win36 Privacy Policy

win36 ("win36," "we," "us," or "our") operates the online casino platform accessible at win36.app, including all associated games, services, features, and mobile applications (collectively, the "Platform"). This Privacy Policy describes how win36 collects, uses, stores, shares, and protects the personal data of individuals ("you," "your," or "Data Subject") who access or use the Platform.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). It applies to all personal data processed by win36 in connection with the Platform, regardless of whether such data is collected online, offline, or through third-party integrations.

This Privacy Policy should be read together with the win36 Terms & Conditions, which govern your overall use of the Platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters of data privacy, this Privacy Policy shall prevail.

win36 collects personal data that is adequate, relevant, and limited to what is necessary for the purposes described in this Privacy Policy. The categories of personal data we collect include:

win36 does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where government-issued identification documents incidentally contain such information as part of mandatory KYC verification.

win36 collects personal data through the following channels and methods:

• Direct Submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Technologies: Data collected automatically when you access the Platform, including cookies, web beacons, pixel tags, server logs, and similar tracking technologies that record your device information, IP address, and browsing behavior on win36.
• Payment Processors: Transaction data received from payment service providers such as GCash, PayMaya, BDO, BPI, and Metrobank when you conduct financial transactions on the Platform.
• Identity Verification Partners: Data received from third-party KYC and identity verification service providers engaged by win36 to validate the authenticity of documents and information you submit.
• Fraud Prevention Services: Data received from fraud detection and anti-money laundering screening services used to protect the integrity of the Platform.
• Publicly Available Sources: In limited circumstances, win36 may supplement your data with information from publicly available sources, such as government sanction lists or public records, for AML compliance purposes.

win36 uses your personal data for the following purposes, each of which is grounded in a lawful basis described in Section 5:

• Account Management: To create, maintain, and administer your win36 account, including processing your registration, verifying your identity, and managing your account settings and preferences.
• Service Delivery: To provide you with access to win36 games, features, promotions, and customer support services, and to process your deposits and withdrawals in Philippine Peso (₱).
• KYC & Age Verification: To verify that you meet the minimum age requirement of 21 years as mandated by PAGCOR regulations and Philippine law, and to confirm your identity before processing withdrawals.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal or prohibited conduct on the Platform.
• Regulatory Compliance: To comply with our obligations under Philippine law, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and NPC data privacy regulations, including mandatory reporting to the Anti-Money Laundering Council (AMLC).
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce deposit and loss limits you have set, and administer self-exclusion requests in accordance with our Responsible Gaming policy.
• Communications: To send you account-related notifications, transaction confirmations, security alerts, and — where you have opted in — promotional communications about win36 offers and new games.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the win36 Platform.
• Legal Claims: To establish, exercise, or defend legal claims arising in connection with your use of the Platform.

win36 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have given explicit consent.

Under the Philippine Data Privacy Act of 2012, win36 processes your personal data on the following legal bases:

• Consent: Where you have given clear, informed, and freely given consent to the processing of your personal data for a specific purpose, such as receiving marketing communications or enabling optional platform features.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and win36 — specifically, the win36 Terms & Conditions — including account creation, game access, and payment processing.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to win36, including PAGCOR licensing conditions, AMLA reporting requirements, and NPC data privacy regulations.
• Legitimate Interests: Where processing is necessary for the legitimate interests of win36 or a third party, provided those interests are not overridden by your rights and interests. This includes fraud prevention, platform security, and service improvement.
• Vital Interests: In exceptional circumstances, where processing is necessary to protect your vital interests or those of another person.

win36 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Service Providers: GCash, PayMaya, BDO, BPI, Metrobank, and other payment processors engaged to facilitate deposits and withdrawals on the Platform. These providers process your financial data under their own privacy policies and are bound by contractual data protection obligations with win36.
• KYC & Identity Verification Providers: Third-party service providers engaged to verify your identity and age as part of the mandatory KYC process. These providers are contractually bound to process your data solely for verification purposes.
• Fraud Prevention & AML Screening Services: Service providers that assist win36 in detecting and preventing fraud, money laundering, and other illegal activity. Data shared is limited to what is necessary for screening purposes.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law, court order, or regulatory directive.
• Legal Advisors & Auditors: Professional advisors, including lawyers, accountants, and auditors, who are bound by professional confidentiality obligations and engaged to provide services to win36.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of win36's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third parties with whom win36 shares personal data are required to maintain appropriate technical and organizational security measures and to process your data only for the purposes for which it was shared.

win36 uses cookies and similar tracking technologies — including web beacons, pixel tags, and local storage — to enhance your experience on the Platform, remember your preferences, maintain your session, and analyze how the Platform is used.

