Privacy Policy – How wi1win Protects Your Personal Data

1. Introduction & Scope

This Privacy Policy ("Policy") describes how wi1win ("wi1win," "we," "us," or "our"), the operator of the online gaming platform located at wi1win.vip, collects, uses, stores, discloses, and protects the personal information of individuals ("Players," "Users," or "you") who access or use the Platform.

This Policy applies to all personal data processed by wi1win in connection with the Platform, regardless of the device, browser, or access method used. It applies to all registered Players across the Philippines — whether you are based in Metro Manila, Cebu, Davao, Quezon City, or anywhere else in the archipelago.

By registering an Account with wi1win, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree to this Policy, you must not register an Account or use the Platform.

This Policy should be read together with wi1win's Terms & Conditions, which govern the overall relationship between wi1win and Players.

2. Data Controller Information

wi1win is the data controller responsible for the personal data collected through the Platform. As data controller, wi1win determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations ("IRR").

wi1win has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with the DPA and for responding to data subject requests. Players may contact wi1win's DPO through the support channels available on the Platform. Contact email: [email protected]

3. Personal Data We Collect

3.1 Registration Data

When you register an Account on wi1win, we collect the following personal information:

• Full legal name as it appears on your government-issued identification;
• Date of birth (to verify you are 21 years of age or older as required by PAGCOR);
• Philippine mobile number (used as your primary account identifier and for OTP verification);
• Username and hashed password;
• Referral code, if used during registration.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR's Know Your Customer ("KYC") requirements and Philippine Anti-Money Laundering Council ("AMLC") obligations, wi1win collects the following when you complete identity verification:

• Scanned image or photograph of a valid Philippine government-issued identification document (e.g., PhilSys National ID, Passport, Driver's License, SSS ID, GSIS eCard, PhilHealth ID, Postal ID, Voter's ID);
• A selfie or liveness verification photograph taken at the time of KYC submission;
• Proof of address documentation, where required;
• Source of funds documentation, where required for enhanced due diligence.

3.3 Financial Data

wi1win collects financial transaction data necessary to process deposits and withdrawals, including:

• GCash mobile number or Maya account details (used for transaction matching — wi1win does not store full payment credentials);
• Bank account name and account number for bank transfer withdrawals via BPI, BDO, or Metrobank;
• Cryptocurrency wallet addresses for USDT transactions;
• Transaction history including deposit amounts, withdrawal amounts, dates, and reference numbers.

3.4 Gaming Activity Data

wi1win automatically records your gaming activity on the Platform, including game sessions played, wager amounts, game results, bonus usage history, and session timestamps. This data is used for account management, dispute resolution, PAGCOR compliance reporting, and responsible gaming monitoring.

3.5 Technical & Device Data

When you access the Platform, our systems automatically collect certain technical data, including:

• IP address;
• Device type, operating system version, and browser type;
• Session timestamps and pages visited;
• Referring URL (how you arrived at the Platform).

This data is used for security monitoring, fraud prevention, platform performance optimization, and geographic access controls.

4. How We Collect Your Data

wi1win collects personal data through the following means:

• Directly from you — when you complete the registration form, submit KYC documents, contact customer support, participate in promotions, or complete any other action on the Platform that involves submitting personal information;
• Automatically through the Platform — through cookies, session tracking, and standard web server logs when you browse or interact with the Platform;
• From payment processors — transaction confirmation data from GCash, Maya, and banking partners to match deposits and withdrawals to your Account;
• From identity verification partners — where wi1win uses third-party KYC verification services to authenticate government ID documents, those services may return data relevant to verification outcomes.

5. Purposes of Data Processing

wi1win processes your personal data for the following purposes, each of which has a lawful basis under the DPA:

• Account creation and management — to establish and maintain your wi1win Account and provide access to the Platform's features;
• Identity verification and KYC compliance — to verify your identity, confirm your age (21+), and fulfil PAGCOR and AMLC regulatory requirements;
• Transaction processing — to process deposits, withdrawals, and the application of bonuses to your Account;
• Responsible gaming monitoring — to identify patterns of play that may indicate problem gambling behaviour and to enforce self-exclusion requests;
• Fraud prevention and security — to detect and prevent unauthorized access, account fraud, money laundering, and abuse of bonuses or the Platform;
• Customer support — to respond to your inquiries, resolve disputes, and process support requests;
• Legal and regulatory compliance — to fulfil reporting obligations to PAGCOR, AMLC, and other Philippine regulatory authorities as required by law;
• Platform improvement — to analyse usage patterns, diagnose technical issues, and improve the Platform's performance and user experience.

