phwon Privacy Policy

This Privacy Policy ("Policy") describes how phwon ("phwon", "we", "us", "our") collects, processes, stores, shares, and protects personal information in connection with your use of the phwon online gaming platform available at phwon.net and any related subdomains or services (collectively, the "Platform").

phwon is committed to protecting the privacy of all users of the Platform in accordance with the Republic Act No. 10173, known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC) of the Philippines.

This Policy applies to:

• All registered phwon account holders, regardless of whether they are currently active players.
• Visitors to the phwon website who have not registered an account.
• Former account holders whose data phwon is required to retain under applicable law.
• Any person who contacts phwon's customer support team via live chat or email.

This Policy should be read together with phwon's Terms & Conditions, which are incorporated herein by reference. Where this Policy and the Terms & Conditions conflict on matters of data privacy, this Policy takes precedence.

phwon collects personal information that is necessary to provide a secure, compliant, and high-quality gaming experience for Filipino players. The categories of personal data we collect include:

phwon collects personal information through several channels, depending on how you interact with the Platform:

• Direct Registration: Information you provide when creating a phwon account, including your name, date of birth, address, email, and mobile number.
• KYC Verification: Identity documents and supporting materials you submit during the Know Your Customer (KYC) verification process.
• Deposits & Withdrawals: Payment details and transaction records generated when you fund your phwon account or request a withdrawal via GCash, Maya, BPI, BDO, or other supported channels.
• Platform Usage: Technical and gaming data collected automatically as you navigate the phwon website, play games, place bets, and interact with Platform features. This includes cookies, server logs, and session tracking.
• Customer Support: Information you provide when contacting phwon via live chat or email, including the nature of your query and any personal details you share during the interaction.
• Third-Party Verification Services: phwon may receive data from identity verification service providers used in the KYC process to confirm the authenticity of documents you submit.
• Fraud Prevention Systems: Device fingerprinting and behavioural analytics tools that help phwon identify and prevent fraudulent activity on the Platform.

phwon does not purchase personal data from data brokers or other third-party marketing sources to build player profiles.

phwon uses your personal data only for specific, legitimate purposes directly connected to the operation of a licensed online gaming platform serving Filipino players. The primary purposes are:

• Account Management: Creating, verifying, and maintaining your phwon player account, including processing your registration and managing your account settings and preferences.
• Identity Verification (KYC): Confirming that you meet the age requirement (21+) and eligibility criteria for online gaming in the Philippines, as required by PAGCOR regulations.
• Payment Processing: Facilitating deposits and withdrawals through GCash, Maya, GrabPay, BPI, BDO, and other supported payment methods.
• Game Provision: Enabling you to access and play the full phwon game library, including slots, live casino, sports betting, bingo, and sabong.
• Bonus & Promotions Administration: Processing bonus credits, tracking wagering requirements, and verifying eligibility for phwon promotional offers.
• Responsible Gaming: Monitoring gaming behaviour to detect potential problem gambling patterns and to administer deposit limits, cooling-off periods, and self-exclusion requests in accordance with PAGCOR responsible gaming standards.
• Fraud Prevention & Security: Detecting and investigating suspicious activity, preventing unauthorised account access, and combating money laundering in compliance with Republic Act No. 9160 (AMLA).
• Customer Support: Responding to your queries, complaints, and data rights requests in a timely and accurate manner.
• Legal Compliance: Meeting phwon's obligations under Philippine law, including PAGCOR regulations, the Data Privacy Act, and the Anti-Money Laundering Act.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the phwon Platform, fix bugs, and develop new features that better serve Filipino players.
• Marketing Communications: Sending you promotional offers, new game announcements, and bonus notifications — but only where you have opted in to receive such communications.

Under the Data Privacy Act of 2012, phwon must have a lawful basis for processing your personal data. The legal bases phwon relies upon are:

• Contract Performance: Processing is necessary to perform our contractual obligations to you as a registered phwon player — including account creation, payment processing, and game provision.
• Legal Obligation: Processing is required to comply with Philippine law, including KYC/AML obligations under PAGCOR regulations and the Anti-Money Laundering Act.
• Legitimate Interests: Processing is necessary for phwon's legitimate business interests, including fraud prevention, platform security, and improving the Platform — provided these interests are not overridden by your fundamental rights.
• Consent: Where phwon relies on consent as the legal basis — primarily for marketing communications and the use of non-essential cookies — you may withdraw that consent at any time by contacting support or adjusting your account preferences.

phwon does not rely on consent as the legal basis for processing personal data that is necessary to fulfil our contractual or regulatory obligations. Withdrawing marketing consent, for example, will not affect phwon's ability to process your data for account management or payment purposes.

phwon does not sell, rent, or trade your personal data. We share personal information only in the following limited circumstances, and only with parties bound by appropriate data protection agreements:

• Payment Processors: GCash (Mynt), Maya (PayMaya Philippines), BPI, BDO, Metrobank, and other payment providers require certain transaction and identity data to process deposits and withdrawals.
• Identity Verification Providers: Third-party KYC service providers that assist phwon in verifying the authenticity of government-issued IDs and confirming age eligibility.
• Game Technology Providers: Software providers whose games are available on the phwon Platform may receive anonymised session data necessary to operate their games and resolve technical disputes.
• Fraud Prevention & Security Vendors: Specialised service providers who help phwon detect suspicious activity, prevent account takeovers, and comply with AML obligations.
• Regulatory Authorities: phwon is required by law to disclose certain data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities upon lawful request.
• Professional Advisers: phwon's lawyers, auditors, and other professional advisers where necessary in connection with the provision of their services, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of phwon's business or assets, your personal data may be transferred to the acquiring entity, subject to the same level of data protection commitments as set out in this Policy.

phwon uses cookies and similar technologies (such as web beacons and local storage) to operate the Platform, remember your preferences, and improve your overall experience. The following categories of cookies are used:

phwon does not use advertising or cross-site tracking cookies. We do not share cookie data with advertising networks or social media platforms.

