win36e Privacy Policy

§ 01 Introduction

This Privacy Policy ("Policy") describes how win36e ("win36e," "we," "us," or "our") collects, uses, stores, and discloses personal information about individuals ("you," "your," or "Player") who access or use the win36e online casino platform, including the win36e website and any associated mobile-optimised interfaces.

win36e is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. This Policy is drafted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

By registering a win36e account or using any win36e service, 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, please discontinue use of the win36e platform and contact our support team to close your account.

§ 02 Personal Data We Collect

win36e collects personal data through several channels: directly from you when you register or use our services, automatically through your use of the platform, and from third parties where permitted by law. The categories of personal data we collect include:

win36e does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive personal information is collected (such as government ID numbers), it is handled with the heightened protections required under the DPA.

§ 03 How We Use Your Personal Data

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

1. Account Management: To create, maintain, and administer your win36e player account, including verifying your identity and age (21+ requirement) and managing your account settings and preferences.
2. Service Delivery: To provide access to win36e games, process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and deliver the full range of win36e platform features.
3. Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160, as amended), the DPA, and all other applicable Philippine laws and regulations, including mandatory reporting obligations.
4. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other security threats to the win36e platform and its players.
5. Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through the win36e support team.
6. Responsible Gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, and to administer self-exclusion and deposit limit requests in accordance with our Responsible Gaming policy.
7. Platform Improvement: To analyse usage patterns, conduct internal research, and improve the win36e platform, game offerings, and user experience.
8. Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent to receive such communications. You may withdraw this consent at any time.

win36e will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by law.

§ 04 Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform the contract between you and win36e — specifically, to operate your player account, process transactions, and deliver the services you have requested.
• Legal Obligation: Processing is required to comply with win36e's legal obligations under Philippine law, including PAGCOR regulations, AML reporting requirements, and tax obligations.
• Legitimate Interests: Processing is necessary for win36e's legitimate interests in preventing fraud, ensuring platform security, and improving our services, provided these interests are not overridden by your data privacy rights.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — win36e relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

§ 05 Sharing Your Personal Data

win36e does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary and permitted by law:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers require certain personal and financial data to process your deposits and withdrawals securely.
• Identity Verification Providers: Third-party KYC and AML screening services that assist win36e in verifying player identities and screening against sanctions lists and politically exposed persons (PEP) databases.
• Technology and Hosting Providers: Cloud infrastructure, data storage, and software providers that support the operation of the win36e platform. These providers are contractually bound to process data only on win36e's instructions and to maintain appropriate security standards.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where disclosure is required by law, court order, or regulatory directive.
• Professional Advisers: Lawyers, auditors, and accountants who provide professional services to win36e, subject to strict confidentiality obligations.

§ 06 Cookies and Tracking Technologies

win36e uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how you use win36e.

The types of cookies win36e uses include:

• Strictly Necessary Cookies: Essential for the win36e platform to function. These include session authentication cookies and security tokens. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and game history to provide a more personalised experience on win36e.
• Analytics Cookies: Help win36e understand how players interact with the platform — which pages are visited most, where players encounter issues, and how navigation flows are used. This data is aggregated and anonymised where possible.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of win36e marketing campaigns. These are only placed with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the win36e platform. For strictly necessary cookies, no consent is required as they are essential to service delivery.

§ 07 Data Security

win36e implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and win36e servers.
• Encryption of sensitive data at rest, including financial information and government ID data.
• Role-based access controls ensuring that win36e staff can only access personal data necessary for their specific job functions.
• Regular security audits, vulnerability assessments, and penetration testing of the win36e platform.
• Multi-factor authentication requirements for win36e administrative systems.
• Incident response procedures to detect, contain, and notify affected players of any personal data breach in accordance with NPC notification requirements.

While win36e takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are also responsible for maintaining the security of your win36e account credentials. If you suspect that your account has been compromised, please contact win36e support immediately via the Support page.

§ 08 Data Retention

win36e retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law and regulatory obligations. Specific retention periods include:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required under PAGCOR regulations and AML obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act.
• KYC Verification Documents: Retained for the duration of your account and for five (5) years following account closure.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, or longer if the matter is subject to ongoing legal proceedings.
• Marketing Consent Records: Retained for as long as you remain subscribed to marketing communications, plus three (3) years thereafter as evidence of consent.
• Technical and Usage Logs: Retained for up to twelve (12) months for security and analytics purposes, after which they are anonymised or deleted.

Upon expiry of the applicable retention period, win36e will securely delete or anonymise your personal data in a manner that prevents reconstruction or identification.

§ 09 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by win36e:

• Right to Be Informed: The right to be told what personal data win36e collects about you, how it is used, and with whom it is shared — which is the purpose of this Privacy Policy.
• Right to Access: The right to request a copy of the personal data win36e holds about you, along with information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data win36e holds about you.
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful, subject to win36e's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on win36e's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe win36e has violated your data privacy rights.

To exercise any of these rights, please contact the win36e Data Privacy Officer through the Support page. win36e will respond to all verified data privacy requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

§ 10 Children's Privacy

The win36e platform is strictly intended for adults aged 21 years and above. win36e does not knowingly collect personal data from individuals under the age of 21. The minimum age for participation in casino-style gambling in the Philippines is 21 years, as prescribed under applicable PAGCOR regulations.

If win36e becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on win36e, please notify us immediately through the Support page.

win36e employs age verification procedures during the registration process and reserves the right to request documentary proof of age at any time. Accounts that cannot confirm the 21+ age requirement will be suspended pending verification.

§ 11 International Data Transfers

win36e primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed from servers or service providers located outside the Philippines — for example, where win36e uses cloud infrastructure or technology providers with international operations.

Where such transfers occur, win36e ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised by the NPC.
• Entering into data transfer agreements with international recipients that impose data protection obligations equivalent to those required under the DPA.
• Implementing technical safeguards such as encryption to protect data in transit across international networks.

By using win36e, you acknowledge and consent to the transfer of your personal data as described in this section, subject to the safeguards outlined above.

§ 12 Changes to This Privacy Policy

win36e 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, win36e will notify registered players by email or through a prominent notice on the win36e platform at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of win36e after the effective date of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how win36e protects your personal data.

If the changes materially affect how win36e processes your personal data in a way that requires fresh consent under the DPA, win36e will seek your explicit consent before the new processing begins.

§ 13 Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or win36e's handling of your personal data, please contact the win36e Data Privacy Officer through the Support page. Our team is available 24/7 and will acknowledge your inquiry within two (2) business days.

If you are not satisfied with win36e's response to your data privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines:

win36e takes all data privacy complaints seriously and is committed to resolving them promptly and fairly in accordance with the DPA and NPC guidelines.