6. Disclosure to Third Parties

6.1 Service Providers

wi1win shares personal data with carefully selected third-party service providers who assist us in operating the Platform. These include game software providers (JILI, Pragmatic Play, PG Soft, Evolution Gaming, and others), payment processing partners (GCash/GXI, Maya/Voyager Innovations, banking partners), KYC identity verification services, and cloud hosting providers. All third-party processors are contractually bound to process data only on wi1win's instructions and to maintain appropriate security measures.

6.2 Regulatory Authorities

wi1win is legally obligated to disclose player information to PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities when required by law, court order, or valid regulatory directive. Such disclosures are mandatory and wi1win cannot refuse them.

6.3 No Sale of Data

wi1win does not sell, rent, lease, or otherwise transfer your personal data to third-party advertisers, data brokers, or marketing companies for their independent use. Any data sharing with third parties is strictly limited to what is necessary to operate the Platform and comply with legal obligations.

7. Data Security

wi1win implements a multi-layered security framework to protect personal data against unauthorized access, disclosure, alteration, and destruction. Key measures include:

• Transport security: All communications between your device and wi1win's servers are encrypted using TLS 1.2 or higher (256-bit SSL);
• Data at rest: Sensitive data stored in wi1win's databases is encrypted at rest using industry-standard encryption algorithms;
• Password security: User passwords are stored only in hashed form using a one-way cryptographic hashing algorithm. wi1win staff cannot retrieve your plain-text password;
• Access controls: Access to personal data within wi1win's systems is restricted on a strict need-to-know basis and subject to role-based access controls and audit logging;
• Fraud monitoring: Automated systems continuously monitor for unusual account activity, suspicious login patterns, and indicators of identity theft.

While wi1win takes all reasonable steps to protect your data, no online system is completely immune to security risks. You are encouraged to use a strong, unique password for your wi1win Account and to enable two-factor authentication through your account security settings.

8. Data Retention

wi1win retains personal data for the following periods:

• Active Accounts: Personal data associated with active Accounts is retained for the duration of your Account's existence on the Platform and for a period of five (5) years following permanent Account closure;
• KYC documents: Identity verification documents are retained for a minimum of five (5) years following Account closure in compliance with PAGCOR's record-keeping requirements and AMLC regulations;
• Transaction records: Financial transaction records are retained for a minimum of five (5) years as required by the Anti-Money Laundering Act of 2001 (RA 9160) as amended;
• Technical logs: Server access logs and session data are retained for a period of up to twelve (12) months for security and fraud investigation purposes, after which they are deleted or anonymized.

Following the applicable retention period, personal data is securely deleted or permanently anonymized in a manner that prevents re-identification.

9. Your Rights Under RA 10173

The Philippine Data Privacy Act of 2012 grants you the following rights in relation to your personal data held by wi1win:

• Right to be informed — you have the right to be informed of the personal data wi1win holds about you and how it is processed;
• Right of access — you have the right to request a copy of the personal data we hold about you, along with information about how it is used;
• Right to rectification — you have the right to request correction of inaccurate or incomplete personal data we hold about you;
• Right to erasure or blocking — you have the right to request deletion or blocking of your personal data where processing is no longer necessary, or where you withdraw consent, subject to wi1win's legal retention obligations;
• Right to data portability — you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to object — you have 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 file a complaint — you have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe wi1win has violated your rights under the DPA.

To exercise any of the above rights, contact wi1win's Data Protection Officer via the support channels on the Platform. wi1win will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with the DPA's IRR.

10. Cookies & Tracking Technologies

wi1win uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies used include:

• Strictly necessary cookies: Required for the Platform to function. These enable your login session to persist, maintain your language preference, and ensure the Platform operates correctly. These cannot be disabled without affecting Platform functionality;
• Performance cookies: Used to collect anonymized data about how Players use the Platform — such as which pages are visited most frequently and how long sessions last — to improve performance and user experience;
• Security cookies: Used to support fraud detection and prevention systems by identifying unusual access patterns across sessions.

wi1win does not use third-party advertising or behavioral tracking cookies. You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair the functionality of the Platform.

11. Changes to This Policy

wi1win reserves the right to update or amend this Privacy Policy at any time. Material changes to this Policy will be notified to registered Players via a prominent notice on the Platform's homepage or via direct notification to the Player's registered mobile number, at least seven (7) days before the changes take effect. The "last updated" date at the top of this Policy will be revised to reflect any amendments.

Continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree to the amended Policy, you must discontinue use of the Platform and may request Account closure.