phwing Privacy Policy

01 Introduction

phwing is committed to protecting the privacy and personal data of all players who use our platform. This Privacy Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

This Policy applies to all personal data collected by phwing through the phwing.net website, mobile browser experience, and any related services, communications, or interactions you have with phwing. It covers data collected during registration, account use, financial transactions, customer support interactions, and general platform browsing.

phwing acts as the Personal Information Controller in respect of the personal data described in this Policy. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data privacy laws. Contact details for our DPO are provided in Section 14.

02 Personal Data We Collect

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

Identity & Contact Information:

• Full legal name as it appears on a government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Residential address, including city (e.g., Manila, Cebu, Davao, Quezon City, Makati)
• Email address and mobile phone number
• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys national ID, driver's license)

Financial Information:

• GCash or PayMaya (Maya) account details used for deposits and withdrawals
• BDO, BPI, or Metrobank bank account details where applicable
• Transaction history, including deposit amounts, withdrawal requests, and bet records
• Source of funds documentation where required for anti-money laundering compliance

Technical & Usage Data:

• IP address and approximate geolocation data
• Device type, operating system, and browser information
• Pages visited, games played, session duration, and click-stream data
• Login timestamps and access logs

Communications Data:

• Records of customer support interactions, including chat transcripts and email correspondence
• Feedback, complaints, and dispute records
• Marketing preferences and communication opt-in or opt-out records

03 How We Collect Your Data

phwing collects personal data through the following means:

• Direct collection: Information you provide when registering a phwing 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 and interact with the phwing platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from third-party KYC (Know Your Customer) service providers; fraud prevention data from anti-fraud partners; payment transaction data from e-wallet and banking partners such as GCash, PayMaya, BDO, BPI, and Metrobank.
• Publicly available sources: Publicly accessible information used to verify identity or comply with legal obligations, such as government databases or court records where permitted by Philippine law.

04 How We Use Your Personal Data

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

• To create, verify, and manage your phwing account, including age verification to enforce the 21+ requirement.
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP).
• To provide, maintain, and improve the phwing platform, including games, features, and customer support services.
• To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, gaming regulations, and tax reporting requirements.
• To detect, investigate, and prevent fraud, cheating, collusion, money laundering, and other prohibited activities on the phwing platform.
• To send you transactional communications, such as deposit confirmations, withdrawal notifications, and account security alerts.
• To send you marketing communications about phwing promotions, bonuses, and new features — but only where you have provided your consent or where we have a legitimate interest to do so, and subject always to your right to opt out.
• To personalize your phwing experience and provide game recommendations based on your activity.
• To conduct analytics and research to understand how players use phwing and to improve our services.
• To enforce our Terms & Conditions and other phwing policies.

05 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 required to perform our contract with you — i.e., to operate your phwing account, process transactions, and deliver gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, gaming licensing requirements, and tax obligations.
• Legitimate interests: Processing necessary for phwing's legitimate business interests, such as fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and certain non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

06 Sharing Your Personal Data

phwing does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors and e-wallet providers: GCash, PayMaya, BDO, BPI, Metrobank, and other payment partners, solely to process your financial transactions.
• Identity verification providers: Third-party KYC service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention and security partners: Service providers that assist phwing in detecting and preventing fraud, money laundering, and other prohibited activities.
• Technology and infrastructure providers: Cloud hosting, data storage, and IT service providers who process data on phwing's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Philippine government agencies, regulators, and law enforcement bodies where disclosure is required by law, court order, or regulatory obligation — including the Anti-Money Laundering Council (AMLC) and the National Privacy Commission (NPC).
• Professional advisers: Lawyers, auditors, and accountants where necessary for phwing's legal and compliance obligations, subject to professional confidentiality obligations.

All third parties with whom phwing shares personal data are required to handle that data in accordance with applicable Philippine data privacy laws and phwing's data protection standards.

07 Cookies & Tracking Technologies

phwing 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 phwing.net. We use the following types of cookies:

• Strictly necessary cookies: Essential for the phwing platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and display options, to provide a more personalized phwing experience.
• Analytics cookies: Help phwing understand how players use the platform — which games are most popular, where players encounter issues, and how navigation flows can be improved. Data collected is aggregated and anonymized where possible.
• Marketing cookies: Used only with your consent to deliver relevant phwing promotions and to measure the effectiveness of our marketing campaigns. These do not track you across unrelated third-party websites.

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 service delivery.

08 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and phwing's servers.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Strict access controls ensuring that only authorized phwing personnel can access personal data, on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the phwing platform.
• Multi-factor authentication requirements for phwing staff accessing systems that process personal data.
• Incident response procedures to detect, contain, and report 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 responsible for maintaining the confidentiality of your phwing account credentials and for notifying us immediately if you suspect any unauthorized access to your account.

09 Data Retention

phwing retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required or permitted by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your phwing account and for a minimum of five (5) years after account closure, in compliance with AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Customer support records: Retained for three (3) years from the date of the interaction, or longer if the matter is subject to ongoing legal proceedings.
• Marketing preferences: Retained until you withdraw your consent or opt out of marketing communications.
• Technical and usage logs: Retained for up to twelve (12) months for security and analytics purposes, after which they are deleted or anonymized.

Upon expiry of the applicable retention period, phwing will securely delete or anonymize your personal data in accordance with our data disposal procedures.

10 Your Data Subject Rights

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

• Right to be informed: The right to be informed of how your personal data is being collected and processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data phwing holds about you and information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data phwing holds about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, 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 where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe phwing has violated your data privacy rights.

To exercise any of these rights, please contact phwing's Data Protection Officer using the contact details provided in Section 14. phwing will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with NPC guidelines.

11 Children's Privacy

phwing's platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. phwing does not knowingly collect personal data from individuals under the age of 21.

If phwing becomes aware that personal data has been collected from a person under 21 years of age, 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 the details provided in Section 14 so we can take appropriate action.

12 International Data Transfers

phwing primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or technology partners operating in other jurisdictions.

Where such transfers occur, phwing ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Philippine Data Privacy Act. These safeguards may include contractual data protection clauses, adequacy assessments, or other mechanisms recognized by the National Privacy Commission.

By using phwing, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the purposes described in this Policy, subject always to the safeguards described above.

13 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 processing practices, applicable Philippine law, or NPC guidance. The most current version of this Policy will always be available on this page, with the "Last Updated" date revised accordingly.

For material changes to this Policy, phwing will make reasonable efforts to notify registered players via email or in-platform notification at least 7 days before the changes take effect. Your continued use of phwing after the effective date of any amendment constitutes your acknowledgment of the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how phwing is protecting your personal data.

14 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by phwing, please contact our Data Protection Officer (DPO). Our DPO is responsible for ensuring phwing's compliance with the Philippine Data Privacy Act and for handling all data subject rights requests.

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