The types of cookies used by win36 include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings, display preferences, and responsible gaming limits you have set. Disabling these may affect your experience.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform — such as which games are most popular and how long sessions last — to help win36 improve its services.
• Security & Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and abuse of the Platform.

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the win36 Platform, including your ability to stay logged in or access certain features. win36 does not use third-party advertising cookies or behavioral tracking cookies for external advertising purposes.

win36 retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your win36 account and for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and AMLA record-keeping obligations.
• KYC & Identity Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, in accordance with AMLA requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years following the date of the transaction, as required by AMLA and PAGCOR regulations.
• Gaming Activity Records: Retained for a minimum of three (3) years following account closure for responsible gaming monitoring and regulatory reporting purposes.
• Customer Support Communications: Retained for a minimum of two (2) years following the resolution of the relevant support interaction.
• Technical & Usage Data: Retained for up to twelve (12) months for security and platform improvement purposes, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, win36 will securely delete or anonymize your personal data in accordance with NPC guidelines on data disposal. Where data cannot be immediately deleted due to technical constraints, it will be isolated and protected from further processing until deletion is possible.

win36 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and win36 servers is encrypted using industry-standard 256-bit SSL/TLS protocols.
• Encryption at Rest: Sensitive personal data stored on win36 servers — including identity documents, financial data, and KYC records — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to win36 personnel and authorized service providers who have a legitimate need to access it. All access is logged and subject to regular review.
• Two-Factor Authentication (2FA): win36 offers 2FA for player accounts and requires it for all internal administrative access to systems containing personal data.
• Regular Security Audits: win36 conducts regular internal and third-party security audits, penetration testing, and vulnerability assessments to identify and remediate security risks.
• Incident Response: win36 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, win36 will notify the NPC and affected data subjects in accordance with NPC Circular No. 16-03 on personal data breach management.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by win36. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13.

win36 will respond to all data subject requests within thirty (30) calendar days of receipt. Where a request is complex or involves a large volume of data, win36 may extend this period by a further thirty (30) days, with prior notice to you. win36 reserves the right to verify your identity before processing any data subject request.

If you believe that win36 has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

win36 is strictly an adult platform. The minimum age to register and use win36 is 21 years, as required under Philippine law and PAGCOR regulations governing online gambling. win36 does not knowingly collect personal data from individuals under the age of 21.

If win36 discovers or is notified that personal data has been collected from an individual under the age of 21, we will immediately suspend the relevant account, delete the associated personal data, and refund any real-money balance to the payment method used for deposit, subject to verification. Any winnings generated by an underage account will be forfeited.

win36 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC regulations, or PAGCOR requirements. The "Last Updated" date at the top of this page will be revised whenever a material change is made.

Where changes are material — meaning they significantly affect your rights or how win36 processes your personal data — win36 will notify registered players via the email address on file at least fourteen (14) days before the changes take effect. For non-material updates, the revised Privacy Policy will be posted on this page and will take effect immediately upon posting.

Your continued use of the win36 Platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated Privacy Policy, you must stop using the Platform and may request account closure by contacting our support team.

win36 has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012 and NPC Circular No. 17-01. The DPO is responsible for overseeing win36's compliance with data privacy laws and handling data subject requests and complaints.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by win36, please contact our Data Protection Officer:

For general customer support inquiries unrelated to data privacy, please contact our 24/7 support team via live chat on the win36 Platform or by email at [email protected].

If you are not satisfied with win36's response to your data subject request or complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines.