winoh Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how winoh ("winoh," "we," "us," or "our"), the operator of the online gaming platform at https://winoh.org ("the Platform"), collects, uses, shares, and protects personal data relating to individuals ("you," "Player," or "User") who access or use the Platform or any related services.

winoh takes its obligations under Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR") seriously. This Policy is designed to give you clear, transparent information about how your personal data is handled, and to explain the rights available to you as a data subject under Philippine law.

This Policy should be read alongside winoh's Terms & Conditions. By registering for a winoh account or using the Platform, you acknowledge that you have read and understood this Policy.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and its IRR, winoh is the Personal Information Controller (PIC) in respect of all personal data collected through the Platform.

winoh's designated Data Protection Officer (DPO) oversees compliance with this Policy and applicable data protection legislation. You may contact the DPO at any time with privacy-related inquiries. Contact details are provided in Section 14 of this Policy.

3. Personal Data We Collect

winoh collects the following categories of personal data in connection with account registration, platform use, and regulatory compliance:

3.1 Identity Data

• Full legal name as it appears on your government-issued identification
• Date of birth
• Nationality and country of residence
• Government ID type and number (passport, driver's license, PhilSys ID, SSS, UMID, or PRC ID)
• Photograph (where provided for KYC identity verification)

3.2 Contact Data

• Email address
• Philippine mobile telephone number
• Residential or mailing address

3.3 Financial Data

• GCash wallet reference associated with your winoh account
• PayMaya, BPI, BDO, or Metrobank account details used for deposits or withdrawals
• Transaction history (deposits, withdrawals, wager amounts, winnings)
• Source of funds information where required by anti-money-laundering regulations

3.4 Technical & Usage Data

• IP address and approximate geolocation at the time of login or wagering
• Device type, operating system, and browser information
• Session timestamps, login history, and activity logs
• Game play history, betting patterns, and session duration
• Cookie identifiers and tracking data (see Section 7)

3.5 Communications Data

• Records of your communications with winoh's customer support team via live chat or email
• Feedback, complaints, or dispute records

4. How We Use Your Personal Data

winoh uses the personal data it collects for the following purposes:

• Account Administration: To create, maintain, verify, and administer your winoh player account, including password resets and security alerts.
• Identity Verification (KYC): To verify that you meet the eligibility requirements to use the Platform, including the 21+ age requirement mandated by PAGCOR.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, Philippine banks, and other supported payment methods, and to maintain accurate financial records.
• Regulatory Compliance: To comply with PAGCOR licensing obligations, Republic Act No. 9160 (Anti-Money Laundering Act), Republic Act No. 10173 (Data Privacy Act), and other applicable Philippine laws and regulations.
• Responsible Gaming: To monitor for indicators of problem gambling, enforce self-exclusion orders, apply player-set deposit and session limits, and fulfill winoh's duty of care to players under PAGCOR's responsible gaming framework.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, collusion, account takeover, and other prohibited conduct on the Platform.
• Platform Improvement: To analyse usage patterns and technical performance data to improve the Platform's functionality, game selection, and user experience for Filipino players.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through winoh's 24/7 support team.
• Marketing Communications: Where you have provided explicit consent, to send you information about promotions, bonuses, new game releases, and other winoh news. You may withdraw consent at any time.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its IRR, winoh relies on the following legal bases for the processing of your personal data:

• Contractual necessity: Processing required to perform the contract between you and winoh — account administration, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine law — PAGCOR licensing conditions, AMLA reporting obligations, and National Privacy Commission requirements.
• Legitimate interest: Processing necessary for winoh's legitimate operational interests — fraud prevention, platform security, responsible gaming monitoring — where these are not overridden by your rights and interests.
• Consent: Where winoh relies on your consent as the legal basis for processing (e.g., marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

winoh does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary and lawful:

• PAGCOR and Regulatory Authorities: winoh is obligated to share player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities as required by law.
• Payment Providers: GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency processor partners receive financial data necessary to process your deposits and withdrawals.
• KYC and Identity Verification Services: Third-party identity verification providers who assist winoh in fulfilling its PAGCOR-mandated KYC obligations.
• Game Software Providers: Licensed B2B gaming suppliers receive technical session data required to deliver game services and to maintain their own regulatory compliance.
• IT and Security Service Providers: Cloud infrastructure, cybersecurity, and platform monitoring vendors who process data as Personal Information Processors under winoh's instructions and applicable data processing agreements.
• Legal and Professional Advisers: Where necessary in connection with legal proceedings, regulatory investigations, or corporate transactions, subject to confidentiality obligations.

7. Cookies & Tracking Technologies

winoh uses cookies and similar technologies to operate the Platform and to improve your experience. A cookie is a small text file stored on your device when you visit the Platform.

7.1 Types of Cookies Used

• Strictly Necessary Cookies: Essential to operate the Platform — session management, login authentication, and security functions. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences — language settings, game history display, and layout preferences — to provide a more personalised experience.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform, which pages are visited most frequently, and where errors occur. This data helps winoh improve the Platform for Filipino users.
• Security Cookies: Used to detect and prevent fraudulent logins, unusual geographic access patterns, and bot activity.

You may control cookie settings through your browser's privacy settings. Note that disabling cookies may affect the functionality of the winoh Platform.

8. Data Retention

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

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required under Republic Act No. 9160 (Anti-Money Laundering Act) and PAGCOR licensing conditions.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the relevant transaction.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless retention is required longer for dispute resolution purposes.
• Marketing consent records: Retained until consent is withdrawn, plus a further two (2) years for compliance record-keeping.
• Technical and log data: Generally retained for twelve (12) months, unless required longer for security investigation purposes.

Upon expiry of the applicable retention period, winoh securely destroys or anonymises personal data in accordance with the DPA and its IRR.

9. Your Data Subject Rights

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights in relation to your personal data held by winoh:

To exercise any of the above rights, please contact winoh's Data Protection Officer using the contact details in Section 14. winoh will respond to all valid data subject requests within fifteen (15) calendar days, as required by the DPA IRR.

10. Data Security

winoh implements a range of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Access controls limiting personal data access to authorised winoh personnel with a legitimate business need;
• Multi-factor authentication for all internal systems handling personal data;
• Regular security audits, penetration testing, and vulnerability assessments;
• Incident response procedures compliant with the NPC's mandatory personal data breach notification requirements.

11. Children's Privacy

The winoh Platform is strictly for individuals aged 21 years and above in accordance with PAGCOR regulations and applicable Philippine gaming laws. winoh does not knowingly collect personal data from individuals under 21 years of age.

If winoh becomes aware that personal data has been collected from a person under the age of 21, it will promptly close the associated account, delete the personal data to the extent permitted by applicable retention obligations, and return any funds where legally required. If you believe your child or a minor has registered a winoh account, please contact us immediately using the details in Section 14.

12. International Data Transfers

Some of winoh's third-party service providers — including game software suppliers and cloud infrastructure providers — may be located or operate servers outside the Republic of the Philippines. Where personal data is transferred to recipients outside the Philippines, winoh ensures that such transfers are made only to countries or organisations that provide an adequate level of data protection, or pursuant to contractual arrangements that impose data protection obligations equivalent to those required under the DPA and its IRR.

In all cases, winoh remains responsible for ensuring that your personal data is protected to the standards required under Philippine law, regardless of where it is processed.

13. Changes to This Privacy Policy

winoh may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR requirements, or NPC guidance. The date of the most recent revision is displayed at the top of this Policy.

Where changes are material, winoh will notify registered players by email or by a prominent notice on the Platform at least seven (7) days before the revised Policy takes effect. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Policy.

14. Contact & Privacy Complaints

For any privacy-related questions, data subject rights requests, or concerns about how winoh handles your personal data, please contact our Data Protection Officer:

If you are not satisfied with winoh's response, you have the right to file a complaint with the National Privacy Commission of the Philippines. Information about filing NPC complaints is available on the NPC's official website.