winph4 Privacy Policy

1 Introduction

1.1 winph4 ("winph4," "we," "us," "our") operates the online gaming platform accessible at winph4.app. In the course of providing our services to you, winph4 necessarily collects and processes certain personal data about you as a registered player or visitor to the platform.

1.2 This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, sharing, and protection of your personal data. It also describes the rights you have under Philippine law with respect to your personal information and how you can exercise those rights.

1.3 By registering for a winph4 account, accessing the winph4 platform, or otherwise providing your personal data to winph4, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

1.4 This Policy should be read alongside winph4's Terms & Conditions and Responsible Gaming Policy, which together govern your use of the winph4 platform.

2 Data Controller

2.1 For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, winph4 acts as the personal information controller in respect of the personal data it collects and processes in connection with the winph4 platform.

2.2 winph4 operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). As a PAGCOR-regulated operator, winph4 is subject to data handling requirements imposed by PAGCOR in addition to those under the Data Privacy Act.

2.3 If you have any questions about how winph4 handles your personal data, or if you wish to exercise any of your data subject rights, please contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3 Personal Data We Collect

3.1 winph4 collects the following categories of personal data from players and platform visitors:

3.2 winph4 does not collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly necessary for identity verification and regulatory compliance purposes. Where sensitive personal information is collected, winph4 applies heightened security and access controls.

4 How We Collect Your Data

4.1 winph4 collects personal data through the following means:

• Direct collection: Information you provide when registering for a winph4 account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and usage data collected automatically when you access the winph4 platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; payment data from GCash, Maya, and banking partners; fraud intelligence from security service providers;
• Regulatory sources: Information shared with winph4 by PAGCOR or other regulatory bodies in connection with compliance obligations.

5 How We Use Your Personal Data

5.1 winph4 uses your personal data for the following purposes:

• To create, verify, and manage your winph4 account;
• To process deposits and withdrawals through GCash, Maya, and Philippine bank transfers;
• To verify your identity and age in compliance with PAGCOR regulations and the Data Privacy Act;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To provide customer support and resolve disputes;
• To monitor gaming activity for responsible gaming purposes and to enforce self-exclusion requests;
• To send you transactional communications, including deposit confirmations, withdrawal notifications, and security alerts;
• To send you promotional communications about winph4 offers and new games, where you have consented to receive such communications;
• To improve and personalize the winph4 platform based on your usage patterns;
• To comply with our legal and regulatory obligations under Philippine law and PAGCOR requirements.

5.2 winph4 will not use your personal data for any purpose that is incompatible with the purposes described in this Policy without first obtaining your consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

6.1 winph4 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you (i.e., to operate your winph4 account and provide gaming services);
• Legal obligation: Processing required to comply with PAGCOR regulations, Anti-Money Laundering Act (AMLA) obligations, and other applicable Philippine laws;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Third Parties

7.1 winph4 may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC and identity verification providers: To verify your identity and age in compliance with PAGCOR requirements;
• Payment processors: GCash, Maya, and Philippine banking partners, solely for the purpose of processing your deposits and withdrawals;
• Game software providers: Third-party game studios whose games are available on the winph4 platform, limited to the data necessary to operate the games;
• Fraud prevention and security providers: To detect and prevent fraudulent activity, money laundering, and other prohibited conduct;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulation;
• Legal and professional advisors: Lawyers, auditors, and other professional advisors, subject to strict confidentiality obligations;
• IT and platform service providers: Cloud hosting, analytics, and customer support platform providers who process data on winph4's behalf under data processing agreements.

7.2 winph4 does not sell, rent, or trade your personal data to unaffiliated third parties for their own marketing or commercial purposes.

7.3 Where winph4 engages third-party processors, winph4 ensures that appropriate contractual safeguards are in place to protect your personal data and that processors are bound by obligations no less protective than those in this Policy.

8 Data Retention

8.1 winph4 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations.

8.2 The following general retention periods apply:

• Account and identity data: Retained for the duration of your winph4 account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements;
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act;
• Gaming history: Retained for a minimum of three (3) years from the date of the gaming session;
• Customer support communications: Retained for two (2) years from the date of the last communication;
• Marketing consent records: Retained until consent is withdrawn and for one (1) year thereafter as evidence of consent.

8.3 Upon expiry of the applicable retention period, winph4 will securely delete or anonymize your personal data in accordance with its data disposal procedures. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

9 Security Measures

9.1 winph4's security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the winph4 platform;
• SMS-based two-factor authentication (2FA) via your registered Philippine mobile number for all account logins;
• Encryption at rest for sensitive personal and financial data stored on winph4 servers;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Real-time fraud detection systems that monitor for unusual account activity and unauthorized access attempts;
• Regular security audits and penetration testing conducted by independent security professionals;
• Secure data disposal procedures for the destruction of personal data that is no longer required.

9.2 While winph4 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. winph4 cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, winph4 will notify you and the National Privacy Commission (NPC) in accordance with the Data Privacy Act's breach notification requirements.

9.3 You also play an important role in keeping your data secure. Please ensure you use a strong, unique password for your winph4 account, enable 2FA, and never share your login credentials with anyone.

10 Your Data Subject Rights

10.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by winph4:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy;
• Right of access: The right to request a copy of the personal data winph4 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to winph4's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe winph4 has violated your data privacy rights.

10.2 To exercise any of the above rights, please contact winph4's Data Protection Officer using the contact details in Section 14. winph4 will respond to all data subject requests within thirty (30) days of receipt, or within such extended period as permitted under the Data Privacy Act where the request is complex or numerous.

10.3 winph4 may need to verify your identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized persons. You will not be charged a fee for exercising your data subject rights unless your request is manifestly unfounded or excessive.

11 Cookies & Tracking Technologies

11.1 winph4 uses cookies and similar tracking technologies on the winph4 platform to enhance your experience, analyze platform usage, and support security functions. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the winph4 platform, including session management and security functions. These cannot be disabled;
• Functional cookies: Remember your preferences and settings to personalize your winph4 experience;
• Analytics cookies: Collect anonymized data about how players use the winph4 platform to help us improve performance and usability;
• Marketing cookies: Used to deliver relevant promotional content about winph4 offers, where you have consented to receive such communications.

11.2 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the winph4 platform. Strictly necessary cookies cannot be disabled as they are essential for platform operation.

11.3 winph4 does not use cookies to track your activity on third-party websites unrelated to the winph4 platform.

12 Minors & Age Restriction

12.1 If you are a parent or guardian and believe that a minor has provided personal data to winph4, please contact our Data Protection Officer immediately using the contact details in Section 14 so that appropriate action can be taken.

13 Changes to This Privacy Policy

13.1 winph4 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. The date of the most recent revision is always displayed at the top of this page.

13.2 Where changes to this Policy are material, winph4 will notify registered players via the email address or mobile number on file, or by displaying a prominent notice on the winph4 platform, at least fourteen (14) days before the changes take effect.

13.3 Your continued use of the winph4 platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the updated Policy, you must stop using the winph4 platform and may request account closure by contacting customer support.

14 Contact & Data Protection Officer

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or winph4's handling of your personal data, please contact our Data Protection Officer:

14.2 If you are not satisfied with winph4's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through its official government channels.