69phwin Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 69phwin ("we," "us," or "our") collects, uses, stores, and discloses personal information about individuals ("you" or "Player") who access or use the 69phwin website, mobile platform, games, and all related services (collectively, the "Platform").

69phwin is committed to protecting the privacy and personal data of all players, in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations. This Policy is designed to help you understand what information we collect and how we handle it responsibly.

By registering an account on 69phwin, accessing the Platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the 69phwin Platform.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, which are incorporated herein by reference.

2 Data Controller

For the purposes of applicable Philippine data protection law, 69phwin is the data controller responsible for your personal information collected through the Platform. As data controller, 69phwin determines the purposes and means of processing your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

69phwin operates in compliance with applicable Philippine gaming regulations and takes its obligations as a data controller seriously. We have implemented appropriate technical and organizational measures to ensure that personal data is processed lawfully, fairly, and transparently.

3 Data We Collect

69phwin collects the following categories of personal data from players. We only collect data that is necessary for the purposes described in this Policy:

69phwin does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by applicable law or regulation (for example, problem gambling self-declaration for responsible gaming purposes).

4 How We Collect Data

69phwin collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and similar tracking technologies. See Section 8 for more details on our cookie practices.
• Third-Party Sources: Identity verification data from KYC service providers; fraud screening data from fraud prevention partners; payment data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank; and publicly available information used for compliance purposes.
• Regulatory Sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with our compliance obligations, including self-exclusion register data.

All data collection by 69phwin is conducted in accordance with applicable Philippine law. We do not purchase personal data from data brokers or other third-party commercial data sources for marketing purposes.

5 How We Use Your Data

69phwin uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 69phwin account, including verifying your identity and age (21+ requirement) in compliance with Philippine gaming regulations.
• Platform Operation: To provide you with access to games, process your wagers, calculate and pay out winnings, and deliver all features of the 69phwin Platform.
• Payment Processing: To process deposits and withdrawals via your chosen payment method, including GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our live chat and email support channels.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce deposit and loss limits you have set, and administer self-exclusion requests.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, money laundering, unauthorized account access, and other illegal activities.
• Legal Compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) regulations, gaming regulations, and data protection law.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the 69phwin Platform.
• 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.

69phwin will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

6 Legal Basis for Processing

69phwin processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its implementing rules:

• Contractual Necessity: Processing that is necessary to perform our contract with you — i.e., to operate your account, process transactions, and deliver the Platform services you have signed up for.
• Legal Obligation: Processing required to comply with our legal obligations under Philippine law, including AML regulations, gaming licensing requirements, and tax reporting obligations.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, security monitoring, and platform improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and optional personalization features. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Where 69phwin relies on legitimate interests as the legal basis for processing, we conduct a balancing test to ensure that our interests do not override your fundamental rights and freedoms. You may request information about any such balancing test by contacting our Data Protection Officer.

7 Data Sharing & Disclosure

69phwin 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, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: KYC and AML compliance service providers who assist us in verifying your identity and screening for fraud and financial crime.
• Game Providers: Third-party game studios and software providers whose games are available on the 69phwin Platform, to the extent necessary to operate those games and resolve disputes.
• Regulatory Authorities: PAGCOR and other Philippine government agencies, where disclosure is required by law, court order, or regulatory directive.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required in connection with the investigation or prosecution of criminal activity, including money laundering or fraud.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Professional Advisors: Legal, accounting, and auditing firms, subject to professional confidentiality obligations.

All third parties with whom 69phwin shares personal data are required to handle that data in accordance with applicable Philippine data protection law and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

In the event of a merger, acquisition, or sale of all or part of 69phwin's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

8 Cookies & Tracking

69phwin uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and game display options, to provide a more personalized experience.
• Analytics Cookies: Help us understand how players use the Platform — which pages are visited most, where players encounter issues, and how we can improve the overall experience. Data collected is aggregated and anonymized where possible.
• Marketing Cookies: Used to deliver relevant promotional content within the 69phwin Platform. We do not use third-party advertising networks that track you across other websites.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 69phwin Platform. For strictly necessary cookies, no opt-out is available as they are required for the Platform to operate.

69phwin does not use cross-site tracking technologies to follow your activity on other websites or applications outside of the 69phwin Platform.

9 Data Retention

69phwin retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AML and gaming regulatory requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• KYC / Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, or longer if the matter is subject to ongoing dispute or legal proceedings.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, as evidence of compliance.
• Technical & Usage Data: Retained for up to twenty-four (24) months, after which it is aggregated or anonymized for analytical purposes.

When personal data is no longer required for any of the above purposes, 69phwin will securely delete or anonymize it in accordance with our data disposal procedures. Where deletion is not immediately possible (for example, because data is stored in backup archives), we will isolate the data from further processing until deletion is feasible.

10 Your Rights

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by 69phwin. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

69phwin will respond to all verified data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further sixty (60) days, in which case we will notify you of the extension and the reasons for it. We may need to verify your identity before processing your request to protect against unauthorized access to your data.

If you are not satisfied with how 69phwin has handled your personal data or responded to your rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11 Data Security

69phwin implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the 69phwin Platform is encrypted using 256-bit SSL/TLS encryption. Sensitive data at rest, including financial information and identity documents, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized 69phwin personnel and service providers on a strict need-to-know basis. All access is logged and regularly audited.
• Two-Factor Authentication: 69phwin supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Penetration Testing: The Platform undergoes regular security assessments and penetration testing by qualified cybersecurity professionals to identify and remediate vulnerabilities.
• Incident Response: 69phwin maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected players in accordance with applicable law.
• Staff Training: All 69phwin personnel who handle personal data receive regular data protection and security awareness training.

While 69phwin takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You also play an important role in keeping your data safe — please use a strong, unique password for your 69phwin account and never share your login credentials with anyone.

12 Children's Privacy

The 69phwin Platform is strictly intended for adults who are 21 years of age or older, in accordance with Philippine gaming regulations applicable to casino-style online gaming. 69phwin does not knowingly collect personal data from individuals under the age of 21.

As part of our account registration and KYC process, 69phwin verifies the age of all players. Any account found to belong to a person under the age of 21 will be immediately closed, all funds will be returned to the depositing payment method (less any winnings, which will be forfeited), and the matter may be reported to the relevant Philippine authorities.

If you are a parent or guardian and believe that a minor has registered an account on 69phwin or provided us with personal data, please contact us immediately at the details provided in Section 14. We will take prompt action to investigate and, where confirmed, delete the relevant data and close the account.

13 Changes to This Policy

69phwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or the features of the Platform. When we make material changes to this Policy, we will notify registered players by email and/or by posting a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent changes were made. We encourage you to review this Policy periodically to stay informed about how 69phwin protects your personal data.

Your continued use of the 69phwin Platform following the effective date of any amendment to this Policy constitutes your acceptance of the revised Policy. If you do not agree with the changes, you should stop using the Platform and may request account closure by contacting our support team.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 69phwin, please contact our Data Protection Officer: