Privacy Policy – win100 Philippines

1. Introduction

Win100 ("win100", "we", "us", or "our") is committed to protecting the privacy and personal data of every player who accesses or uses the win100 platform at win100.biz (the "Platform"). This Privacy Policy ("Policy") describes the types of personal information we collect, the purposes for which we use it, how long we retain it, with whom we share it, and the rights you have in relation to your personal data.

By registering for or using the win100 platform, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree with this Policy, please do not use the Platform. This Policy is to be read together with our Terms and Conditions, which are available at /terms-conditions.

2. Data Controller

For the purposes of applicable data protection law, win100 is the data controller in respect of all personal data collected through the win100 platform. As data controller, win100 determines the purposes and means of processing your personal data. Any requests relating to your personal data should be directed to the win100 Data Protection contact identified in Section 13 of this Policy.

3. What Personal Data We Collect

win100 collects personal data in the following categories, depending on how you interact with the Platform:

3.1 Registration Data

• Full legal name (as per government-issued Philippine identification)
• Date of birth (used for mandatory 21+ age verification)
• Philippine mobile number (Globe, Smart, or DITO)
• Email address
• Residential address in the Philippines
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• Government-issued identification document (PhilSys ID, Philippine passport, or driver's licence)
• Selfie or liveness check photograph for identity matching
• Proof of address (utility bill, bank statement, or equivalent)
• Proof of payment method ownership (where required for withdrawals)

3.3 Financial Data

• GCash number, Maya account number, or bank account details used for deposits and withdrawals
• Transaction history (deposit amounts, withdrawal amounts, dates, and payment methods)
• Wallet balance information at time of any compliance-triggered review

3.4 Gaming Activity Data

• Game sessions played, including game title, bet amounts, and outcomes
• Bonus and promotion redemption history
• Session duration and login/logout timestamps
• Responsible gaming tool usage (deposit limits, self-exclusion periods)

3.5 Technical and Device Data

• IP address at time of login and each session
• Device type, operating system, and browser version
• Mobile network carrier identifier (where applicable)
• Cookie identifiers and session tokens (see Section 7)

3.6 Communications Data

• Content of live chat interactions with win100 support
• Email correspondence with win100
• Dispute submissions and any attached evidence

4. How We Use Your Personal Data

win100 uses your personal data for the following purposes:

win100 does not use automated profiling or algorithmic decision-making that produces legal or similarly significant effects on players without human review.

5. Legal Basis for Processing

win100 processes your personal data on the following legal bases under applicable Philippine data protection law (Republic Act No. 10173, the Data Privacy Act of 2012, and its Implementing Rules and Regulations):

• Contractual necessity: Processing required to perform the contract between win100 and you as a registered player, including account creation, game provision, and payment processing.
• Legal obligation: Processing required for compliance with applicable law, including KYC, AML, PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, security monitoring, platform improvement, and responsible gaming programme delivery, where these interests are not overridden by your rights.
• Consent: Processing for optional marketing communications, where you have given clear and specific consent, which you may withdraw at any time by contacting win100 support or updating your account notification preferences.

6. Data Sharing and Third-Party Disclosure

win100 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only in the following limited circumstances:

6.1 Game Providers

Technical session data (player ID, session token, bet metadata) is shared with licensed game software providers (e.g., JILI, Evolution Gaming, Pragmatic Play) solely to enable gameplay. These providers are contractually prohibited from using this data for any purpose other than game delivery and technical support.

6.2 Payment Processors

Financial data necessary to process transactions is shared with payment processing partners (GCash, Maya, BPI, BDO, Metrobank, Coins.ph, and Visa/Mastercard acquiring banks) under strict data processing agreements and only to the extent required to execute the relevant transaction.

6.3 Identity Verification Services

KYC data may be processed by a third-party identity verification service provider engaged by win100 to perform automated and manual document and liveness checks. Such providers are bound by data processing agreements and may not retain or use KYC data beyond the scope of verification.

