win36e Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how win36e ("win36e", "we", "us", "our") collects, processes, stores, and discloses personal information relating to individuals ("you", "Player", "User") who access or use the win36e online casino platform, including the website at win36e.cam, any associated mobile progressive web application, and all related services (collectively, the "Platform").

win36e is committed to protecting the privacy and personal data of all users in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission ("NPC"). As a PAGCOR-regulated online gaming operator, we also comply with applicable PAGCOR data governance requirements.

By accessing the win36e Platform and registering an account, 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 this Policy, please do not use the Platform. This Policy should be read alongside our Terms and Conditions and Responsible Gaming Policy.

2. Data Controller Information

win36e operates as the personal information controller ("PIC") for all personal data collected through the Platform. As the PIC, win36e determines the purposes and means by which your personal data is processed. Our designated Data Protection Officer ("DPO") oversees compliance with the Data Privacy Act and this Policy.

For all data privacy-related inquiries, correction requests, or complaints, you may contact the win36e Data Protection Officer at: [email protected] — please note this is displayed as plain text and is not a clickable link.

3. Personal Data We Collect

win36e collects the following categories of personal data in connection with the registration, operation, and maintenance of your account:

3.1 Identity and Contact Data

• Full legal name (as it appears on your government-issued ID);
• Date of birth (for age verification — you must be 21 years of age or older);
• Philippine mobile phone number;
• Email address;
• Residential address in the Philippines;
• Nationality and citizenship information.

3.2 Verification and KYC Data

• Copies of government-issued identification documents (e.g., Philippine passport, SSS, UMID, PhilSys National ID, driver's license, Voter's ID, PRC ID);
• Selfie or facial image for identity matching purposes;
• Proof of address documents where required;
• Source of funds declarations for accounts exceeding specified transaction thresholds.

3.3 Financial and Transaction Data

• GCash account number or Maya account details linked to your win36e account;
• Philippine bank account details (BPI, BDO, UnionBank) where applicable;
• Transaction history including deposits, withdrawals, and gaming wagers;
• Bonus redemption and promotional activity records.

3.4 Technical and Usage Data

• IP address and approximate geolocation at time of access;
• Device type, operating system, and browser or app version;
• Session logs including login timestamps, duration, and activity;
• Game history and betting records;
• Cookie and tracking identifiers (see Section 8).

3.5 Communications Data

• Records of customer support interactions (chat logs, email correspondence);
• Responses to surveys, feedback forms, or promotions;
• Marketing communication preferences and opt-in/opt-out records.

4. How We Collect Your Data

win36e 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, server logs, and analytics tools (see Section 8);
• Third-Party Sources: Verification data received from KYC service providers, payment processors (e.g., GCash, Maya, BPI), and fraud detection services as part of regulatory compliance obligations;
• PAGCOR and Regulatory Sources: Information shared by PAGCOR or other regulatory bodies in connection with licensing obligations, responsible gaming programs, or investigations.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, win36e processes your personal data on the following legal grounds:

Processing Purpose	Legal Basis
Account registration and management	Contractual necessity — performance of our Terms and Conditions
Age and identity verification (KYC)	Legal obligation — PAGCOR regulatory requirements and Anti-Money Laundering Act compliance
Payment processing and fraud prevention	Contractual necessity and legitimate interests
Responsible gaming monitoring	Legal obligation — PAGCOR responsible gaming requirements
Customer support	Contractual necessity and legitimate interests
Marketing communications	Your explicit consent (opt-in)
Platform security and abuse prevention	Legitimate interests
Legal compliance and regulatory reporting	Legal obligation

6. How We Use Your Personal Data

win36e uses the personal data we collect for the following specific purposes:

• To create, verify, and maintain your win36e account;
• To verify your age (21+) and identity in compliance with PAGCOR requirements;
• To process deposits and withdrawals via GCash, Maya, and Philippine bank channels;
• To provide and improve the games, live casino, bingo, and sports betting services on the Platform;
• To detect, prevent, and investigate fraud, money laundering, collusion, and other prohibited activities;
• To comply with our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine law;
• To administer bonuses, promotions, and loyalty rewards;
• To provide customer support and resolve disputes;
• To send you transactional notifications (account activity, withdrawal confirmations, security alerts);
• To send you marketing communications about win36e promotions and new games, where you have opted in to receive such communications;
• To monitor gaming patterns for responsible gaming purposes and implement protective measures where appropriate;
• To maintain Platform security, integrity, and performance.

win36e does not use your personal data for automated decision-making that produces legal or similarly significant effects, except where required for mandatory fraud screening or regulatory compliance, and in those cases we provide a mechanism for human review upon request.

7. Data Sharing and Disclosure

win36e does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• PAGCOR and Regulatory Authorities: We are required to share certain player data with the Philippine Amusement and Gaming Corporation and other competent Philippine government authorities as a condition of our operating license and in compliance with applicable law;
• Anti-Money Laundering Council (AMLC): Transaction data and suspicious activity reports are shared with the AMLC in compliance with the Anti-Money Laundering Act of 2001, as amended;
• Payment Service Providers: We share necessary financial data with GCash (Mynt), Maya (Voyager Innovations), BPI, BDO, UnionBank, and other payment partners for the processing of deposits and withdrawals. These providers are bound by their own privacy policies and Philippine data protection obligations;
• KYC and Identity Verification Providers: We engage licensed third-party KYC providers to assist with identity and age verification in compliance with PAGCOR requirements;
• Game Technology Providers: Your gameplay data is shared with licensed game studios (e.g., JILI, Pragmatic Play) solely for the purpose of game delivery, RNG certification, and dispute resolution;
• IT and Security Service Providers: Third-party technology vendors who support Platform hosting, security monitoring, and fraud detection operate under strict data processing agreements with win36e;
• Law Enforcement: We may disclose personal data to Philippine law enforcement agencies where required by court order, subpoena, or other lawful demand.

