ph2win Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by ph2win ("ph2win," "we," "us," or "our"), the operator of the online gaming platform accessible at ph2win.net and any associated subdomains (collectively, the "Platform"). This Policy describes how ph2win collects, uses, stores, shares, and protects the personal information of users ("Players," "you," or "your") who access or register on the Platform.

ph2win is committed to handling your personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Republic of the Philippines and its Implementing Rules and Regulations, as well as applicable guidelines issued by the National Privacy Commission (NPC) of the Philippines. ph2win also complies with personal data handling requirements imposed by the Philippine Amusement and Gaming Corporation (PAGCOR) as part of its regulatory framework.

By registering on or using the ph2win Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing, and use of your personal data as described herein. If you do not agree with any part of this Policy, you should not register on or use the ph2win Platform.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, ph2win is the Personal Information Controller (PIC) responsible for the personal data of players on the Platform. ph2win determines the purposes and means by which your personal data is processed and is accountable for ensuring that processing is carried out lawfully, fairly, and transparently.

ph2win has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data privacy laws and this Policy. Enquiries relating to personal data, including access requests and complaints, should be directed to ph2win's customer support at [email protected] (plain text — not a clickable link), and will be forwarded to the DPO where appropriate.

3 Personal Data We Collect

ph2win collects personal data that is necessary and proportionate to the purposes for which it is processed. The categories of personal data collected by ph2win include:

3.1 Registration Data

• Username chosen by the player
• Philippine mobile number (used for account authentication and OTP verification)
• Password (stored in hashed, non-reversible format — never in plain text)
• Date of birth (for age verification — must confirm 21+ years of age per PAGCOR requirements)

3.2 Identity Verification Data (KYC)

• Full legal name as it appears on a government-issued Philippine ID
• Copy of a valid government-issued Philippine ID (e.g., PhilSys ID, passport, SSS ID, UMID, driver's license, PRC ID)
• Proof of address (where required by PAGCOR or AML regulations)
• Selfie photograph (for liveness verification, where required)

3.3 Financial Data

• Deposit and withdrawal transaction records
• GCash or Maya account reference (mobile number used for wallet transactions)
• Bank account details (BPI, BDO, Metrobank, or other PH bank) where used for transactions
• Transaction amounts, dates, and payment method type

ph2win does not store full payment card numbers or complete GCash/Maya account credentials. Financial transactions are processed through certified payment service providers who maintain their own security standards.

3.4 Gameplay Data

• Game session history, including games played, bets placed, outcomes, and winnings
• Session duration and frequency data
• Bonus and promotion participation and usage records
• Responsible gaming tool settings (deposit limits, session alerts, self-exclusion status)

3.5 Technical and Device Data

• IP address at time of registration and subsequent logins
• Device type, operating system, and browser type
• Session timestamps and login history
• Geolocation data (country/region level, derived from IP address)
• Cookie and tracking data as described in Section 11

3.6 Communications Data

• Records of customer support communications (email, chat)
• Feedback, complaints, and dispute records
• Marketing preference settings and communication opt-in/out records

4 How We Collect Personal Data

ph2win collects personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions.
• Automatically: Through cookies, web server logs, and tracking technologies when you access and interact with the ph2win Platform.
• From payment providers: When you initiate a GCash, Maya, or bank transaction, ph2win receives transaction confirmation data from the relevant payment service provider.
• From identity verification services: When KYC verification is conducted, ph2win may use third-party identity verification providers who process your identity document data on ph2win's behalf.
• From game providers: Game providers integrated on the ph2win Platform may share game session data with ph2win for the purpose of account management and dispute resolution.

5 Purposes of Processing

ph2win processes your personal data for the following specific purposes:

6 Legal Bases for Processing

ph2win processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the ph2win Player Agreement, including providing account access, processing transactions, and delivering gameplay services.
• Legal obligation: Processing required to comply with PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, security, responsible gaming enforcement, and platform analytics, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and optional data uses where ph2win has obtained your express consent. You may withdraw consent at any time without affecting the legality of prior processing.

7 Data Sharing and Disclosure

ph2win does not sell, rent, or trade your personal data to any third party for commercial purposes. Your personal data may be shared only in the following circumstances and only to the extent necessary for the stated purpose:

7.1 Regulatory and Law Enforcement Authorities

ph2win is required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies upon lawful request or where disclosure is mandated by Philippine law. ph2win will not resist or obstruct lawful regulatory requests.

7.2 Payment Service Providers

To process deposits and withdrawals, ph2win shares necessary transaction data with payment service providers including GCash, Maya, BPI, BDO, Metrobank, and other processors listed on the ph2win Platform. These providers act as Personal Information Processors (PIPs) under the Data Privacy Act and are bound by data processing agreements with ph2win.

7.3 Game Providers

Game providers integrated on the ph2win Platform (including JILI, PG Soft, Pragmatic Play, and others) receive the minimum data necessary to deliver their games to your account. Game providers are separately licensed entities and maintain their own privacy practices for data processed within their game environments.

7.4 Identity Verification Providers

Where ph2win uses third-party KYC verification services to confirm your identity and age, your identity document data is shared with such providers solely for the purpose of verification. These providers are bound by data processing agreements requiring them to handle your data securely and confidentially.

7.5 Legal Proceedings

ph2win may disclose personal data where required by a valid court order, legal process, or where disclosure is necessary to protect the rights, property, or safety of ph2win, its players, or the public.

