data

4.1 winph35 uses your personal data for the following purposes:

• To create, manage, and maintain your winph35 account;
• To verify your identity and age in compliance with Philippine gaming regulations (players must be 21 years or older);
• To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank;
• To provide customer support and respond to your inquiries;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities;
• To monitor gaming activity for responsible gaming purposes and to enforce self-exclusion requests;
• To send you transactional communications, account notifications, and promotional offers (where you have opted in);
• To improve the winph35 Platform, personalize your experience, and conduct internal analytics;
• To comply with our legal and regulatory obligations under Philippine law.

5. Legal Basis for Processing

5.1 winph35 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including account management and payment processing;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering requirements and gaming regulations;
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights;
• Consent: Processing based on your explicit consent, such as for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

6.1 winph35 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 only to the extent necessary:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing your financial transactions;
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and eligibility;
• Fraud prevention and security services: Providers that help winph35 detect and prevent fraudulent activity on the Platform;
• IT and infrastructure providers: Cloud hosting, data storage, and technical support providers who process data on our behalf under strict data processing agreements;
• Regulatory and law enforcement authorities: Where required by applicable Philippine law, court order, or regulatory directive;
• Professional advisors: Legal, accounting, and compliance advisors bound by professional confidentiality obligations.

6.2 All third parties with whom winph35 shares personal data are required to process such data in accordance with applicable data protection laws and our instructions. winph35 does not permit third-party service providers to use your personal data for their own purposes.

7. Cookies and Tracking Technologies

7.1 winph35 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Performance and analytics cookies: Used to collect anonymized data about how players use the Platform, helping us identify areas for improvement.
• Functional cookies: Used to remember your preferences and settings, such as language and display options, to provide a more personalized experience.
• Targeting and session cookies: Used to track your session activity for responsible gaming monitoring and to ensure Platform integrity.

7.2 You may control cookie settings through your browser preferences. Please note that disabling certain cookies may affect the functionality of the winph35 Platform. By continuing to use the Platform, you consent to our use of cookies as described in this Policy.

8. Data Retention

8.1 winph35 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements.

8.2 As a general guideline, winph35 retains account and transaction data for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering regulations and gaming record-keeping requirements. Communications data is retained for a period of two (2) years from the date of the interaction.

8.3 Where personal data is no longer required, winph35 will securely delete or anonymize it in accordance with our internal data retention and disposal procedures.

9. Data Security

9.1 winph35 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the winph35 Platform;
• Secure, access-controlled server environments with regular security audits;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular staff training on data protection and information security practices;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

9.2 While winph35 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your winph35 login credentials and for notifying us immediately if you suspect unauthorized access to your account.

10. Your Data Rights

10.1 Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by winph35:

• Right to be informed: The right to know whether winph35 holds personal data about you and how it is being processed;
• Right of access: The right to request a copy of the personal data winph35 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• 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 our 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 legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

10.2 To exercise any of the above rights, please contact the winph35 Data Protection Officer using the contact details provided in Section 15 of this Policy. winph35 will respond to all valid data rights requests within thirty (30) days of receipt, in accordance with applicable law.

11. Children's Privacy

11.1 The winph35 Platform is strictly intended for individuals who are at least twenty-one (21) years of age. winph35 does not knowingly collect personal data from individuals under the age of 21. If winph35 becomes aware that personal data has been collected from a minor, we will take immediate steps to delete such data and close the associated account.

11.2 If you are a parent or guardian and believe that a minor has registered on the winph35 Platform, please contact our support team immediately via live chat or at the email address provided in Section 15.

12. International Data Transfers

12.1 winph35 primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines, for example where our technology or service providers are located abroad.

12.2 Where such international transfers occur, winph35 ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to process personal data to a standard equivalent to that required under Philippine law.

13. Third-Party Links

13.1 The winph35 Platform may contain links to third-party websites or services. This Privacy Policy applies solely to the winph35 Platform and does not cover the privacy practices of any third-party websites. winph35 is not responsible for the content or privacy practices of any linked third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

14. Updates to This Privacy Policy

14.1 winph35 reserves the right to update or amend this Privacy Policy at any time. When we make material changes, we will post the updated Policy on the Platform with a revised effective date. Where required by law, we will notify you of significant changes by email or through a prominent notice on the Platform.

14.2 Your continued use of the winph35 Platform following the posting of any changes to this Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how winph35 protects your personal data.

15. Contact and Data Protection Officer

15.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by winph35, please contact our Data Protection Officer (DPO):

• Email: [email protected]
• Live Chat: Available 24/7 on the winph35 Platform
• Response Time: Within 30 days of receipt of your request

15.2 If you are not satisfied with winph35's response to your data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.