Privacy Policy

This Privacy Policy (hereinafter "Policy") describes how winph11 (hereinafter "winph11," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal data of individuals (hereinafter "you," "Player," or "Data Subject") who visit, register on, or use the winph11 online gaming platform available at winph11.co and its associated services (the "Platform").

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines (hereinafter "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). It is also informed by the requirements of Republic Act No. 9160, the Anti-Money Laundering Act (AMLA), and the regulations of the Philippine Amusement and Gaming Corporation (PAGCOR), which impose mandatory data collection and record-keeping obligations on winph11 as a licensed online gaming operator.

By accessing or using the winph11 Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read together with winph11's Terms and Conditions and Responsible Gaming Policy, both of which are published on this website.

For the purposes of the Data Privacy Act of 2012, winph11 acts as the personal information controller in respect of the data it collects directly from players through the Platform. winph11 operates the Platform under a valid PAGCOR license and is registered as a personal information controller with the National Privacy Commission of the Philippines in accordance with NPC regulations applicable to personal information controllers processing the personal data of a large number of individuals.

winph11's designated Data Protection Officer (DPO) is responsible for overseeing compliance with the DPA, this Policy, and all related data privacy obligations. Contact details for the DPO are provided in Section 14 of this Policy. Data subjects may direct any privacy-related inquiries, requests, or complaints to the DPO.

Where winph11 engages third-party service providers to process personal data on its behalf — including payment processors, game technology providers, and cloud infrastructure providers — those parties act as personal information processors under written data processing agreements that impose obligations consistent with the DPA.

winph11 collects personal data that is necessary, proportionate, and relevant to the purposes identified in this Policy. The categories of personal data we collect include:

winph11 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Performance of a Contract: Processing that is necessary to provide you with a winph11 account, allow you to deposit and withdraw funds, place wagers, and use all Platform features. This is the primary legal basis for most of winph11's data processing activities;
• Compliance with a Legal Obligation: Processing required by PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160 as amended), KYC regulatory requirements, the Data Privacy Act itself, and applicable PAGCOR circulars. winph11 has no discretion over processing required to meet these obligations;
• Legitimate Interests: Processing necessary for winph11's legitimate business interests where these are not overridden by the rights and interests of the data subject — including fraud detection, platform security monitoring, responsible gaming compliance monitoring, and internal analytics for product improvement;
• Consent: Where consent is the applicable basis (primarily for marketing communications and non-essential cookies), winph11 obtains your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

winph11 uses the personal data it collects for the following purposes:

• Account Registration and Management: Creating and maintaining your winph11 account, verifying your identity, communicating account-related information, and processing account closure requests;
• Identity Verification (KYC): Confirming that you meet the eligibility requirements to use the Platform (including age verification — 21+ as required by PAGCOR), complying with anti-money laundering regulations, and preventing fraudulent account activity;
• Transaction Processing: Facilitating deposits from and withdrawals to your GCash, PayMaya, or bank accounts; maintaining accurate financial records; and issuing transaction confirmations;
• Platform Services: Enabling your access to all winph11 game categories including casino, live dealer, slots, bingo, sports betting, fishing games, and sabong;
• Customer Support: Responding to your inquiries, resolving disputes, and maintaining records of our communications for quality assurance and compliance purposes;
• Responsible Gaming: Monitoring gaming activity to identify potential signs of problem gambling, enforcing deposit limits and session restrictions you have set, and administering self-exclusion requests;
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent transactions, unauthorized account access, collusion, money laundering, and other prohibited conduct;
• Regulatory Compliance: Meeting all reporting obligations to PAGCOR, the Anti-Money Laundering Council, the National Privacy Commission, and other competent Philippine authorities;
• Marketing Communications: Where you have consented, sending you promotional offers, bonus notifications, and updates about new game releases or platform features. You may opt out at any time;
• Platform Improvement: Analyzing aggregated and anonymized usage data to improve the Platform's functionality, game selection, and user experience.