8 International Data Transfers

ph2win is a Philippines-focused platform and processes the majority of player data within the Philippines or through service providers operating in jurisdictions with adequate data protection standards. Where personal data is transferred outside the Philippines — for example, to international game providers or cloud infrastructure providers — ph2win ensures that such transfers are:

• Made only to countries, organizations, or entities that provide adequate levels of protection for personal data as recognized by the National Privacy Commission;
• Governed by appropriate data processing agreements incorporating standard contractual protections;
• Limited to the minimum data necessary for the stated processing purpose;
• Subject to the same security standards applied to data processed within the Philippines.

ph2win does not transfer your financial data or KYC identity documents to entities outside the Philippines except where strictly required by the applicable payment processor or regulatory authority.

9 Data Retention

ph2win retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Specific retention periods include:

• Active account data: Retained for the duration of your ph2win account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• KYC and identity documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, as required under the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support records: Retained for three (3) years from the date of the most recent communication, or longer where a dispute or legal matter is ongoing.
• Marketing consent records: Retained until you withdraw consent and for a reasonable period thereafter to evidence that consent was properly obtained.
• Technical and log data: Retained for up to twelve (12) months for security, fraud prevention, and platform debugging purposes.

Upon expiry of the applicable retention period, ph2win will securely destroy or permanently anonymize your personal data in accordance with its data destruction procedures.

10 Security Measures

ph2win implements a range of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your device and ph2win servers is encrypted using current SSL/TLS protocols.
• Password hashing: Account passwords are stored exclusively as cryptographic hashes using industry-standard algorithms. Plain-text passwords are never stored or accessible by ph2win staff.
• Access controls: Personal data is accessible only to ph2win personnel and service providers who have a legitimate need to access it for the stated purposes. Access is governed by role-based permissions and is logged.
• OTP authentication: Sensitive account actions, including registration and certain account changes, require OTP verification to your registered Philippine mobile number.
• Session security: Inactive sessions are automatically terminated after a defined period to prevent unauthorized access from unattended devices.
• Secure infrastructure: ph2win's platform is hosted on infrastructure with physical and network-level security controls, including firewalls, intrusion detection, and DDoS mitigation.
• Regular security reviews: ph2win conducts periodic security assessments and vulnerability reviews of its platform and data handling practices.

11 Cookies and Tracking Technologies

ph2win uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file stored on your device by your web browser when you visit ph2win. ph2win uses the following categories of cookies:

11.1 Strictly Necessary Cookies

These cookies are essential for the ph2win Platform to function. They enable core features such as account authentication, session management, and security protections. These cookies cannot be disabled without affecting Platform functionality.

11.2 Functional Cookies

Functional cookies remember your preferences — such as your chosen language, display settings, and game lobby configuration — so you don't need to re-enter them on each visit to ph2win.

11.3 Analytics Cookies

ph2win uses analytics tools to understand how players interact with the Platform, which features are most used, and where technical issues occur. Analytics data is aggregated and used only to improve the ph2win Platform. ph2win does not share identifiable analytics data with third-party advertising platforms.

11.4 Cookie Management

You can manage or delete cookies through your browser settings. Deleting or disabling strictly necessary cookies will impair your ability to log in to and use the ph2win Platform. Disabling analytics cookies will not affect your ability to play but will limit ph2win's ability to improve the Platform based on usage data.

12 Your Data Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph2win:

To exercise any of the above rights, please contact ph2win customer support at [email protected] (plain text — not a clickable link). ph2win will respond to data rights requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. Where ph2win is unable to fulfil a request due to legal retention obligations, we will provide a clear explanation.

If you are not satisfied with ph2win's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph (for reference only — not a clickable link from this page).

13 Minors – Under 21 Years of Age

The ph2win Platform is strictly for persons aged 21 years or older, in accordance with the minimum age requirement mandated by PAGCOR. ph2win does not knowingly collect personal data from persons under 21 years of age.

If ph2win discovers or has reason to believe that personal data has been collected from a person under 21 years of age, ph2win will immediately suspend the relevant account, delete the associated personal data without undue delay, and report the matter to PAGCOR where required.

14 Changes to This Privacy Policy

ph2win reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable law, PAGCOR requirements, ph2win's data practices, or the services offered on the Platform. Material changes to this Policy will be communicated to registered players by notification on the ph2win Platform and/or by SMS to the registered mobile number, at least seven (7) days before the changes take effect where reasonably practicable.

The date of the most recent update to this Policy is displayed at the top of this page. We encourage you to review this page periodically to stay informed about how ph2win protects your personal information. Your continued use of the ph2win Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the revised terms.

15 Contact – Data Privacy Enquiries

For all enquiries, requests, and complaints relating to this Privacy Policy or the processing of your personal data by ph2win, please contact:

• Data Protection Officer, ph2win
• Email: [email protected] (plain text — not a clickable link) — Subject line: "DATA PRIVACY ENQUIRY"
• Support Hours: 8:00 AM – 11:00 PM Philippine Standard Time (PST), 7 days a week
• Response Time: ph2win acknowledges data privacy enquiries within 3 business days and responds substantively within 15 business days.

For responsible gaming concerns, self-exclusion requests, or account restriction queries, please visit our Responsible Gaming page or contact support directly. For general terms of service questions, please review the Terms & Conditions page.