All third parties with whom we share personal data are required to process such data only for the specified purpose and in accordance with the Data Privacy Act of 2012.

8. Cookies and Tracking Technologies

win36e uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small data files placed on your device when you access the win36e website. We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function, including session management, login authentication, and security. These cannot be disabled;
• Functional Cookies: Remember your preferences such as language settings and game layout choices to improve your experience;
• Analytics Cookies: Collect aggregated information about how players use the Platform, helping us improve game performance and navigation. Data collected is anonymized where possible;
• Marketing Cookies: Used only with your explicit consent to deliver relevant win36e promotions. You may withdraw this consent at any time through your browser settings or by contacting our support team.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will affect Platform functionality. win36e does not use third-party advertising networks or place cookies on behalf of external advertisers.

9. Data Retention

win36e retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. Specific retention periods include:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA requirements;
• Transaction records: Retained for a minimum of five (5) years following the transaction date, in compliance with AMLA reporting obligations;
• Customer support communications: Retained for three (3) years from the date of the interaction;
• Marketing consent records: Retained for the duration of your account plus three (3) years following account closure;
• Technical and session logs: Retained for twelve (12) months, after which they are deleted or anonymized.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized in accordance with NPC-approved data disposal procedures.

10. Data Security

win36e implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security infrastructure includes:

• Transport Layer Security (TLS 1.3) encryption for all data transmitted between your device and the win36e Platform;
• AES-256 encryption for personal data stored in our databases;
• One-time password (OTP) two-factor authentication for all account logins;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular independent security audits and penetration testing;
• Real-time fraud monitoring and anomaly detection systems;
• Physical and environmental security controls for data center infrastructure.

Despite these measures, no security system is completely impenetrable. In the event of a personal data breach that is likely to result in serious harm to affected individuals, win36e will notify the National Privacy Commission and affected players within 72 hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03.

11. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by win36e:

• Right to be Informed: The right to know that your personal data is being collected and processed, as provided by this Policy;
• Right to Access: The right to request a copy of the personal data win36e holds about you, as well as information about how it is being processed;
• Right to Rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data in your win36e account;
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to our legal retention obligations under PAGCOR and AMLA requirements;
• Right to Object: The right to object to the processing of your personal data for marketing purposes at any time. Withdrawal of marketing consent will not affect the lawfulness of prior processing;
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format where technically feasible;
• 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.

To exercise any of these rights, please contact the win36e Data Protection Officer. We will respond to all verified requests within thirty (30) calendar days. Some requests may be subject to identity verification before processing, and certain rights may be limited where they conflict with our legal obligations under Philippine law or PAGCOR regulations.

12. International Data Transfers

While win36e is a Philippines-focused platform, some of our third-party service providers — including game studios, KYC verification providers, and cloud infrastructure partners — may process your personal data in jurisdictions outside the Philippines. Where such transfers occur, win36e ensures that appropriate safeguards are in place, including:

• Contractual clauses requiring offshore processors to comply with standards equivalent to the Philippine Data Privacy Act;
• Verification that recipient jurisdictions provide adequate levels of data protection;
• Data processing agreements that restrict the use of transferred data to specified, limited purposes.

win36e does not transfer personal data to jurisdictions that do not provide adequate data protection without implementing appropriate additional safeguards, in compliance with NPC guidelines on cross-border data flows.

13. Children and Minors

The win36e Platform is strictly restricted to individuals who are twenty-one (21) years of age or older, in compliance with PAGCOR regulations governing online gambling in the Philippines. win36e does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from an individual under 21 years of age — whether through misrepresentation during registration or any other means — we will immediately suspend and close the associated account, void any winnings derived from the account, and securely delete the personal data of the minor in accordance with our data retention procedures. The matter will be reported to PAGCOR as required.

Parents and guardians who believe that a minor has registered on the win36e Platform should contact our customer support team immediately so that appropriate action can be taken.

14. Changes to This Privacy Policy

win36e reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, we will:

• Update the "Last Updated" date at the top of this Policy;
• Notify registered players via email to the address on file; and
• Post a prominent notice on the win36e Platform for a period of not less than thirty (30) days following the change.

We encourage you to review this Policy periodically. Your continued use of the win36e Platform following any update to this Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you may request account closure at any time.

15. Contact and Complaints

For all data privacy-related inquiries, requests to exercise your data subject rights, or complaints regarding the handling of your personal data, please contact the win36e Data Protection Officer:

Email: [email protected] — please include "Data Privacy Request" in the subject line. This address is displayed as plain text only and is not a clickable link.

We aim to acknowledge all data privacy requests within five (5) business days and to provide a substantive response within thirty (30) calendar days. Complex requests may require additional time, in which case we will inform you of the expected timeframe.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) through their official channels. The NPC is the independent authority established under the Data Privacy Act to ensure compliance and protect the data privacy rights of Filipino citizens.