6.4 Regulatory and Law Enforcement Authorities

win100 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts where required by applicable Philippine law, a valid court order, or in response to a lawful regulatory demand. win100 will notify you of such disclosure where legally permitted to do so.

6.5 Business Succession

In the event of a merger, acquisition, or sale of all or a substantial portion of win100's business assets, player personal data may be transferred to the successor entity, subject to equivalent or greater data protection commitments. You will be notified of any such transfer.

7. Cookies and Tracking Technologies

win100 uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies: Required for the Platform to function — session management, authentication tokens, and security cookies. These cannot be disabled without impairing Platform functionality.
• Analytics cookies: Used to understand how players navigate the Platform, which game categories are most visited, and where technical friction occurs. Data is aggregated and does not identify individual players to win100's analytics team.
• Preference cookies: Store your language, notification, and display preferences so you don't have to reset them on each visit.
• Marketing cookies: Used only with your explicit consent to present relevant promotions. You may withdraw consent at any time via browser settings or account preferences.

You can control non-essential cookies through your browser settings. Note that disabling cookies may affect the performance of certain features on the win100 platform.

8. Data Retention

win100 retains 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 5 years from the date of account closure, in compliance with AMLC record-keeping requirements.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, as required by applicable Philippine AML law.
• Gaming activity logs: Retained for a minimum of 2 years from the date of each session, for dispute resolution and regulatory audit purposes.
• Customer support records: Retained for 2 years from the date of the last interaction, or longer if related to an ongoing dispute or investigation.
• Marketing consent records: Retained for the duration of your consent plus 1 year to evidence compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with win100's data deletion procedures.

9. Your Data Rights

As a data subject under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights in relation to your personal data held by win100:

• Right to be informed: The right to know what personal data win100 holds about you and how it is being used — which this Policy addresses.
• Right of access: You may request a copy of the personal data win100 holds about you. Requests will be responded to within 30 days.
• Right to rectification: You may request correction of inaccurate or incomplete personal data. You may update many details directly in your win100 account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to win100's legal retention obligations (see Section 8).
• Right to object: You may object to processing of your personal data for direct marketing purposes at any time, and for processing based on legitimate interests where your rights override those interests.
• Right to data portability: You may request that win100 provide a machine-readable copy of your personal data for transfer to another data controller where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact win100's Data Protection contact as described in Section 13.

10. Data Security

win100 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption of all data in transit between your device and the win100 Platform
• Encryption of sensitive personal data (including passwords and payment details) at rest
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Two-factor authentication enforced for all win100 staff with access to player data systems
• Regular security audits and penetration testing by independent security firms
• Incident response procedures aligned to NPC notification requirements in the event of a data breach

In the event of a personal data breach that poses a risk to your rights and freedoms, win100 will notify the National Privacy Commission and, where required, notify affected players within the timeframes prescribed by applicable Philippine law.

11. Children and Minors

The win100 platform is strictly restricted to persons aged 21 years and above. 21+ win100 does not knowingly collect or process personal data from persons under 21 years of age. Age verification is conducted at registration and at each withdrawal to enforce this restriction. If win100 discovers that personal data has been collected from a person under 21, that data will be permanently deleted and the associated account closed immediately. If you believe a minor has registered on the Platform, please contact win100 support without delay.

12. Changes to This Privacy Policy

win100 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, win100 will provide notice via in-platform notification or direct email to your registered address. The date of the most recent revision is displayed at the top of this Policy. Continued use of the Platform following notification of changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

13. Contact Us — Data Protection Enquiries

For all privacy-related enquiries, data subject rights requests, or concerns about this Policy, please contact the win100 Data Protection team:

• Email: [email protected] — subject line: "Privacy / Data Request"
• Live Chat: Available 24/7 via the in-platform chat widget
• Response time: Data subject rights requests acknowledged within 5 business days; substantive response within 30 days

You may also file a complaint with the National Privacy Commission of the Philippines (NPC) if you believe your data rights have not been adequately addressed by win100. NPC contact details are published on the official NPC website.

This Privacy Policy was last reviewed and updated on 1 January 2026. All previous versions are superseded by this document.