winpg Privacy Policy

1. Who We Are

This Privacy Policy is issued by winpg ("winpg," "we," "us," or "our"), the operator of the online gaming platform accessible at winpg.one and its associated mobile interfaces. winpg is the data controller responsible for the personal information you provide when using our platform.

winpg operates within the regulatory framework established by the Philippine Amusement and Gaming Corporation (PAGCOR) and is committed to full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

If you have any questions about this Privacy Policy or how winpg handles your personal data, please contact our Data Protection Officer at [email protected].

2. Personal Data We Collect

winpg collects the following categories of personal data from players and platform users:

winpg does not collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

3. How We Collect Your Data

winpg collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access the winpg platform.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment data from GCash, Maya, and banking partners as part of transaction processing.
• Regulatory sources: Information received from PAGCOR or other competent Philippine authorities in connection with regulatory compliance obligations.

4. How We Use Your Personal Data

winpg uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your winpg account; verifying your identity and age (21+ requirement); processing your login and authentication.
• Service delivery: Enabling you to access and play games on the winpg platform; processing deposits and withdrawals via GCash, Maya, and bank transfer; crediting bonuses and promotional rewards.
• Legal and regulatory compliance: Fulfilling our obligations under the Data Privacy Act, PAGCOR regulations, Anti-Money Laundering Act (AMLA), and other applicable Philippine laws; responding to lawful requests from regulatory authorities.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, unauthorized account access, money laundering, and other prohibited activities.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior; enforcing deposit limits, loss limits, and self-exclusion requests; complying with responsible gaming obligations.
• Customer support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Marketing and promotions: Sending you information about winpg promotions, bonuses, and new features, where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time.
• Platform improvement: Analyzing usage patterns to improve the winpg platform's performance, features, and user experience.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you (i.e., providing the winpg gaming service, processing transactions, managing your account).
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, AMLA obligations, and NPC requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our legitimate interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

winpg does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, Maya, and banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing your deposits and withdrawals.
• KYC and compliance providers: Identity verification and AML screening service providers engaged to assist winpg in meeting its regulatory obligations.
• Game content providers: Third-party game studios and live dealer operators whose games are available on the winpg platform, to the extent necessary for game operation and dispute resolution.
• IT and infrastructure providers: Cloud hosting, cybersecurity, and platform maintenance providers who process data on winpg's behalf under strict data processing agreements.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where disclosure is required by law or regulatory directive.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other lawful process.

All third-party service providers engaged by winpg are contractually required to process your personal data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable Philippine data protection laws.

7. Cookies & Tracking Technologies

winpg uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies we use include:

• Strictly necessary cookies: Essential for the platform to function, including session management, authentication, and security. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, display settings) to provide a more personalized experience.
• Analytics cookies: Collect aggregated, anonymized data about how users interact with the winpg platform to help us improve performance and usability.
• Security cookies: Used for fraud detection, bot prevention, and platform security monitoring.

You can manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the winpg platform. winpg does not use third-party advertising or behavioral tracking cookies.

8. Data Retention

winpg retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention guidelines:

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AMLA obligations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications, after which it is deleted within 30 days.

Upon expiry of the applicable retention period, winpg will securely delete or anonymize your personal data in accordance with our data disposal procedures.

9. Data Security

winpg implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the winpg platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Multi-factor authentication options for player accounts.
• Regular security audits, penetration testing, and vulnerability assessments.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• 24/7 security monitoring and intrusion detection systems.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, winpg will notify the National Privacy Commission and affected individuals in accordance with the timelines prescribed by the Data Privacy Act and NPC regulations.

10. Your Privacy Rights

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

• Right to be informed: The right to know what personal data winpg collects about you and how it is used – which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data winpg 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, subject to winpg's legal retention obligations (e.g., AMLA, PAGCOR record-keeping requirements).
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe winpg has violated your data privacy rights.

To exercise any of these rights, please contact winpg's Data Protection Officer at [email protected]. winpg will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. Identity verification may be required before processing your request.

11. Children's Privacy

The winpg platform is strictly intended for individuals who are 21 years of age or older, in compliance with Philippine law governing online casino gaming. winpg does not knowingly collect personal data from individuals under the age of 21.

Age verification is conducted as part of the KYC process for all registered accounts. If winpg discovers that personal data has been collected from an individual under 21 years of age, the account will be immediately closed, all associated data will be deleted, and any balance will be handled in accordance with applicable regulatory requirements.

If you believe that winpg may have inadvertently collected data from an underage individual, please contact us immediately at [email protected].

12. International Data Transfers

winpg primarily processes and stores personal data within the Philippines. In limited circumstances, personal data may be transferred to or processed by service providers located outside the Philippines (for example, cloud infrastructure providers or game content providers with international operations).

Where such international transfers occur, winpg ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under the Philippine Data Privacy Act.
• Transfers only to countries or organizations that the NPC has determined provide an adequate level of data protection.
• Your explicit consent, where required by applicable law.

13. Updates to This Privacy Policy

winpg reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, winpg will notify registered players via email or a prominent notice on the platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically. Your continued use of the winpg platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or winpg's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Response time: Within 15 business days for formal data subject requests; within 24 hours for general privacy inquiries via live chat.
• NPC complaints: If you are not satisfied with winpg's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.