phwind Privacy Policy

Welcome to the phwind Privacy Policy. phwind ("we," "us," or "our") is committed to protecting the personal data of every player who uses the phwind Platform at phwind.net. This Privacy Policy describes in clear, legal-standard terms how phwind collects, uses, discloses, stores, and protects your personal information when you access or interact with the phwind website, create a phwind account, make deposits or withdrawals, play games, or contact our support team.

This Privacy Policy should be read alongside phwind's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. By using the phwind Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

For the purposes of applicable data protection legislation, the data controller responsible for your personal information is phwind, operating the platform accessible at phwind.net and providing online gaming services to players in the Philippines.

As data controller, phwind determines the purposes for which and the means by which your personal data is processed. phwind is responsible for ensuring that such processing complies with applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

For all data protection enquiries, you may contact phwind's designated Data Protection Officer (DPO) at [email protected] with the subject line "Data Privacy Request."

phwind collects the following categories of personal data, depending on how you interact with the Platform:

phwind collects personal data through the following means:

• Direct submission: Data you provide when registering your phwind account, completing KYC verification, making deposits or withdrawals, contacting our support team, or submitting any form on the Platform.
• Automated collection: Technical and behavioural data collected automatically when you access and use the phwind Platform, including through cookies, log files, and analytics tools.
• Payment processors: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, and Metrobank when you process payments through those services.
• Third-party game providers: Aggregated gameplay logs from phwind's licensed game studio partners who power the games available on the Platform.
• Identity verification services: Confirmation data from third-party KYC and identity verification service providers used to validate the authenticity of documents submitted during the verification process.

phwind processes your personal data for the following specific purposes:

• Account management: Creating, maintaining, and securing your phwind account, including authentication, password resets, and session management.
• KYC & regulatory compliance: Verifying your age (21+) and identity as required under PAGCOR-aligned regulations and Philippine anti-money laundering laws.
• Transaction processing: Processing your PHP deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers accurately and securely.
• Fraud prevention and security: Detecting and preventing fraudulent account activity, bonus abuse, unauthorised access, and money laundering.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behaviours and to apply deposit limits, session reminders, or self-exclusion measures where appropriate.
• Customer support: Responding to your enquiries, resolving disputes, and providing assistance through our 24/7 support channels.
• Platform improvement: Analysing aggregated usage data to improve the performance, design, and content of the phwind Platform.
• Marketing communications: Sending you promotional offers and phwind news — but only where you have given explicit consent to receive such communications.
• Legal obligations: Complying with applicable Philippine laws, regulatory orders, and court requirements where phwind is legally obligated to disclose or retain data.

phwind processes your personal data on the following legal bases under the Data Privacy Act of 2012 (RA 10173) and applicable regulations:

• Contractual necessity: Processing required to fulfil our obligations under the phwind Terms & Conditions, including account management, payment processing, and customer support.
• Legal obligation: Processing required for phwind to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and KYC requirements.
• Legitimate interests: Processing for fraud detection, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights.
• Consent: Processing for optional purposes such as marketing communications and the use of non-essential cookies, where you have provided explicit, freely given consent. You may withdraw this consent at any time.

phwind does not sell, rent, or trade your personal data to third parties for their own commercial purposes. phwind shares your data only in the following limited circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank receive the transaction data necessary to process your deposits and withdrawals. Each processor operates under its own privacy policy and data security standards.
• KYC and identity verification providers: phwind uses licensed third-party KYC service providers to validate identity documents. These providers process only the data necessary to complete verification and are contractually bound to confidentiality obligations.
• Game studio providers: Licensed game studios that power phwind's slots, live dealer, and other games may receive session identifiers and gameplay data necessary to deliver those games. They do not receive your full identity or financial information.
• Regulatory and law enforcement authorities: phwind will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory and law enforcement bodies where required by law or valid legal order.
• Professional advisers: Lawyers, auditors, and compliance consultants who are bound by professional confidentiality obligations, where necessary for phwind's legal and regulatory compliance.
• Business transfers: In the event of a merger, acquisition, or sale of phwind's business assets, personal data may be transferred to the successor entity. You will be notified of any such transfer and your options with respect to your data.

phwind uses cookies and similar tracking technologies on the phwind Platform. Cookies are small text files stored on your device that help us deliver a better, more personalised experience.

phwind uses the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly — including session management, login authentication, and security. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and game display options to provide a more personalised experience.
• Analytics cookies: Collect aggregated, anonymised data about how players use the phwind Platform, helping us identify popular games and improve Platform performance. Used only with your consent.
• Security cookies: Help detect and prevent fraudulent activity, including bot traffic and account takeover attempts.

