win36 Privacy Policy

win36 operates the online casino and sports betting platform accessible at https://win36.vu (the "Platform"). For the purposes of applicable data protection law, win36 is the data controller responsible for personal data collected through the Platform. This Privacy Policy applies to all Players, registered users, and visitors who access or use any part of the win36 Platform.

win36 is committed to handling your personal information with care, transparency, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations, as overseen by the National Privacy Commission ("NPC") of the Philippines.

win36 collects only the personal data that is necessary to provide and maintain the Platform, comply with legal and regulatory obligations, and deliver a safe and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Identity Data: Full legal name, date of birth, nationality, and government-issued identification numbers (e.g., Philippine Passport number, Driver's License number, SSS/UMID number, Voter's ID number) collected during account registration and KYC verification.

2.2 Contact Data: Email address, Philippine mobile number, and residential or billing address. This data is used to communicate with you about your account, transactions, and promotions (where opted in).

2.3 Financial Data: GCash account reference numbers, Maya wallet identifiers, bank account names and partial account numbers, and cryptocurrency wallet addresses used for deposit and withdrawal transactions. win36 does not store full bank account numbers or card numbers.

2.4 Transaction Data: Records of all deposits, withdrawals, bonus claims, and bet history associated with your win36 account, including amounts in Philippine Peso, timestamps, and transaction reference numbers.

2.5 Technical Data: IP address, browser type and version, device type, operating system, screen resolution, session duration, pages visited, and referring URLs. This data is collected automatically when you access the Platform.

2.6 Behavioural Data: Game preferences, wagering patterns, session frequency, and responsible gaming tool usage. This data is used to improve the Platform experience and to fulfil win36's responsible gaming obligations.

2.7 Communications Data: Records of your interactions with win36 support, including live chat transcripts, email correspondence, and support ticket history.

win36 collects personal data through the following means:

• Direct Registration: Information you provide when creating your win36 account, completing KYC verification, or updating your profile.
• Platform Transactions: Data generated automatically when you make deposits, place bets, request withdrawals, or claim bonuses on win36.
• Automated Technical Collection: Cookies, web beacons, server logs, and similar technologies that record your interaction with the win36 Platform.
• Third-Party Payment Processors: Confirmation data from GCash, Maya, BPI, BDO, Metrobank, and other payment partners when you initiate a financial transaction.
• Identity Verification Providers: Information returned by third-party KYC and fraud prevention services used to verify the identity and eligibility of Players.
• Customer Support Interactions: Information you voluntarily provide when contacting the win36 support team.

win36 uses your personal data for the following purposes:

• Account Management: Creating, maintaining, and securing your win36 account; processing identity verification; and managing your PHP wallet balance.
• Service Delivery: Enabling you to play games, place bets, make deposits and withdrawals, and access all features of the win36 Platform.
• Legal and Regulatory Compliance: Fulfilling anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, age verification, and cooperation with PAGCOR, the NPC, and law enforcement authorities where legally required.
• Fraud Prevention and Security: Detecting and preventing fraudulent activity, unauthorized access, collusion, bonus abuse, and other prohibited conduct on the Platform.
• Responsible Gaming: Monitoring wagering patterns to identify potential problem gambling behavior and administering responsible gaming tools such as deposit limits, session reminders, and self-exclusion programs.
• Customer Support: Responding to your enquiries, resolving disputes, and improving the quality of win36's support services.
• Platform Improvement: Analysing aggregated and anonymised usage data to improve game offerings, payment flows, and the overall user experience on win36.
• Marketing Communications: Sending promotional offers, bonus notifications, and Platform updates to Players who have opted in to receive such communications. You may opt out at any time.

win36 processes your personal data on the following legal grounds under the Philippine Data Privacy Act:

• Contractual Necessity: Processing required to perform our obligations under the Terms and Conditions you accepted at registration, including account management, game access, and payment processing.
• Legal Obligation: Processing required to comply with applicable law, including AML regulations, KYC requirements, and regulatory reporting obligations.
• Legitimate Interests: Processing necessary for win36's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and business analytics, provided these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent, particularly for marketing communications and the use of non-essential cookies. You may withdraw consent at any time.

win36 does not sell, rent, or trade your personal data. We may share your information only in the following limited circumstances:

• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, and other payment service providers receive the minimum data necessary to process your transactions.
• KYC and Fraud Prevention Providers: Identity verification partners receive identity documents and personal details for the sole purpose of verifying Player eligibility and detecting fraud.
• Game Software Providers: Third-party game studios that power win36's slot and live casino content may receive anonymised session and wagering data as required for game operation and RTP certification.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities may receive data where win36 is legally compelled to disclose.
• Professional Advisers: Legal, audit, and compliance professionals bound by confidentiality obligations who assist win36 with legal and regulatory matters.
• Business Transfers: In the event of a merger, acquisition, or asset sale involving win36, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

All third-party service providers engaged by win36 are required to process your data only for the specified purpose and in accordance with contractual data processing obligations consistent with the DPA.

win36 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention principles apply:

• Active Accounts: Personal data associated with an active win36 account is retained for the duration of the account relationship.
• Closed Accounts: Following account closure, win36 retains identity, transaction, and communications data for a minimum of five (5) years to comply with AML record-keeping obligations and potential regulatory investigations.
• Technical Logs: Server logs and technical data are retained for up to twelve (12) months for security analysis and fraud detection purposes.
• Marketing Data: Where consent to marketing communications is withdrawn, your contact details will be removed from active marketing lists within thirty (30) days, subject to retention for suppression list purposes.

win36 uses cookies and similar technologies on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function correctly, including maintaining your login session, remembering your PHP wallet state, and enabling secure transactions. These cannot be disabled.
• Analytics Cookies: Used to understand how Players navigate and use the win36 Platform, enabling us to improve game lobby design, payment flows, and content. Analytics data is aggregated and anonymised where possible.
• Preference Cookies: Store your display preferences and settings to improve your experience across sessions.

Non-essential cookies are set only with your consent. You may manage cookie preferences through your browser settings at any time. Disabling certain cookies may affect the functionality of the win36 Platform.

win36 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and win36 servers.
• Encryption of sensitive data at rest within win36's database infrastructure.
• Role-based access controls limiting employee access to personal data strictly to those with a legitimate business need.
• Regular security assessments and penetration testing of the win36 Platform.
• Two-factor authentication options for Player accounts to prevent unauthorised access.
• Incident response procedures to detect, contain, and notify affected Players and the NPC of any personal data breach in accordance with DPA requirements.

While win36 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. Players are responsible for maintaining the confidentiality of their own account credentials.

Under the Philippine Data Privacy Act and as a win36 Player, you have the following rights with respect to your personal data:

• Right to be Informed: The right to be notified about how your personal data is collected and processed — which this Privacy Policy fulfils.
• Right of Access: The right to request a copy of the personal data win36 holds about you and information about how it is being used.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. You may update most of your account information directly from your win36 account settings.
• Right to Erasure: The right to request deletion of your personal data where win36 no longer has a lawful basis to retain it. This right is subject to win36's legal obligations to retain certain records.
• Right to Data Portability: The right to receive a structured, machine-readable copy of the personal data you provided to win36 for transmission to another service.
• Right to Object: The right to object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: The right to file a complaint with the Philippine National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, contact win36's Data Protection Officer at [email protected]. win36 will respond to verifiable requests within fifteen (15) calendar days as required under the DPA.

win36 is strictly an adult platform. We do not knowingly collect personal data from individuals under the age of 21. The Platform employs age verification measures at registration and KYC stages to prevent underage access. If win36 becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended, associated data will be deleted or anonymised, and the matter will be referred to relevant authorities where required.

If you are a parent or guardian and believe your child has accessed win36, please contact us immediately at [email protected].

win36 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform functionality. Material changes will be communicated to registered Players via email to the address on file and through a prominent notice on the win36 Platform at least seven (7) days before taking effect.

The "Last Updated" date at the top of this page indicates when the current version took effect. Continued use of win36 following notification of changes constitutes your acceptance of the revised Privacy Policy.

For any questions, concerns, or requests relating to this Privacy Policy or win36's data processing practices, please contact our Data Protection Officer: