Privacy Policy — phwn Casino

Introduction

This Privacy Policy ("Policy") describes how phwn Casino ("phwn," "we," "us," "our") collects, processes, stores, and discloses personal information relating to registered players and visitors ("you," "Data Subject") of the phwn platform, accessible at phwn.club.

phwn operates as a PAGCOR-regulated online gaming platform serving players in the Philippines. As a licensed operator, phwn is required under Philippine law — including the Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its implementing rules — as well as under PAGCOR's licensing conditions, to process certain categories of personal data for identity verification, transaction monitoring, and regulatory compliance purposes.

This Policy applies to all personal data collected through the phwn website, mobile browser interface, account registration process, customer support interactions, and all other touchpoints through which phwn receives personal information about you. By registering a phwn account or using phwn's Services, you acknowledge that you have read and understood this Policy.

Data Controller Information

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, phwn Casino is the Personal Information Controller ("PIC") responsible for your personal data collected through the phwn platform.

phwn has appointed a designated Data Protection Officer ("DPO") responsible for overseeing compliance with this Policy, the DPA, and phwn's internal data governance procedures. Inquiries relating to data privacy may be directed to phwn's support team via live chat, which can route your query to the appropriate compliance personnel.

Categories of Personal Data We Collect

phwn collects the following categories of personal data, depending on the nature of your interaction with the platform:

How phwn Collects Your Data

phwn collects personal data through the following channels and mechanisms:

• Direct Submission: Information you voluntarily provide when registering a phwn account, completing KYC verification, updating your account details, or contacting customer support.
• Automated Technical Collection: Technical data collected automatically when you access the phwn platform, including IP address, device information, browser type, and session activity, via server logs and similar technologies.
• Cookies and Similar Tracking Technologies: As described in Section 8 of this Policy, phwn uses cookies and related technologies to collect data about your browsing behavior on phwn.club.
• Payment Processors: Transaction confirmation data received from phwn's integrated payment processors (GCash, Maya, BDO, BPI, Metrobank, and other supported methods) following deposit or withdrawal processing.
• Third-Party Verification Providers: Identity verification data returned by KYC service providers engaged by phwn to assist with PAGCOR compliance screening.
• Game Providers: Game session data generated by phwn's integrated game providers (including JILI, Pragmatic Play, and others) during gameplay, returned to phwn for account management, bonus processing, and regulatory reporting purposes.

Legal Basis for Processing Personal Data

Under the Data Privacy Act of 2012, phwn processes your personal data on one or more of the following legal bases:

• Contractual Necessity: Processing necessary to enter into and perform the contract between you and phwn under the platform's Terms and Conditions — including account creation, payment processing, and game service delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR's KYC and AML requirements under the Anti-Money Laundering Act (Republic Act No. 9160, as amended), and the Terrorism Financing Prevention and Suppression Act.
• Legitimate Interests: Processing necessary for phwn's legitimate business interests, including fraud detection and prevention, platform security monitoring, customer support operations, and platform improvement — provided those interests are not overridden by your privacy rights.
• Consent: Where phwn processes data for optional purposes (such as marketing communications or optional analytics), consent forms the legal basis. You may withdraw consent at any time by contacting phwn support, without affecting the lawfulness of prior processing.

How phwn Uses Your Personal Data

phwn uses the personal data it collects for the following specific purposes:

