winingplus Privacy Policy

1. Overview & Scope

This Privacy Policy ("Policy") is issued by winingplus ("the Platform," "we," "us," "our") and applies to all personal data collected from individuals ("you," "Player," "User") who access or use the winingplus website, mobile platform, and related services (collectively, the "Platform").

winingplus is committed to protecting the privacy and security of your personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). By using the winingplus Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are available on the winingplus Platform. If you have any questions about how we handle your data, please contact us using the details provided in Section 13.

2. Personal Data We Collect

winingplus collects the following categories of personal data:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — you must be 21 or older)
• Nationality and country of residence
• Residential address (barangay, city/municipality, province)
• Mobile number (Philippine mobile number preferred)
• Email address

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, UMID, PhilHealth ID, driver's license, voter's ID)
• Selfie or live photo for liveness verification where required
• Proof of address documents where required

2.3 Financial Data

• GCash or Maya account number (mobile number)
• Bank account details (bank name, account number) for bank transfer transactions
• Debit card details (card number, expiry — stored in tokenized form only)
• Transaction history: deposits, withdrawals, and wager records

2.4 Gaming & Behavioral Data

• Game session logs (games played, duration, bet amounts, outcomes)
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion status)
• Customer support interaction records

2.5 Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Platform access logs and timestamps

3. How We Collect Your Data

winingplus collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, 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; fraud and AML screening data from compliance service providers; payment confirmation data from GCash, Maya, and banking partners.

4. How We Use Your Personal Data

winingplus processes your personal data for the following purposes:

5. Legal Basis for Processing

winingplus 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, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations, KYC requirements, and PAGCOR regulatory requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such 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

winingplus 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:

• KYC and identity verification providers: To verify your identity and age in compliance with regulatory requirements.
• Payment processors: GCash, Maya, and banking partners, to process your deposits and withdrawals.
• AML and fraud screening providers: To screen transactions and player activity against sanctions lists and fraud databases.
• Game software providers: Game providers may receive anonymized session data necessary to deliver their games on the Platform.
• IT and cloud infrastructure providers: Hosting, database, and security service providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Where required by law, court order, or regulatory directive — including PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC).

All third-party service providers who process personal data on behalf of winingplus are bound by contractual data processing agreements that require them to maintain appropriate security measures and process data only as instructed by winingplus.

7. Data Retention

winingplus retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, in accordance with AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming session logs: Retained for a minimum of two (2) years.
• Customer support records: Retained for a minimum of two (2) years from the date of the last interaction.
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter for compliance purposes.

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

8. Security Measures

winingplus implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• SSL/TLS encryption for all data transmitted between your device and the winingplus Platform.
• Encryption at rest for sensitive data fields including KYC documents and financial data.
• Tokenization of payment card details — raw card numbers are never stored on winingplus servers.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Multi-factor authentication for all internal systems that process personal data.
• Regular security audits and penetration testing conducted by independent third-party security firms.
• Incident response procedures to detect, contain, and notify affected players and the NPC of any personal data breach within the timeframes prescribed by the Data Privacy Act.

While winingplus takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

9. Cookies & Tracking Technologies

winingplus uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens and security cookies. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations.
• Analytics cookies: Collect aggregated, anonymized data about how players use the Platform to help us improve performance and user experience. Used only with your consent.
• Marketing cookies: Used to deliver relevant promotional content within the Platform. Used only with your consent.

You may manage your cookie preferences through the cookie settings panel available on the Platform. Disabling non-essential cookies will not affect your ability to use the core features of winingplus.

10. Your Privacy Rights

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

• Right to be informed: The right to know what personal data we collect and how we use it — which this Policy fulfils.
• Right of access: The right to request a copy of the personal data we hold 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 our legal retention obligations.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact the winingplus Data Protection Officer using the contact details in Section 13. We will respond to all verified requests within fifteen (15) business days, in accordance with NPC guidelines.

11. Minors & Age Restriction

The winingplus Platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect personal data from persons under 21. Age verification is conducted as part of the KYC process for all registered players.

If winingplus becomes aware that personal data has been collected from a person under 21, we will immediately suspend the associated account, delete the personal data, and report the matter to the appropriate authorities where required. If you believe a minor has registered on the Platform, please contact our support team immediately.

12. Changes to This Policy

winingplus reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via the email address on file or via 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 Policy will always reflect the most recent revision. Your continued use of the Platform following the effective date of any update constitutes your acceptance of the revised Policy.

13. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the winingplus Data Protection Officer:

• Live Chat: Available 24/7 directly on the winingplus Platform.
• Email (DPO): [email protected]

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have not been respected. Information about the NPC and how to file a complaint is available through official Philippine government channels.