windph Privacy Policy

1. Introduction

windph ("windph," "we," "us," or "our") operates the windph online casino and sports betting platform available at windph.app (the "windph Platform"). We are committed to protecting the privacy and personal data of every player who uses windph. This Privacy Policy describes how windph collects, uses, stores, shares, and protects your personal information when you access or use the windph Platform.

This Privacy Policy applies to all windph players, registered account holders, and visitors to the windph website, regardless of whether you are based in Manila, Cebu, Davao, Quezon City, Makati, or anywhere else in the Philippines. By registering a windph account or using any windph service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein.

windph acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players, as defined under the Philippine Data Privacy Act of 2012 (RA 10173).

2. Personal Data We Collect

windph collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued Philippine ID details (e.g., PhilSys ID, passport, driver's license number).
• Contact Data: Email address, Philippine mobile number, and residential address.
• Account Data: windph username, encrypted password, account preferences, and communication preferences.
• Financial Data: GCash account details, PayMaya account details, BPI/BDO/Metrobank account information (as applicable), transaction history, deposit and withdrawal records, and account balance information.
• Gaming Data: Game history, betting records, wagering activity, session duration, and responsible gaming tool settings (e.g., deposit limits, self-exclusion status).
• Technical Data: IP address, device type, browser type and version, operating system, time zone, and platform access logs.
• Usage Data: Information about how you navigate and interact with the windph Platform, including pages visited, features used, and session timestamps.
• Communications Data: Records of your communications with the windph support team, including support chat transcripts and email correspondence.

windph does not collect sensitive personal information beyond what is strictly necessary for identity verification, KYC compliance, and responsible gaming purposes. windph does not collect biometric data.

3. How windph Uses Your Personal Data

windph uses the personal data it collects for the following purposes:

1. Account Registration & Management: To create and manage your windph player account, verify your identity, and maintain accurate account records.
2. KYC & Age Verification: To verify that you meet the minimum age requirement of 21 years as required under PAGCOR guidelines, and to comply with applicable anti-money laundering (AML) obligations.
3. Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods in Philippine Peso.
4. Platform Operation: To provide, maintain, and improve the windph Platform, including games, sports betting, and all related features.
5. Customer Support: To respond to your enquiries, resolve disputes, and provide 24/7 Filipino-speaking support.
6. Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and administer deposit limits and session reminders.
7. Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the windph Platform.
8. Legal Compliance: To comply with applicable Philippine laws and regulations, including the Data Privacy Act of 2012, PAGCOR requirements, and AML obligations.
9. Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent to receive such communications. You may opt out at any time.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform the contract between you and windph (i.e., to operate your windph account and provide gaming services).
• Legal Obligation: Processing is necessary to comply with windph's legal obligations under Philippine law, including KYC, AML, and PAGCOR regulatory requirements.
• Legitimate Interests: Processing is necessary for windph's legitimate interests in operating a secure, compliant, and commercially viable gaming platform, provided those interests are not overridden by your data protection rights.
• Consent: For marketing communications and certain non-essential cookies, windph relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

windph does not sell your personal data to third parties. windph 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: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to the extent necessary to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and identity verification service providers engaged by windph to assist with age verification and AML compliance.
• Technology Service Providers: Cloud hosting, platform infrastructure, and cybersecurity service providers who process data on windph's behalf under strict data processing agreements.
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where windph is legally required to disclose information.
• Law Enforcement: Philippine law enforcement agencies, where windph is required or permitted by law to disclose information in connection with the investigation of criminal activity.

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

6. Cookies & Tracking Technologies

windph uses cookies and similar tracking technologies on the windph Platform to enhance your user experience, maintain your session, and analyze platform usage. The types of cookies windph uses include:

• Strictly Necessary Cookies: Essential for the windph Platform to function. These cookies enable core features such as windph Login session management and security. They cannot be disabled.
• Functional Cookies: Used to remember your preferences (e.g., language settings, display preferences) to provide a more personalized windph experience.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the windph Platform, helping windph improve its services. These cookies are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the windph Platform. windph does not use third-party advertising cookies or sell cookie data to advertisers.

7. Data Retention

windph retains your personal data for as long as your windph account is active and for a period thereafter as required by applicable Philippine law and regulatory obligations. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years as required under Philippine AML regulations.
• Gaming activity records are retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes.
• Support communications are retained for two (2) years following the resolution of the relevant enquiry.

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

8. Your Data Privacy Rights

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

• Right to Be Informed: The right to be informed about how windph collects and processes your personal data — which this Privacy Policy fulfils.
• Right of Access: The right to request a copy of the personal data windph 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 windph'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.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe windph has violated your data privacy rights.

To exercise any of these rights, please contact the windph Data Privacy Officer at [email protected]. windph will respond to all data privacy requests within 15 business days.

9. Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the windph Platform;
• Encryption of sensitive data at rest, including financial data and identity documents;
• Two-factor authentication (2FA) available for all windph player accounts;
• Regular security audits and vulnerability assessments of the windph Platform;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Staff training on data protection and information security obligations.

While windph takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, windph will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

10. Children's Privacy

The windph Platform is strictly intended for persons aged 21 years and older. windph does not knowingly collect personal data from persons under 21 years of age. If windph becomes aware that it has inadvertently collected personal data from a person under 21, windph will promptly delete that data and close the associated account.

If you believe that a person under 21 years of age has registered a windph account or provided personal data to windph, please notify us immediately at [email protected] so that we can take appropriate action.

11. Changes to This Privacy Policy

windph reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable Philippine law, regulatory requirements, or windph's data processing practices. When windph makes material changes to this Privacy Policy, we will notify registered players via email or a prominent notice on the windph Platform prior to the changes taking effect.

The date at the top of this Privacy Policy indicates when it was last updated. We encourage you to review this Privacy Policy periodically to stay informed about how windph protects your personal data. Your continued use of the windph Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms.

12. Contact Us

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

• Email: [email protected]
• Support Hours: 24/7 · Philippine Standard Time (GMT+8)
• Languages: English and Filipino
• Response Time: Within 15 business days for data privacy requests

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with windph's response to your data privacy concern.