phwine Privacy Policy

1.Data Controller Identity

phwine is the personal information controller responsible for the processing of personal data collected through the phwine Platform at https://phwine.club. phwine has appointed a designated Data Protection Officer (DPO) in accordance with Section 21 of the IRR of RA 10173. Data subject requests and privacy-related inquiries may be directed to the DPO at the contact details provided in Section 13 of this Policy.

2.Personal Data We Collect

phwine collects personal data that you provide directly during account registration and ongoing platform use, as well as data generated automatically during your interaction with the phwine Platform. The categories of personal data collected include:

Category	Data Elements	Source
Identity Data	Full legal name, date of birth, government ID type and number, selfie/photo for biometric identity verification	Provided by you during registration and KYC
Contact Data	Email address, Philippine mobile number, residential address	Provided by you during registration
Financial Data	GCash number, PayMaya number, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records	Provided by you; generated by platform transactions
Gaming Activity Data	Game session logs, bet history, wager amounts, game outcomes, bonus activity, win/loss records	Automatically generated by platform use
Technical Data	IP address, device type and model, operating system, browser type, session timestamps, geolocation (jurisdiction verification)	Automatically collected via platform systems and cookies
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Generated during support interactions

phwine does not collect sensitive personal information (as defined under Section 3(l) of RA 10173), such as health data, political opinions, or religious beliefs, except where disclosure is strictly required by applicable law or regulatory mandate.

3.How phwine Uses Your Personal Data

phwine processes your personal data for the following purposes, each grounded in a lawful basis as described in Section 4:

• Account creation and management: Processing your registration, authenticating your identity at login, maintaining your account, and providing access to phwine's games and features.
• Payment processing: Facilitating deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank; verifying payment method ownership; preventing payment fraud.
• Regulatory compliance: Conducting KYC (Know Your Customer) verification as required by PAGCOR; complying with AMLA obligations; maintaining records required by Philippine gaming and financial regulations.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviors; administering self-exclusion, deposit limits, and cooling-off periods; complying with PAGCOR responsible gaming standards.
• Platform security and fraud prevention: Detecting and investigating suspicious account activity, unauthorized access, bonus abuse, money laundering, and other prohibited activities.
• Customer support: Responding to your inquiries, disputes, and feedback; maintaining support interaction records for quality assurance.
• Marketing communications: Sending promotional offers, game updates, and platform announcements by email or SMS — only with your prior consent and always with a clear opt-out mechanism.
• Platform improvement: Analyzing aggregated, anonymized usage data to improve game selection, user interface, and platform performance.

4.Legal Basis for Processing

phwine processes your personal data on the following lawful bases under Section 12 of RA 10173:

• Contractual necessity: Processing required to perform the contract between you and phwine (i.e., your account agreement and the Terms & Conditions), including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with phwine's legal obligations under PAGCOR regulations, AMLA (RA 9160 as amended), and other applicable Philippine law.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where phwine's interests do not override your fundamental privacy rights.
• Consent: Processing for marketing communications and optional analytics features, where you have provided freely given, specific, and informed consent. You may withdraw consent at any time without affecting prior processing.

5.Data Sharing and Disclosure

phwine does not sell, rent, or trade your personal data. We share personal data only in the following limited circumstances:

• PAGCOR and Philippine regulatory authorities: phwine discloses player data to PAGCOR and other authorized Philippine government agencies as required by law, including AMLA reporting to the Anti-Money Laundering Council (AMLC).
• Payment processors: GCash (G-Xchange Inc.), PayMaya Philippines, and Philippine banking partners receive necessary financial data to process your deposits and withdrawals. These entities are bound by their own data protection obligations under Philippine law.
• Game providers: Certified game software providers receive anonymized session data necessary to deliver game functionality. No identifiable personal data beyond a session token is shared with game providers.
• IT and security service providers: Cloud hosting providers, cybersecurity vendors, and platform infrastructure providers process data on phwine's behalf under written data processing agreements that require compliance with RA 10173 standards.
• Legal proceedings: phwine may disclose personal data where required by court order, subpoena, or other lawful legal process issued by a Philippine court or competent authority.

All third-party data processors engaged by phwine are subject to contractual data processing agreements that impose data protection obligations consistent with RA 10173 and phwine's security standards.

