Your privacy matters to us. This Privacy Policy explains exactly what personal data win100 collects, why we collect it, how we use and protect it, and what rights you have as a Filipino data subject under the Data Privacy Act of 2012.
win100 complies fully with Republic Act No. 10173 and the regulations of the National Privacy Commission (NPC).
Filipino data subjects have the right to access, correct, object to, erase, and port their personal data. win100 honours all these rights.
win100 never sells, rents, or trades your personal data to unaffiliated third parties for commercial marketing purposes.
Certain data disclosures to PAGCOR, AMLC, and other Philippine authorities are legally required — these are not voluntary and are explained in full below.
1.1 This Privacy Policy describes how win100 collects, uses, discloses, stores, and protects personal information obtained from players and visitors to the win100 Platform. It also describes the rights of data subjects under Philippine law and the procedures for exercising those rights.
1.2 win100 is a PAGCOR-licensed online gaming operator. Our collection and processing of personal data is driven by two primary requirements: (a) our legal and regulatory obligations as a licensed gaming operator in the Philippines, including PAGCOR licensing conditions, AMLA compliance, and PAGCOR's Know Your Customer (KYC) directives; and (b) our legitimate operational needs to provide a functional, secure, and personalised gaming experience to Filipino players.
1.3 This Privacy Policy should be read together with win100's Terms and Conditions. Capitalised terms not defined here have the meanings given in the Terms and Conditions.
2.1 For the purposes of the Data Privacy Act of 2012 and related regulations, win100 is the personal information controller in respect of all personal data collected through the win100 Platform.
2.2 win100's designated Data Protection Officer (DPO) is responsible for overseeing compliance with this Privacy Policy and with applicable data protection law. Players may contact the DPO with any privacy-related inquiry, request, or complaint using the contact details in Section 15 of this Policy.
2.3 win100 processes personal data in accordance with the general principles of data privacy under the DPA: transparency, legitimate purpose, and proportionality. We collect only the personal data that is necessary for the specified purposes described in this Policy.
3.1 win100 collects the following categories of personal data from players and platform visitors:
win100 collects personal data through the following means:
win100 processes personal data on the following legal bases under the Data Privacy Act of 2012:
| Legal Basis | Processing Activities Covered |
|---|---|
| Contractual necessity | Account registration, payment processing, game operation, withdrawal processing, customer support — all necessary to perform the contract between win100 and the player. |
| Legal obligation | KYC/AML identity verification, PAGCOR reporting, AMLC transaction monitoring and reporting, age verification — required by Philippine law and PAGCOR licensing conditions. |
| Legitimate interests | Fraud prevention, account security monitoring, platform analytics, responsible gaming monitoring, IT infrastructure management. |
| Consent | Marketing communications, personalised promotional offers, participation in optional surveys or feedback programmes. Consent is withdrawable at any time. |
| Vital interests / public interest | Disclosures to law enforcement or government agencies where required to prevent serious harm or in response to lawful orders. |
win100 uses the personal data we collect for the following purposes:
To create and maintain your win100 account; to authenticate your identity at login; to process deposits and withdrawals; to operate games and settle bets; to manage your win100 wallet balance; to communicate account-related information including transaction confirmations, security alerts, and service updates.
To conduct KYC identity verification as required by PAGCOR; to comply with Anti-Money Laundering Act obligations, including transaction monitoring, suspicious transaction reporting, and covered transaction reporting to AMLC; to verify that players meet the minimum age requirement of 21 years for casino-type games; to respond to lawful requests from PAGCOR, NPC, AMLC, BIR, and other Philippine government authorities.
To detect, investigate, and prevent fraud, account abuse, money laundering, multi-accounting, and other prohibited conduct described in our Terms and Conditions; to monitor for and respond to account security incidents; to maintain system and network security.
To monitor player activity for indicators of problem gambling behaviour; to enforce deposit limits, session limits, and self-exclusion restrictions set by or for the player; to fulfil win100's responsible gaming obligations under PAGCOR licensing conditions.
To respond to inquiries, complaints, and support requests; to process dispute resolution and escalations; to maintain records of support interactions for quality assurance and training purposes.
To send promotional offers, bonus notifications, and marketing communications to players who have opted in to receive them via SMS or email; to personalise the Platform experience based on game preferences and activity history; to administer loyalty programmes and promotional campaigns. Marketing communications may be opted out of at any time by contacting win100 support.
To analyse aggregated, anonymised usage data to improve Platform performance, game selection, user experience, and overall service quality. Individual players are not identifiable from aggregated analytics reports.
7.1 win100 does not sell, rent, or trade personal data to unaffiliated third parties for marketing or commercial purposes.
7.2 win100 shares personal data with third parties only in the following circumstances:
8.1 win100 uses cookies and similar tracking technologies (collectively "cookies") on the Platform. Cookies are small text files stored on your device when you visit a website. They help the Platform function correctly, improve performance, and enable certain features.