You may manage your cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the phwind Platform, though some features may be affected. Note that strictly necessary cookies cannot be disabled as they are required for basic Platform functionality.

phwind retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, and compliance obligations. The following general retention periods apply:

• Account data and KYC documents: Retained for the duration of your phwind account plus a minimum of 5 years following account closure, as required under Philippine AMLA and PAGCOR regulations.
• Transaction records: Retained for a minimum of 5 years from the date of the transaction, in line with Philippine financial record-keeping requirements.
• Support communications: Retained for 3 years following the resolution of the relevant support interaction.
• Marketing consent records: Retained for 3 years from the date consent was last confirmed or until consent is withdrawn, whichever is earlier.
• Technical and log data: Retained for up to 12 months from the date of collection, unless a longer period is required for a specific security investigation or legal proceeding.

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

phwind takes the security of your personal data seriously and implements a range of technical and organisational measures to protect it against unauthorised access, loss, alteration, or disclosure:

• Encryption: All data transmitted between your device and the phwind Platform is encrypted using TLS (Transport Layer Security). Sensitive data at rest is encrypted using AES-256 encryption.
• Credential security: Passwords are stored using strong one-way cryptographic hashing. phwind never stores your plain-text password.
• Access controls: Access to personal data is strictly limited to phwind personnel and authorised service providers who require it to perform their specific functions, under binding confidentiality obligations.
• Two-factor authentication (2FA): OTP-based 2FA is available and encouraged for all phwind accounts to add an additional layer of login security.
• Monitoring and incident response: phwind continuously monitors its systems for security anomalies and maintains an incident response plan to address data breaches promptly and in accordance with applicable notification requirements.

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by phwind:

• Right to be informed: The right to know what personal data phwind holds about you and how it is being used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data phwind holds about you, including your account information, KYC records, and transaction history.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held by phwind.
• Right to erasure: The right to request deletion of your personal data, subject to phwind's legal and regulatory data retention obligations (see Section 9).
• Right to object: The right to object to phwind's processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time.
• Right to data portability: The right to request your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phwind has violated your data privacy rights.

To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Privacy Request." phwind will respond to all verified data rights requests within 30 days of receipt. Requests may require identity verification before they can be actioned.

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

phwind implements KYC age verification procedures to prevent underage access to the Platform. If phwind discovers that personal data has been collected from an individual who is under 21 years of age, phwind will immediately:

• Permanently close the affected account.
• Securely delete all personal data associated with the underage account as promptly as possible, subject to any applicable legal retention obligations.
• Void and forfeit any balances or winnings held in the affected account.

If you believe that a minor is using or has registered a phwind account, please report this immediately to [email protected].

The phwind Platform primarily serves Filipino players and operates within the regulatory framework of the Philippines. In certain cases, personal data may be processed or stored on servers located outside the Philippines — for example, when using cloud infrastructure or third-party service providers whose data centres are located in other countries.

Where personal data is transferred internationally, phwind ensures that appropriate safeguards are in place to protect that data, including contractual data transfer agreements that impose data protection standards equivalent to those required under Philippine law. phwind will not transfer your personal data to a country or territory that does not provide an adequate level of protection for personal data without first implementing the appropriate safeguards.

phwind reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable laws, or the phwind Platform's features. When material changes are made, phwind will update the "Last Updated" date at the top of this page.

Where required by applicable law, or where changes are material to your rights, phwind will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the phwind Platform following the publication of any revised Privacy Policy constitutes your acceptance of the updated terms.

We recommend reviewing this Privacy Policy periodically. If you have questions about any change, please contact our support team before continuing to use the Platform.

If you have any questions, concerns, or requests relating to this Privacy Policy or phwind's data practices, please contact us through any of the following channels:

• Email (Data Privacy): [email protected] — subject line: "Data Privacy Request"
• Live Chat: Available 24/7 directly within the phwind Platform
• Messenger: Via phwind's official Messenger support channel

For further information on your rights under the Data Privacy Act of 2012, or to file a complaint, you may also contact the National Privacy Commission (NPC) of the Philippines.