winph11 Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") describes how winph11 ("winph11", "we", "us", "our") collects, uses, discloses, stores, and protects the personal information of users ("Player", "User", "you") who access or use the winph11 website at winph11.app and all associated services (collectively, the "Platform").

1.2 This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as enforced by the National Privacy Commission ("NPC") of the Philippines.

1.3 By registering an account or using the winph11 Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, please discontinue use of the Platform immediately.

1.4 This Policy should be read together with the winph11 Terms & Conditions, which govern your use of the Platform.

2. Data Controller

2.1 winph11 acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players and visitors to the Platform, as defined under Section 3(h) of the Data Privacy Act of 2012.

2.2 winph11 has appointed a Data Protection Officer (DPO) as required under Section 21 of the DPA. The DPO is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 16 of this Policy.

3. Data We Collect

3.1 winph11 collects the following categories of personal data:

Category	Examples	Purpose
Identity Data	Full name, date of birth, nationality, government-issued ID number	Account registration, KYC verification, age verification (21+)
Contact Data	Mobile number, email address, residential address	Account communications, transaction notifications, support
Financial Data	GCash number, Maya account, bank account details, transaction history	Deposit and withdrawal processing, AML compliance
Technical Data	IP address, device type, browser type, operating system, session logs	Platform security, fraud detection, service optimization
Usage Data	Games played, bet amounts, session duration, login timestamps	Responsible gaming monitoring, personalization, analytics
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Customer support, dispute resolution, service improvement

3.2 Sensitive Personal Information. winph11 may collect sensitive personal information as defined under Section 3(l) of the DPA, including government ID numbers and financial account details, solely for the purpose of KYC verification and regulatory compliance. Such data is subject to heightened security controls.

3.3 winph11 does not collect data that is not necessary for the purposes described in this Policy. You are not required to provide optional data fields, though doing so may enhance your experience on the Platform.

4. How We Collect Data

4.1 winph11 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated technologies: Data collected automatically when you access the Platform, including cookies, web beacons, server logs, and similar tracking technologies (see Section 8);
• Third-party sources: Data received from payment processors (e.g., GCash, Maya, partner banks), identity verification providers, fraud prevention services, and regulatory databases where permitted by law;
• Public sources: Publicly available information used for fraud prevention and AML compliance purposes.

5. Legal Basis for Processing

5.1 winph11 processes your personal data on the following legal bases as provided under the Data Privacy Act of 2012:

• Consent (Section 12(a) DPA): Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications;
• Contractual necessity (Section 12(b) DPA): Where processing is necessary for the performance of the contract between you and winph11, including account management, game provision, and payment processing;
• Legal obligation (Section 12(c) DPA): Where processing is required to comply with applicable laws, including the Anti-Money Laundering Act, PAGCOR regulations, and the Data Privacy Act itself;
• Legitimate interests (Section 12(f) DPA): Where processing is necessary for the legitimate interests of winph11, including fraud prevention, platform security, and service improvement, provided such interests are not overridden by your rights and freedoms.

6. How We Use Your Data

6.1 winph11 uses your personal data for the following purposes:

• To create, verify, and manage your winph11 account;
• To process deposits, withdrawals, and other financial transactions;
• To verify your identity and age (21+) in compliance with PAGCOR and AML requirements;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities;
• To monitor your gaming activity for responsible gaming purposes and to enforce self-exclusion or deposit limit settings;
• To provide customer support and resolve disputes;
• To send you transactional notifications (e.g., deposit confirmations, withdrawal updates, security alerts);
• To send you promotional communications where you have consented to receive them;
• To personalize your experience on the Platform based on your preferences and usage patterns;
• To comply with legal and regulatory obligations, including reporting to PAGCOR, the AMLC, and the NPC where required;
• To improve the Platform through analytics and user research.

6.2 winph11 will not use your personal data for purposes incompatible with those listed above without first obtaining your consent or establishing a new legal basis for processing.

7. Data Sharing and Disclosure

7.1 winph11 may share your personal data with the following categories of recipients:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and debit card networks, for the purpose of processing financial transactions;
• Identity verification providers: Third-party KYC and AML screening services engaged to verify player identities and screen against sanctions lists;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government agencies where disclosure is required by law;
• Law enforcement: Philippine law enforcement agencies where disclosure is required by court order, subpoena, or applicable law;
• IT service providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged under strict data processing agreements;
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

7.2 winph11 does not sell, rent, or trade your personal data to third-party advertisers or data brokers under any circumstances.