8.3 win100 does not use cookies for third-party advertising or behavioural tracking on external websites. win100 does not share cookie data with advertising networks.
8.4 You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the win100 Platform, including logging in and processing transactions.
9.1 win100 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the minimum retention periods required by Philippine law.
| Data Category | Retention Period | Legal Basis |
|---|---|---|
| Account registration data | Duration of account + 5 years post-closure | PAGCOR licensing; AMLA compliance |
| KYC identity documents | Duration of account + 5 years post-closure | AMLA (RA 9160 as amended); PAGCOR |
| Transaction records | 5 years from transaction date | AMLA; BIR; PAGCOR audit requirements |
| Game history & bet records | 3 years from activity date | PAGCOR licensing; dispute resolution |
| Customer support records | 3 years from last interaction | Legitimate interests; dispute resolution |
| Marketing consent records | Until consent withdrawn + 1 year | DPA consent record requirements |
| Technical / device logs | 12 months | Security and fraud prevention |
9.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents reconstruction of the original data.
9.3 Where a legal dispute, regulatory investigation, or government inquiry is pending, win100 may retain relevant data beyond the standard retention period until the matter is fully resolved.
10.1 win100 implements technical, organisational, and physical security measures designed to protect personal data against unauthorised access, disclosure, alteration, destruction, or accidental loss. These measures include:
10.2 Notwithstanding the above, no internet-based platform can guarantee absolute security. win100 strongly encourages players to protect their own account credentials, enable SMS two-factor authentication, and immediately report any suspected unauthorised account activity.
10.3 In the event of a personal data breach that is likely to adversely affect the rights and freedoms of data subjects, win100 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with NPC Circular 16-03.
Under the Data Privacy Act of 2012, Filipino data subjects have the following rights with respect to their personal data held by win100. To exercise any of these rights, please contact win100's Data Protection Officer using the contact details in Section 15.
The right to know whether win100 holds your personal data, and to receive a copy of this Privacy Policy explaining how it is processed.
The right to obtain a copy of your personal data held by win100, including information about its source, processing purposes, and recipients.
The right to have inaccurate or incomplete personal data corrected. Players may update certain profile information directly in their account settings.
The right to request deletion of personal data where it is no longer necessary, consent is withdrawn, or processing was unlawful — subject to overriding legal retention obligations.
The right to object to processing based on legitimate interests — including direct marketing. win100 will cease such processing unless compelling legitimate grounds exist.
The right to receive your personal data in a structured, commonly used, machine-readable format for transfer to another service provider.
The right to request that processing of your personal data be suspended pending resolution of a dispute about accuracy or lawfulness of processing.
The right to lodge a complaint with the National Privacy Commission (NPC) if you believe win100 has violated your data privacy rights under the DPA.
12.1 The win100 Platform is strictly for adults. win100 does not knowingly collect personal data from individuals under the age of eighteen (18). Casino-type gaming on win100 is additionally restricted to individuals who are at least twenty-one (21) years of age, as mandated by PAGCOR.
12.2 If win100 becomes aware that it has inadvertently collected personal data from a minor, win100 will immediately delete such data, close the associated account, and refund any deposits made (where the funds can be returned to their source), subject to applicable legal requirements.
12.3 If you believe a minor has registered an account on win100, please contact our support team immediately at [email protected] (plain text — not a clickable link).
13.1 win100 operates primarily within the Philippines. However, as a technology-based platform, certain service providers engaged by win100 — including cloud infrastructure, cybersecurity, and KYC verification providers — may be located outside the Philippines or process data on servers located in other countries.
13.2 Where personal data is transferred outside the Philippines, win100 ensures that such transfers are subject to appropriate safeguards, including contractual data processing agreements that require the recipient to provide a level of data protection equivalent to that required under Philippine law.
13.3 win100 will not transfer personal data to a country or jurisdiction that does not provide adequate data protection without first implementing appropriate safeguards, such as standard contractual clauses approved by the National Privacy Commission.
14.1 win100 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 shown at the top of this page.
14.2 Where changes are material — meaning they significantly affect the way win100 processes your personal data or your rights as a data subject — win100 will notify registered players via their registered mobile number or email address prior to the changes taking effect.
14.3 Your continued use of the win100 Platform after a revised Privacy Policy takes effect constitutes your acknowledgment of and agreement to the updated terms. If you do not agree with the revised Policy, you may close your account in accordance with the account termination procedure described in the Terms and Conditions.
15.1 For all privacy-related inquiries, data subject rights requests, or complaints regarding win100's handling of your personal data, please contact win100's Data Protection Officer:
15.2 If you are not satisfied with win100's response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC is the regulatory body responsible for enforcing the Data Privacy Act and its Implementing Rules and Regulations.
win100 is a PAGCOR-licensed, DPA-compliant platform that treats Filipino players' privacy with the same seriousness as their winnings. Your data is protected — your gaming experience is what we're focused on.
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