phwing Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how phwing ("phwing," "we," "us," "our") collects, processes, stores, and protects the personal information of users ("you," "Player," "User") who access or use the phwing online gaming platform at phwing.app (the "Platform").

phwing is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all other applicable Philippine laws and regulations governing data protection and privacy.

By registering an account on phwing or otherwise using the 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. If you do not agree with this Policy, you must not use the phwing Platform.

This Policy should be read together with the phwing Terms & Conditions, which govern your use of the Platform generally.

02 Personal Data We Collect

phwing collects personal data that you provide directly to us, data generated through your use of the Platform, and data received from third parties in connection with our compliance and operational obligations. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (for age verification — you must be 21 or older to use phwing);
• Residential address, including barangay, city or municipality, province, and postal code;
• Email address and mobile phone number;
• Username and encrypted password.

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID);
• Proof of address documents (e.g., utility bills, bank statements);
• Selfie or facial image for identity verification purposes, where required.

2.3 Financial Data

• GCash or PayMaya account details (mobile number associated with the account);
• Bank account details for bank transfer transactions (account name, account number, bank name);
• Debit card details where applicable;
• Transaction history, including deposit and withdrawal records.

2.4 Gaming & Activity Data

• Game history, including games played, bets placed, outcomes, and winnings;
• Session data, including login times, session duration, and activity logs;
• Responsible gaming settings and self-exclusion records;
• Bonus and promotion participation history.

2.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Cookies and similar tracking technologies (see Section 6);
• Platform interaction data, including pages visited and features used.

2.6 Communications Data

• Records of your communications with phwing customer support;
• Feedback, complaints, and survey responses you submit to phwing.

03 How We Use Your Personal Data

phwing uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your phwing player account, including processing your registration and verifying your identity;
• Age Verification: To verify that you meet the minimum age requirement of 21 years as required under Philippine gaming regulations;
• KYC & AML Compliance: To fulfill our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under Philippine law, including verifying the source of funds where required;
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, bank transfer, and other accepted payment methods in Philippine Peso;
• Game Provision: To provide access to phwing's games, track game outcomes, and maintain accurate records of your gaming activity;
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools including deposit limits, session limits, and self-exclusion;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats;
• Legal Compliance: To comply with applicable Philippine laws, regulations, and regulatory requirements, including those of PAGCOR and the National Privacy Commission;
• Platform Improvement: To analyze usage patterns and improve the phwing Platform's features, performance, and user experience;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.

04 Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary for the performance of the contract between you and phwing (i.e., the Terms & Conditions), including account management, payment processing, and game provision;
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including KYC, AML, and gaming regulatory requirements;
• Legitimate Interests: Processing is necessary for phwing's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and interests;
• Consent: For marketing communications and certain non-essential cookies, processing is based on your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing carried out before withdrawal.

05 Data Sharing & Disclosure

phwing does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and AML service providers who assist phwing in verifying player identities and screening for financial crime risks;
• Game Software Providers: Licensed game developers and studios whose games are available on the phwing Platform, to the extent necessary to provide game services;
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on phwing's behalf under strict data processing agreements;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or regulation;
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other legal process;
• Professional Advisors: Legal counsel, auditors, and other professional advisors, subject to confidentiality obligations.

06 Cookies & Tracking Technologies

phwing uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function, including session management, login authentication, and security. These cannot be disabled;
• Functional Cookies: Remember your preferences and settings (e.g., language, responsible gaming limits) to improve your experience;
• Analytics Cookies: Help us understand how players use the Platform so we can improve its performance and features. Data collected is aggregated and anonymized where possible;
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the phwing Platform. For strictly necessary cookies, no consent is required as they are essential to the service.

07 Data Retention

phwing retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. Specific retention periods include:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by Philippine AML regulations;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with AMLC requirements;
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship;
• Customer Support Records: Retained for three (3) years from the date of the last interaction;
• Marketing Consent Records: Retained until you withdraw consent, plus a reasonable period thereafter for compliance purposes.

When personal data is no longer required, phwing will securely delete or anonymize it in accordance with our data disposal procedures.

08 Your Data Rights

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

• Right to Be Informed: The right to be informed about how your personal data is collected and processed, as set out in this Policy;
• Right of Access: The right to request a copy of the personal data phwing 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 phwing'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 format where technically feasible;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

09 Data Security

phwing implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the phwing Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Multi-factor authentication options for player accounts;
• Regular security audits and penetration testing by qualified cybersecurity professionals;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While phwing takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are also responsible for maintaining the security of your phwing account credentials. Please notify us immediately at [email protected] if you suspect any unauthorized access to your account.

10 Children's Privacy & Age Restriction

If phwing discovers or is notified that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe your child has registered on phwing, please contact us immediately at [email protected].

11 Third-Party Links

The phwing Platform may contain links to third-party websites or services for informational purposes. phwing is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Policy applies solely to personal data collected by phwing through the phwing Platform.

12 Changes to This Privacy Policy

phwing reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, we will notify registered players via email or through a prominent notice on the Platform. The "Last Updated" date at the top of this page will always reflect the date of the most recent revision.

Your continued use of the phwing Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with the changes, you must cease using the Platform and may request account closure in accordance with the phwing Terms & Conditions.

13 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact the phwing Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.