You can manage or delete cookies through your browser settings at any time. Note that disabling essential or security cookies may prevent you from accessing certain features of the phwon Platform.

phwon retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by Philippine law. The following retention periods apply:

• Active Account Data: Retained for the duration of your phwon account and for five (5) years after account closure, consistent with PAGCOR record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years after each transaction under the Anti-Money Laundering Act and PAGCOR regulations.
• KYC Documents: Retained for five (5) years after account closure or the date of the last transaction, whichever is later.
• Customer Support Records: Retained for two (2) years after the closure of each support interaction, or longer where the interaction relates to an ongoing dispute or regulatory investigation.
• Marketing Consent Records: Retained for the duration of your account plus one (1) year, as evidence of your consent or opt-out status.
• Technical Logs (IP, session data): Retained for ninety (90) days for security and fraud investigation purposes, after which they are anonymised or deleted.

When your data is no longer required, phwon will either securely delete it, anonymise it so it can no longer be associated with you, or render it permanently inaccessible.

phwon takes the security of your personal data seriously and has implemented a multi-layered security framework to protect it against unauthorised access, accidental loss, destruction, or disclosure.

• Encryption in Transit: All data transmitted between your browser or device and the phwon Platform is protected using TLS 1.2 or higher encryption, indicated by HTTPS in your browser address bar.
• Encryption at Rest: Sensitive personal data stored on phwon's servers — including ID documents, financial records, and password hashes — is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to phwon staff who genuinely need it to perform their job functions. All staff with data access undergo background checks and regular data privacy training.
• Two-Factor Authentication: phwon offers and strongly encourages the use of two-factor authentication (2FA) on all player accounts to reduce the risk of unauthorised access.
• Penetration Testing: phwon's Platform and infrastructure undergo regular independent security assessments to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: phwon maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights, phwon will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, as required by NPC Circular 16-03.

While phwon takes every reasonable measure to protect your data, no online platform can guarantee absolute security. You also play a role in keeping your account secure — use a strong, unique password, enable 2FA, and never share your credentials with anyone.

As a data subject under the Data Privacy Act of 2012, Filipino players on phwon have the following rights with respect to their personal data. These rights may be exercised by contacting phwon's Data Protection Officer (DPO) at the details provided in Section 14.

phwon will respond to all verified data rights requests within fifteen (15) business days of receipt. In complex cases, this period may be extended by a further fifteen (15) business days, and you will be notified of the extension and the reason for it.

The phwon Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine law governing online gambling and gaming. phwon does not knowingly collect personal data from minors.

During registration, all applicants are required to provide their date of birth and to submit a government-issued photo ID confirming that they meet the age requirement. Accounts that are found to have been registered by individuals under the age of 21 will be immediately suspended, all funds will be frozen pending investigation, and the matter will be reported to the relevant authorities as required.

phwon also supports the use of parental control software to prevent minors from accessing online gambling websites. We recommend tools such as Net Nanny, Qustodio, and similar applications for households with children.

phwon primarily processes personal data within the Philippines. However, certain third-party service providers used by phwon — such as cloud infrastructure providers, identity verification vendors, and game software suppliers — may process data in other countries.

Where personal data is transferred outside the Philippines, phwon ensures that such transfers are made only to countries or organisations that provide an adequate level of data protection, or that appropriate safeguards are in place, including:

• Standard data processing agreements incorporating the NPC's approved contractual clauses for cross-border data transfers.
• Binding corporate rules where the recipient is a member of the same corporate group as phwon.
• Your explicit consent to the transfer, where required by law.

phwon does not transfer your data to jurisdictions that the NPC has determined to offer inadequate data protection without first putting in place appropriate safeguards and, where required, obtaining NPC approval for the transfer.

phwon may update this Privacy Policy from time to time to reflect changes in our data processing practices, updates to Philippine law or NPC guidance, or improvements to the phwon Platform. The "Last Updated" date at the top of this Policy will be revised accordingly whenever a material change is made.

Where a change to this Policy is material — meaning it significantly affects your rights or how phwon uses your data — phwon will provide advance notice by:

• Posting a prominent notice on the phwon homepage and/or login page for at least thirty (30) days before the change takes effect.
• Sending a notification to your registered email address, where we hold a valid and active email for your account.

Your continued use of the phwon Platform after any update to this Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you should stop using the Platform and may request closure of your account by contacting support.

phwon has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act of 2012. If you have any questions, concerns, or requests related to your personal data or this Policy, please contact the phwon DPO:

If you are not satisfied with phwon's response to your data rights request or complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines. The NPC can be contacted through its official website and hotline as published on its official government portal.