6.Cookies and Tracking Technologies

phwine uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies: Required for platform functionality, including session management, login state persistence, and security tokens. These cannot be disabled without impairing Platform function.
• Analytics cookies: Used to collect anonymized data on page views, feature usage, and session duration to improve Platform performance. These are activated only with your consent.
• Preference cookies: Store your Platform settings, such as language preferences and display options.

You may manage cookie preferences through your browser settings. Blocking strictly necessary cookies may impair your ability to log in and use phwine. phwine does not use third-party advertising or tracking pixels.

7.Data Retention

phwine retains personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC records: Retained for a minimum of 5 years from account closure, as required by PAGCOR regulations and AMLA.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction, in compliance with AMLA record-keeping requirements.
• Support communications: Retained for 2 years from the date of the communication, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your account plus 2 years, to demonstrate lawful basis for marketing communications.

Upon expiry of applicable retention periods, phwine securely deletes or anonymizes personal data. Where anonymization is not technically feasible, data is archived in restricted-access storage with access logging.

8.Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted to and from the phwine Platform
• AES-256 encryption for personal data stored at rest in phwine's databases
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Multi-factor authentication for all phwine administrative system access
• Regular penetration testing and vulnerability assessments by independent third-party security firms
• 24/7 monitoring of platform systems for unauthorized access attempts and anomalous activity

9.Your Data Subject Rights

Under RA 10173, you have the following rights with respect to your personal data processed by phwine:

• Right to Access: You may request a copy of the personal data phwine holds about you and information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Some data (such as your legal name) can be updated only through the KYC re-verification process.
• Right to Erasure: You may request deletion of your personal data, subject to phwine's legal obligations to retain records under PAGCOR, AMLA, and other applicable Philippine law. Erasure requests during the mandatory retention period will be noted but fulfilled only after the retention period expires.
• Right to Object: You may object to processing based on legitimate interests and to all direct marketing processing at any time. Objection to marketing is always honoured immediately.
• Right to Data Portability: Where technically feasible, you may request a copy of your personal data in a structured, machine-readable format.
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission of the Philippines (NPC) if you believe phwine has violated your data privacy rights.

To exercise any of these rights, contact phwine's Data Protection Officer as detailed in Section 13. phwine will respond to all data subject requests within 15 business days of receipt of a complete request.

10.Children's Privacy and Age Restriction

The phwine Platform is strictly restricted to persons aged 21 years and above, in compliance with PAGCOR's online gambling regulations. phwine does not knowingly collect personal data from individuals under 21 years of age. If phwine determines that personal data has been collected from an underage individual, the associated account will be immediately closed, all balances voided, and collected data deleted to the extent permitted by law. Parents or guardians who become aware that an underage person has registered on phwine should contact phwine support immediately.

11.Third-Party Services and Links

The phwine Platform integrates third-party services — including certified game providers and payment processors — which operate under their own privacy policies. phwine's Privacy Policy does not govern the data practices of these third parties. Where phwine shares data with third parties as described in Section 5, we do so under data processing agreements that require those parties to maintain standards consistent with RA 10173. phwine recommends that you review the privacy policies of any third-party services you interact with through phwine.

12.Changes to This Privacy Policy

phwine may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, phwine will notify registered Players by email to the address on record, or via a prominent in-platform notice, at least 7 days before the changes take effect. The current version of this Privacy Policy is always accessible at https://phwine.club/privacy-policy. The effective date at the top of this Policy indicates when the most recent version was published. Continued use of the phwine Platform following the effective date of any update constitutes acceptance of the revised Policy.

13.Contact and Data Protection Officer

For any questions, requests, or concerns relating to this Privacy Policy or phwine's data processing practices, please contact:

• Data Protection Officer (DPO): phwine Data Protection Office
• Email: support@phwine.club
• Live Chat: Available 24/7 via the phwine Platform
• Response time: Privacy requests acknowledged within 2 business days; resolved within 15 business days

Complaints that cannot be resolved directly with phwine may be submitted to the National Privacy Commission of the Philippines (NPC) at complaints@privacy.gov.ph or via the NPC website. phwine cooperates fully with NPC investigations and takes all data subject complaints seriously.