winph77 Privacy Policy

1. Overview

This Privacy Policy ("Policy") describes how winph77 ("winph77," "we," "us," or "our") collects, processes, stores, and protects the personal information of individuals ("you," "your," or "Player") who access or use the winph77 online gaming platform available at winph77.app ("Platform").

winph77 is committed to protecting the privacy and security of all personal data entrusted to us by our players and platform visitors. We operate in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

By registering an account on winph77, accessing the Platform, or otherwise providing us with your personal information, 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 with any part of this Policy, you should not use the winph77 Platform.

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

2. Personal Data We Collect

winph77 collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected and processed. The categories of personal data we collect include:

2.1 Identity & Contact Information

• Full legal name as it appears on your government-issued identification;
• Date of birth (used for age verification — players must be 21 years of age or older);
• Philippine mobile number and email address;
• Residential address (province, city/municipality, barangay);
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license, SSS/GSIS number).

2.2 Financial Information

• GCash or PayMaya/Maya account number linked to your winph77 account;
• Bank account details for bank transfer transactions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank);
• Debit card details where applicable;
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references.

2.3 Gaming Activity Data

• Game history, including games played, bet amounts, outcomes, and session durations;
• Bonus and promotion usage history;
• Responsible gaming tool settings (deposit limits, session reminders, self-exclusion status);
• Account balance and wagering records.

2.4 Technical & Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser information;
• Session timestamps and login history;
• Cookie identifiers and similar tracking data (see Section 9).

2.5 Communications Data

• Records of your communications with winph77 customer support, including live chat transcripts and support ticket history;
• Feedback, survey responses, and promotional opt-in preferences.

3. How We Collect Your Data

winph77 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 data collected automatically when you access the Platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; payment transaction data from GCash, PayMaya, and banking partners; fraud prevention data from anti-money laundering screening services;
• Regulatory sources: Self-exclusion status information from PAGCOR or other recognized responsible gaming registries.

4. How We Use Your Personal Data

winph77 uses your personal data for the following purposes:

5. Legal Basis for Processing

winph77 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Consent: 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: Where processing is necessary for the performance of the contract between you and winph77 — including account registration, payment processing, and game provision;
• Legal obligation: Where processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AML obligations, and NPC requirements;
• Legitimate interests: Where processing is necessary for winph77's legitimate interests, such as fraud prevention, platform security, and responsible gaming monitoring, provided such interests are not overridden by your rights and freedoms.

6. Sharing Your Personal Data

winph77 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 and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya/Maya, and Philippine banking partners, for the purpose of processing your deposits and withdrawals;
• KYC and identity verification providers: Third-party services engaged to verify your identity and age in compliance with regulatory requirements;
• Fraud prevention and AML screening services: Service providers that assist winph77 in detecting and preventing fraudulent activity and money laundering;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulatory obligation;
• Game providers: Licensed game software providers whose games are available on the winph77 Platform, to the extent necessary for game operation and dispute resolution;
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers engaged by winph77 to operate and secure the Platform.

All third parties with whom winph77 shares personal data are required to process such data in accordance with applicable Philippine data privacy laws and are bound by contractual data protection obligations.

7. Data Retention

winph77 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. Specific retention periods include:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AML regulations;
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship;
• Support communications: Retained for a minimum of two (2) years from the date of the communication;
• Marketing preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.

Upon expiry of the applicable retention period, winph77 will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

8. Data Security

winph77 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the winph77 Platform;
• Encryption of sensitive data at rest, including financial information and government ID numbers;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing of the Platform;
• Multi-factor authentication for administrative access to systems containing personal data;
• 24/7 monitoring of Platform systems for suspicious activity and potential security incidents.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, winph77 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the requirements of the Data Privacy Act of 2012.

While winph77 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 account credentials and for notifying winph77 immediately if you suspect any unauthorized access to your account.

9. Cookies & Tracking Technologies

winph77 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled;
• Functional cookies: Remember your preferences and settings, such as language and display options, to improve your experience on the Platform;
• Analytics cookies: Collect anonymized data about how players use the Platform, helping us identify areas for improvement. No personally identifiable information is collected through analytics cookies;
• Marketing cookies: Used to deliver relevant promotional content to you, where you have consented to receive marketing communications from winph77.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the winph77 Platform. Strictly necessary cookies cannot be disabled as they are essential for Platform operation.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by winph77:

To exercise any of these rights, please contact winph77 customer support via live chat or email. winph77 will respond to your request within thirty (30) days. We may need to verify your identity before processing your request. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

11. Minors & Age Restriction

winph77 employs age verification procedures during account registration and KYC review to prevent underage access to the Platform. If you believe that a minor has registered an account on winph77, please contact our customer support team immediately so that we can investigate and take appropriate action.

12. Cross-Border Data Transfers

winph77 primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or game software vendors operating internationally.

Where such cross-border transfers occur, winph77 ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses that require the recipient to maintain standards equivalent to those required under the Philippine Data Privacy Act of 2012. winph77 will not transfer your personal data to a foreign country or international organization unless adequate data protection standards are in place.

13. Changes to This Privacy Policy

winph77 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. When material changes are made, winph77 will notify registered players via their registered mobile number or email address, or by displaying a prominent notice on the Platform, at least seven (7) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the winph77 Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy. We encourage you to review this page periodically to stay informed about how winph77 protects your personal data.

14. Contact & Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by winph77, please contact our Data Privacy Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.