winph11 does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. Your data is shared only in the following limited circumstances:

• Payment Processors: GCash (Mynt – Globe Fintech Innovations), PayMaya (PayMaya Philippines), BPI, BDO, Metrobank, UnionBank, and any other payment service provider integrated into the winph11 Cashier — strictly for the purpose of processing your deposit and withdrawal transactions;
• Game Technology Providers: Third-party game studios and live dealer platform providers whose games are offered on winph11, where game session data must be processed through their certified systems to determine game outcomes. These providers operate under data processing agreements and cannot use your data for independent purposes;
• KYC and Identity Verification Services: Third-party identity verification service providers engaged by winph11 to assist with KYC document verification, facial recognition matching, and address verification;
• IT Infrastructure and Security Providers: Cloud hosting, content delivery, cybersecurity, and data analytics providers who process data on winph11's behalf under binding data processing agreements;
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and law enforcement agencies where winph11 is legally required or compelled to disclose personal data. winph11 will notify affected data subjects of such disclosures where legally permissible;
• Professional Advisers: Lawyers, auditors, accountants, and other professional advisers, subject to confidentiality obligations, where necessary for the conduct of winph11's business.

winph11 retains your personal data for no longer than is necessary for the purposes for which it was collected, subject to the following retention principles and mandatory legal requirements:

• Active Accounts: All personal data associated with an active winph11 account is retained for the duration of the account relationship plus any mandatory regulatory retention period;
• Closed Accounts: Upon account closure, winph11 retains identity, transaction, and KYC records for a minimum of five (5) years in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act's prescribed retention period. Certain records relating to suspicious transaction reports (STRs) may be retained for longer as required by AMLC regulations;
• Inactive Accounts: Accounts with no login activity for twelve (12) consecutive months are classified as inactive. winph11 applies a data minimization review to inactive accounts, deleting non-essential data while retaining records required by law;
• Communications and Support Records: Customer support transcripts and correspondence are retained for three (3) years from the date of the interaction, except where the communication is relevant to an ongoing dispute or regulatory investigation;
• Marketing Consent Records: Records of your consent to, or withdrawal of consent from, marketing communications are retained for the duration of the account plus three (3) years;
• Technical Logs: Session logs, IP address records, and login history are retained for twelve (12) months for security and fraud prevention purposes, after which they are anonymized or deleted.

When personal data is no longer required and is not subject to a mandatory retention obligation, winph11 securely deletes or anonymizes it in accordance with industry-standard data destruction procedures.

winph11 implements organizational, technical, and physical security measures appropriate to the risks associated with processing the personal data of online gaming platform users, including sensitive personal information such as government IDs and financial data. These measures include:

• Encryption in Transit: All data transmitted between your device and winph11's servers is protected by TLS 1.2 or higher (SSL) encryption, indicated by the padlock symbol in your browser address bar;
• Encryption at Rest: Sensitive data stored in winph11's databases — including identity verification documents, financial account details, and personally identifiable information — is encrypted using AES-256 encryption;
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. winph11 staff are granted access to player data only to the minimum extent required to perform their authorized functions. All access is logged and regularly audited;
• Two-Factor Authentication: winph11's internal systems require multi-factor authentication for staff accessing data processing systems. Two-factor authentication is also offered to players for account security;
• Regular Security Audits: winph11 engages independent cybersecurity firms to conduct periodic penetration testing and vulnerability assessments of the Platform's infrastructure;
• Incident Response: winph11 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to data subjects, winph11 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and notify affected data subjects without undue delay, as required by the DPA.

winph11 uses cookies and similar tracking technologies to operate the Platform and improve the user experience. The following categories of cookies are used:

• Strictly Necessary Cookies: These are essential for the Platform to function and cannot be disabled. They include session authentication cookies (maintaining your logged-in state), security cookies (CSRF protection), and load-balancing cookies. No consent is required for strictly necessary cookies;
• Performance and Analytics Cookies: These cookies collect aggregated, anonymized information about how players use the Platform — pages visited, session duration, error encounters. This data helps winph11 improve Platform performance. These cookies are set only where you have consented;
• Functional Cookies: These remember preferences you have set on the Platform (such as language, display settings, and responsible gaming configurations) to provide a personalized experience across sessions.

winph11 does not deploy third-party advertising cookies, retargeting pixels, social media tracking scripts, or behavioral profiling cookies on the Platform. You can manage browser-based cookies through your browser settings at any time. Note that disabling strictly necessary cookies will prevent the Platform from functioning correctly.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by winph11. winph11 processes data subject rights requests within thirty (30) days of receipt, extendable by a further fifteen (15) days where necessary, with notification to you of any extension.

To exercise any of these rights, please contact winph11's Data Protection Officer at the contact details provided in Section 14. winph11 may require identity verification before processing a data subject rights request to ensure the security of your personal data. Certain rights are subject to limitations where processing is required by law or is necessary for winph11 to comply with its PAGCOR and AMLA obligations.

winph11 is an online gambling platform exclusively for adults. Under PAGCOR regulations and applicable Philippine law, players must be at least twenty-one (21) years of age to register and use the Platform. winph11 does not knowingly collect, solicit, or process the personal data of individuals under 21 years of age.

winph11 employs age verification as a mandatory part of the account registration and KYC process. Where winph11 becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, all data will be reviewed, and the account and associated funds will be handled in accordance with winph11's underage account policy and applicable PAGCOR guidelines.

If you have reason to believe that a minor has registered on winph11, please contact our Data Protection Officer immediately at the details in Section 14 so the matter can be investigated and resolved promptly.

winph11's primary data processing infrastructure is located within the Philippines. Where it is necessary to transfer personal data to a country or jurisdiction outside the Philippines — for example, to game technology providers with processing infrastructure in other jurisdictions, or to cloud service providers with globally distributed data centers — winph11 ensures that such transfers are made only to countries or organizations that provide an adequate level of data protection consistent with the requirements of the Data Privacy Act of 2012.

Mechanisms used by winph11 to legitimize cross-border data transfers include:

• Contractual clauses in Data Processing Agreements incorporating the NPC's standard data protection provisions;
• Transfers to countries that the National Privacy Commission has recognized as providing adequate protection;
• Binding corporate rules where applicable within corporate groups;
• Specific consent obtained from data subjects where permitted by the NPC as an appropriate transfer mechanism.

winph11 maintains a register of cross-border data transfers, reviewed annually by the Data Protection Officer to ensure ongoing compliance with NPC regulations and guidance.

winph11 reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, changes in applicable Philippine privacy law and NPC guidance, or changes arising from our PAGCOR licensing obligations. The effective date at the top of this document indicates when the current version was last revised.

Where changes to this Policy are material — meaning they significantly affect your rights or our obligations with respect to your personal data — winph11 will provide advance notice by email to your registered address and/or by a prominent notice on the Platform at least fourteen (14) days before the change takes effect.

Non-material changes (such as typographical corrections, formatting improvements, or clarifications that do not alter the substance of any provision) may be implemented without prior notice. Your continued use of the winph11 Platform after the effective date of any updated Policy constitutes your acknowledgment of the revised terms. You are encouraged to review this page periodically for the most current version.

If you have any questions, concerns, or requests regarding this Privacy Policy or winph11's data processing practices, you may contact us through the following channels:

winph11 endeavors to respond to all data subject rights requests and privacy inquiries within the timeframes prescribed by the DPA — generally within thirty (30) days of receipt, with extension where necessary with notice to you.

If you are not satisfied with winph11's response to your privacy inquiry or data subject rights request, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC). The NPC is the authority responsible for enforcing the Data Privacy Act of 2012 and can be reached through the NPC's official government channels.