• Account Management: Creating and maintaining your phwn account, verifying your identity at registration and during ongoing compliance reviews, and managing account settings and security.
• Payment Processing: Processing deposits and withdrawals, verifying that payment instruments are registered in your name, and maintaining transaction records for audit and regulatory purposes.
• Gaming Services: Enabling access to phwn's game library, recording game session data for account history, processing bonus activation and wagering requirements, and delivering promotional offer communications where consented.
• PAGCOR Compliance and AML: Fulfilling phwn's mandatory Know Your Customer (KYC), Anti-Money Laundering (AML), and counter-terrorism financing (CTF) obligations as a PAGCOR-licensed operator. This includes ongoing transaction monitoring and, where required, reporting to PAGCOR or the Anti-Money Laundering Council (AMLC).
• Security and Fraud Prevention: Monitoring login activity, detecting anomalous account behavior, investigating suspected fraud or platform abuse, and protecting the integrity of phwn's platform and player funds.
• Customer Support: Responding to your support inquiries, resolving account disputes, processing responsible gaming requests (including self-exclusion), and maintaining records of support interactions.
• Platform Improvement: Analyzing aggregated and anonymized usage data to identify and fix technical issues, improve the mobile experience, and enhance platform features for the benefit of all phwn players.
• Legal Proceedings: Preserving and disclosing personal data where required by court order, regulatory direction from PAGCOR, or other lawful process under Philippine law.

Data Sharing and Third-Party Disclosure

phwn does not sell, rent, or trade your personal information to third parties for commercial purposes. phwn may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

• PAGCOR and Regulatory Authorities: phwn is legally required to provide player data — including identity information, transaction records, and gaming history — to PAGCOR upon request, and to report certain transactions to the Anti-Money Laundering Council (AMLC) under the Philippines' AMLA framework. These disclosures are mandatory and are not subject to your consent.
• Payment Processors: phwn shares transaction data with integrated Philippine payment processors (GCash, Maya, BDO, BPI, Metrobank, and others) as necessary to process your deposits and withdrawals. Each processor is subject to their own data privacy obligations under Philippine law.
• Game Content Providers: Game session data is shared with phwn's integrated game providers (including JILI and Pragmatic Play) as necessary to deliver game services and to support bonus and jackpot processing. These providers operate under data processing agreements with phwn.
• KYC and Identity Verification Providers: phwn engages third-party identity verification services to assist with PAGCOR-mandated KYC screening. These providers process identity data under strict contractual obligations and are prohibited from using it for any purpose beyond verification.
• IT and Security Service Providers: phwn's platform infrastructure relies on contracted technical service providers for hosting, security monitoring, and platform maintenance. These providers operate under data processing agreements and may have limited access to personal data in the course of their services.
• Law Enforcement and Courts: phwn will disclose personal data to Philippine law enforcement agencies, courts, or other government bodies when required to do so by applicable law, court order, or lawful direction.

Cookies and Tracking Technologies

phwn uses cookies and similar tracking technologies (collectively, "Cookies") on phwn.club. Cookies are small data files placed on your browser or device when you visit the platform. They help phwn remember your session, preferences, and activity to improve your experience and for compliance purposes.

phwn uses the following categories of Cookies:

You may manage Cookie preferences through your browser settings. Note that disabling Essential Cookies will impair your ability to log in and use phwn's platform. For analytics and marketing Cookies, you may opt out at any time without affecting your ability to play.

Data Retention

phwn retains personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, tax, and reporting obligations under Philippine law. The following general retention periods apply:

• Account and Identity Data: Retained for the lifetime of your phwn account plus a minimum period of five (5) years following account closure, consistent with PAGCOR's record-keeping requirements and the Philippines' AMLA.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by PAGCOR and the AMLC.
• KYC Documentation: Retained for a minimum of five (5) years from the date of verification or from account closure, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the interaction, unless the matter has resulted in a formal dispute requiring longer retention.
• Technical and Session Logs: Retained for up to twelve (12) months, after which they are deleted or anonymized.
• Marketing Communications Data: Retained until you withdraw consent or request removal from phwn's communications list.

At the end of applicable retention periods, phwn will securely delete or anonymize personal data in a manner that prevents reconstruction or identification.

Data Security Measures

phwn implements technical and organizational security measures appropriate to the sensitivity of the personal data it processes. These measures include, but are not limited to:

• SSL/TLS encryption for all data transmitted between your browser and phwn's servers, including login credentials and financial transaction data.
• Encryption at rest for stored personal data, including identity documents and financial records.
• Access controls restricting internal access to personal data on a strict need-to-know basis, with all access logged and auditable.
• Multi-factor authentication for phwn system administrators accessing sensitive data.
• Regular security vulnerability assessments and penetration testing of phwn's platform infrastructure.
• Incident response procedures for detecting, containing, and reporting personal data breaches in accordance with the DPA's 72-hour breach notification requirement to the National Privacy Commission (NPC) where applicable.

International Data Transfers

phwn's primary platform infrastructure is located within or serving the Philippines. However, some of phwn's third-party service providers — including game content providers, technical infrastructure vendors, and KYC verification services — may process personal data in jurisdictions outside the Philippines.

When personal data is transferred outside the Philippines, phwn ensures that appropriate safeguards are in place consistent with the DPA's requirements for cross-border data transfers. These safeguards typically include contractual clauses requiring the receiving party to maintain data protection standards equivalent to those applicable in the Philippines.

phwn does not transfer personal data to jurisdictions where adequate data protection standards cannot be contractually assured.

Your Data Subject Rights Under RA 10173

As a data subject under the Philippines' Data Privacy Act of 2012, you hold the following rights in respect of your personal data processed by phwn. To exercise any of these rights, please contact phwn's support team via live chat or email.

Please note that certain data subject rights are subject to limitations where personal data must be retained to comply with phwn's legal obligations under PAGCOR regulations, the AMLA, or other applicable Philippine law. phwn will inform you of any applicable limitations when responding to a rights request.

If you are not satisfied with phwn's response to a data subject rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

Children's Privacy and Minor Protection

phwn's Services are strictly restricted to individuals aged 21 years and above, as required by PAGCOR for online gaming platforms in the Philippines. phwn does not knowingly collect personal data from individuals under the age of 21.

If phwn discovers or is notified that personal data has been collected from an individual under 21 years of age — whether through misrepresentation during registration or otherwise — phwn will take the following steps:

• Immediately suspend the relevant phwn account pending investigation.
• Delete or return any personal data collected from the minor where legally permissible.
• Report the matter to PAGCOR as required under phwn's licensing conditions.
• Refer the matter to appropriate authorities where circumstances warrant.

If you are the parent or guardian of a minor who you believe has provided personal data to phwn, please contact our support team immediately via live chat so we can investigate and take appropriate action.

Third-Party Links and Services

The phwn platform may contain reference to third-party services — including game providers, payment processors, and other integrated services — that operate under their own privacy policies and data practices. phwn is not responsible for the privacy practices of third-party services that are not directly operated by phwn.

When you use a third-party payment method such as GCash or Maya to deposit to or withdraw from your phwn account, that transaction is also subject to the relevant payment provider's privacy policy. phwn recommends reviewing the privacy policies of any third-party services you use in connection with your phwn account.

Amendments to This Privacy Policy

phwn reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform Services. When material changes are made, phwn will update the "Effective Date" at the top of this Policy and will make reasonable efforts to notify active Players via their registered email address.

Continued use of phwn's Services following publication of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with any amended terms, you may request closure of your phwn Account as provided under the phwn Terms and Conditions.

phwn recommends reviewing this Privacy Policy periodically. Previous versions of this Policy are available from phwn's support team upon written request.

Contact Us and Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or phwn's personal data processing practices, please contact us through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the phwn platform. This is the fastest route to immediate assistance for account-related privacy matters.
• Email: [email protected] — for written data subject rights requests or detailed privacy inquiries (plain text only; not a clickable link).

When submitting a data subject rights request by email, please include your registered phwn username, the specific right you wish to exercise, and sufficient information to allow phwn to identify your account and verify your identity before processing the request.

You also retain the right to submit a complaint directly to the National Privacy Commission of the Philippines (NPC) if you believe phwn has failed to comply with its obligations under the Data Privacy Act of 2012.