phwim Privacy Policy

1. Who We Are

phwim ("we," "us," "our," or "the Company") operates the online gaming platform accessible at phwim.app, offering casino games, live dealer tables, slots, bingo, and related gaming services to eligible players in the Philippines. phwim acts as the data controller in respect of all personal data collected through the phwim platform.

This Privacy Policy applies to all users of the phwim website and platform, including registered players, visitors who browse without registering, and individuals who contact phwim support. By accessing or using phwim, you acknowledge that you have read and understood this Privacy Policy.

2. Personal Data We Collect

phwim collects the following categories of personal data from players and platform users:

phwim does not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data, health information, or political affiliations.

3. How We Collect Your Data

phwim collects personal data through the following means:

• Direct collection: Information you provide when registering a phwim account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the phwim platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from licensed KYC providers; fraud and sanctions screening data from compliance service providers; payment data from GCash, PayMaya, and banking partners.
• Publicly available sources: Information from public registries or databases used for fraud prevention and regulatory compliance purposes.

4. How We Use Your Personal Data

phwim uses your personal data for the following purposes:

• Account management: Creating and maintaining your phwim player account, verifying your identity and age (21+ requirement), and managing your account settings and preferences.
• Platform operation: Providing access to phwim games, processing bets, calculating winnings, and delivering the core gaming experience.
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card; verifying payment method ownership; and maintaining transaction records.
• Regulatory compliance: Meeting obligations under Philippine gaming regulations, anti-money laundering (AML) laws, and the Data Privacy Act of 2012, including mandatory reporting to PAGCOR and other competent authorities.
• Fraud prevention and security: Detecting and preventing fraudulent activity, unauthorized account access, bonus abuse, and other prohibited conduct.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior, enforcing deposit limits and self-exclusion requests, and providing responsible gaming support.
• Customer support: Responding to your inquiries, resolving disputes, and improving the quality of phwim's support services.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time.
• Platform improvement: Analyzing usage patterns and player feedback to improve phwim's games, features, and user experience.

phwim will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173), phwim processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., operating your phwim account, processing payments, and delivering gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, AML obligations, and tax reporting requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

phwim does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC and identity verification providers: Licensed third-party providers who assist phwim in verifying player identities and ages in compliance with regulatory requirements.
• Payment processors: GCash, PayMaya, and banking partners who process your deposits and withdrawals. These providers are subject to their own privacy policies and applicable financial regulations.
• Game software providers: Licensed game suppliers whose platforms power phwim's casino games. These providers may receive anonymized or pseudonymized gaming data for technical and operational purposes.
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where disclosure is required by law or court order.
• Fraud prevention services: Third-party providers who assist phwim in detecting and preventing fraudulent activity and sanctions violations.
• IT and cloud service providers: Providers who host and maintain phwim's platform infrastructure, subject to strict data processing agreements.

All third parties with whom phwim shares personal data are contractually required to process such data only for the specified purpose, to maintain appropriate security standards, and to comply with applicable data protection laws.

7. Cookies & Tracking Technologies

phwim uses cookies and similar tracking technologies to operate and improve the platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the phwim platform to function. These include session cookies that maintain your login state and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, game display options, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymized data about how players use the phwim platform, helping us identify areas for improvement. Used only with your consent.
• Marketing cookies: Track your interactions with phwim promotions to deliver relevant offers. Used only with your explicit consent.

You can manage your cookie preferences through your browser settings or phwim's cookie consent tool. Disabling non-essential cookies will not affect your ability to use the core phwim platform.

8. Data Retention

phwim retains your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to the following retention periods:

• Account data: Retained for the duration of your phwim account and for a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Support communications: Retained for three (3) years from the date of the communication, or longer if relevant to an ongoing dispute or regulatory matter.
• Marketing data: Retained until you withdraw consent or for a maximum of two (2) years from your last interaction with phwim marketing communications, whichever is earlier.

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

9. Data Security

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

• Encryption: All data transmitted between your device and the phwim platform is encrypted using 256-bit SSL/TLS technology. Sensitive data at rest is encrypted using industry-standard algorithms.
• Access controls: Access to personal data is restricted to phwim personnel and authorized third parties who require it for legitimate operational purposes, on a strict need-to-know basis.
• Two-factor authentication: phwim supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security.
• Regular security audits: phwim conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities in the platform.
• Incident response: phwim maintains a data breach response plan. In the event of a breach affecting your personal data, phwim will notify you and the National Privacy Commission (NPC) within the timeframes required by the Data Privacy Act.

While phwim takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your phwim account credentials.

10. Your Data Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in respect of your personal data held by phwim:

• Right to be informed: The right to know what personal data phwim collects about you and how it is used — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data phwim holds 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 phwim's legal retention obligations.
• Right to object: 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 data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phwim has violated your data privacy rights.

To exercise any of these rights, please contact phwim's Data Protection Officer using the contact details in Section 14. phwim will respond to all verified data rights requests within thirty (30) days of receipt. We may request proof of identity before processing your request.

11. Children's Privacy

The phwim platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gaming regulations. phwim does not knowingly collect personal data from individuals under the age of 21.

phwim enforces the 21+ age requirement through mandatory KYC identity verification at the time of registration. Any account found to belong to a person under 21 years of age will be immediately suspended, all balances will be frozen pending investigation, and the matter will be referred to the relevant regulatory authorities.

If you believe that phwim has inadvertently collected personal data from a person under 21, please contact us immediately at the details provided in Section 14 so that we can take prompt corrective action.

12. Cross-Border Data Transfers

phwim's primary data processing operations are conducted within the Philippines. However, some of phwim's third-party service providers — including cloud infrastructure providers, KYC verification services, and game software suppliers — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, phwim ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Philippine Data Privacy Act. These safeguards may include:

• Standard contractual clauses approved by the National Privacy Commission.
• Transfers to jurisdictions recognized as providing an adequate level of data protection.
• Binding corporate rules where applicable within phwim's corporate group.

You may request further information about the specific safeguards applied to cross-border transfers of your personal data by contacting phwim's Data Protection Officer.

13. Updates to This Privacy Policy

phwim may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or platform features. The effective date at the top of this page will be updated whenever a material change is made.

Where changes are material, phwim will notify registered players via email to their registered address or through an in-platform notification prior to the changes taking effect. For non-material changes, continued use of the phwim platform following the updated effective date constitutes acceptance of the revised Privacy Policy.

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

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or phwim's handling of your personal data, please contact our Data Protection Officer:

• Data Protection Officer: phwim DPO
• Email: [email protected]
• General Support: [email protected]
• Response Time: phwim aims to acknowledge all privacy-related inquiries within 5 business days and to resolve them within 30 days.

If you are not satisfied with phwim's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). Information about the NPC and how to file a complaint is available through official Philippine government channels.