7.3 All third-party service providers engaged by winph11 are required to process personal data only on winph11's instructions and in accordance with applicable data protection laws.

8. Cookies and Tracking Technologies

8.1 winph11 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather analytics data. The following types of cookies are used:

• Strictly necessary cookies: Required for the Platform to function correctly, including session management and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, display settings) to personalize your experience.
• Analytics cookies: Collect anonymized data about how players use the Platform to help us improve performance and usability.
• Security cookies: Used for fraud detection and to protect the integrity of your account session.

8.2 You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may impair the functionality of the Platform.

9. Data Retention

9.1 winph11 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account data: Retained for the duration of your account and for five (5) years following account closure, in accordance with PAGCOR record-keeping requirements;
• Financial 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 five (5) years following account closure or the last transaction, whichever is later;
• Support communications: Retained for two (2) years from the date of the last interaction;
• Technical and usage logs: Retained for twelve (12) months for security and analytics purposes.

9.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with winph11's data disposal procedures.

10. Your Rights as a Data Subject

10.1 Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by winph11:

• Right to be informed: The right to be notified of how your personal data is being processed;
• Right of access: The right to obtain a copy of the personal data winph11 holds about you;
• Right to rectification: The right to have inaccurate or incomplete personal data corrected;
• 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 legal retention obligations;
• Right to object : The right to object to the processing of your personal data on grounds relating to your particular situation;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

10.2 To exercise any of the above rights, please submit a written request to the winph11 Data Protection Officer at [email protected]. winph11 will respond to all verified data subject requests within fifteen (15) business days of receipt.

10.3 winph11 may request additional information to verify your identity before processing a data subject request. This is to ensure that personal data is not disclosed to unauthorized parties.

10.4 Where a request is manifestly unfounded or excessive, winph11 reserves the right to charge a reasonable administrative fee or decline to act on the request, with written reasons provided.

11. Data Security

11.1 winph11 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• TLS 1.3 encryption for all data in transit between your device and the Platform;
• AES-256 encryption for sensitive data stored at rest;
• Multi-factor authentication for all administrative access to production systems;
• Regular penetration testing and vulnerability assessments conducted by independent security firms;
• Role-based access controls limiting data access to authorized personnel on a need-to-know basis;
• 24/7 intrusion detection and security monitoring;
• Regular staff training on data protection and information security best practices.

11.2 Notwithstanding the above, no method of electronic transmission or storage is completely secure. winph11 cannot guarantee absolute security of your personal data and encourages you to take steps to protect your own account, including using a strong, unique password and enabling two-factor authentication.

11.3 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, winph11 will notify the National Privacy Commission within 72 hours and will inform affected players without undue delay, in accordance with Section 20(f) of the Data Privacy Act.

12. Children's Privacy

12.1 The winph11 Platform is strictly intended for persons aged twenty-one (21) years and above. winph11 does not knowingly collect personal data from individuals under the age of 21.

12.2 If winph11 becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately closed, all associated data will be deleted, and any funds will be handled in accordance with applicable regulatory requirements.

12.3 If you believe that a minor has registered on the winph11 Platform, please contact our support team immediately at [email protected] so that appropriate action can be taken.

13. Cross-Border Data Transfers

13.1 winph11 primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines, winph11 will ensure that such transfers are made only to countries or organizations that provide an adequate level of data protection, or that appropriate safeguards are in place, in accordance with Section 21 of the Data Privacy Act and NPC guidelines on cross-border data flows.

13.2 Players will be notified of any material changes to cross-border data transfer arrangements that may affect their rights.

14. Third-Party Links

14.1 The winph11 Platform may contain references to third-party services, such as payment processors. winph11 is not responsible for the privacy practices of third-party services and encourages you to review the privacy policies of any third-party service you interact with.

14.2 This Policy applies solely to personal data collected and processed by winph11 through the Platform. It does not apply to data collected by third parties through their own platforms or services.

15. Updates to This Policy

15.1 winph11 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. The revised Policy will be published on the Platform with an updated effective date.

15.2 Where changes are material, winph11 will notify registered players via SMS or in-platform notification at least seven (7) days before the changes take effect. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

15.3 We encourage you to review this Policy periodically to stay informed about how winph11 protects your personal data.

16. Contact & Data Protection Officer

16.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the winph11 Data Protection Officer:

16.2 If you are not satisfied with winph11's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through its official government channels.