26phwin Privacy Policy

1. Who We Are

This Privacy Policy is issued by 26phwin ("26phwin," "we," "us," or "our"), the operator of the online gaming platform accessible at https://26phwin.app and any associated subdomains or mobile interfaces (collectively, the "Platform"). 26phwin acts as the Personal Information Controller (PIC) in respect of the personal data it collects from users of the Platform, as defined under the Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") of the Philippines.

This Privacy Policy applies to all individuals who access or use the 26phwin Platform, including registered players, visitors, and any other persons whose personal data is processed by 26phwin in connection with the Platform. By using the Platform, 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.

2. Personal Data We Collect

26phwin collects the following categories of personal data from users of the Platform:

2.1 Identity and Contact Information

• Full legal name
• Date of birth
• Gender
• Nationality and country of residence
• Residential address (including barangay, city/municipality, province, and ZIP code)
• Email address
• Mobile phone number

2.2 Identity Verification (KYC) Documents

• Government-issued photo identification (e.g., Philippine passport, driver's license, SSS/GSIS ID, PhilSys National ID, Voter's ID, PRC ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Proof of payment method ownership (e.g., screenshots of GCash or Maya account, bank account details)
• Selfie or live photo for identity verification purposes

2.3 Financial Information

• GCash or PayMaya/Maya account details (mobile number associated with the account)
• Bank account details (bank name, account number, account name) for bank transfer transactions
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used

2.4 Gaming Activity Data

• Game history, including games played, bets placed, outcomes, and winnings
• Session data, including login times, session duration, and logout times
• Bonus and promotion usage history
• Responsible gaming tool usage (e.g., deposit limits set, self-exclusion requests)

2.5 Technical and Device Data

• IP address and approximate geolocation derived from IP address
• Device type, operating system, and browser type and version
• Unique device identifiers
• Cookie identifiers and similar tracking technology data
• Platform interaction data, including pages visited, links clicked, and features used

2.6 Communications Data

• Records of communications between you and 26phwin customer support, including chat transcripts, email correspondence, and call recordings (where applicable)
• Feedback, survey responses, and other voluntary submissions

3. How We Collect Your Data

26phwin collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in promotions, or otherwise interact with the Platform.
• Automatically: Through cookies, web beacons, pixel tags, and similar tracking technologies when you access and use the Platform. See Section 7 for more details on our use of cookies.
• From third parties: From identity verification service providers, payment processors (such as GCash, Maya, and partner banks), fraud prevention services, and regulatory authorities, where permitted by applicable law.

4. How We Use Your Personal Data

26phwin processes your personal data for the following purposes:

• Account management: To create, maintain, and manage your 26phwin player account, including verifying your identity and eligibility to use the Platform.
• Service delivery: To provide you with access to the games, features, and services available on the Platform, and to process your deposits and withdrawals.
• Legal and regulatory compliance: To comply with our obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable legislation. This includes conducting KYC verification, transaction monitoring, and reporting to regulatory authorities as required.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, loss limits, and self-exclusion.
• Customer support: To respond to your inquiries, complaints, and requests, and to provide technical assistance.
• Marketing and promotions: To send you information about 26phwin promotions, bonuses, and new features, where you have consented to receive such communications. You may opt out of marketing communications at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the Platform.
• Legal claims: To establish, exercise, or defend legal claims in connection with the Platform or your use thereof.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 26phwin processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary for the performance of the contract between you and 26phwin (i.e., the Terms and Conditions), including account management, service delivery, and payment processing.
• Legal obligation: Processing is necessary for compliance with a legal obligation to which 26phwin is subject, including KYC/AML obligations, PAGCOR regulatory requirements, and tax reporting.
• Legitimate interests: Processing is necessary for the legitimate interests of 26phwin, including fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and interests.
• Consent: For certain processing activities, such as marketing communications and non-essential cookies, 26phwin relies on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Data Sharing and Disclosure

26phwin 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 and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya/Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers who assist us in verifying your identity and screening against sanctions and watchlists.
• IT and platform service providers: Cloud hosting, data storage, cybersecurity, and analytics providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other Philippine government authorities, where disclosure is required by law or regulation.
• Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by 26phwin, subject to professional confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 26phwin's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

All third parties with whom 26phwin shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and 26phwin's data protection standards.

7. Cookies and Tracking Technologies

26phwin uses cookies and similar tracking technologies (such as web beacons and pixel tags) to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform.

7.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function correctly, including maintaining your login session and enabling secure transactions. These cannot be disabled.
• Performance and analytics cookies: Help us understand how users interact with the Platform, which pages are most visited, and where errors occur, so we can improve performance.
• Functional cookies: Remember your preferences (such as language settings and display preferences) to provide a more personalized experience.
• Marketing cookies: Used to deliver relevant promotional content and to measure the effectiveness of our marketing campaigns. These 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 Platform.

8. Data Retention

26phwin retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically, 26phwin retains:

• Account and KYC data: For a minimum of five (5) years from the date of account closure, in accordance with PAGCOR regulations and AMLA requirements.
• Transaction records: For a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• Customer support communications: For up to three (3) years from the date of the communication, or longer if relevant to an ongoing legal claim.
• Marketing consent records: For as long as you remain a registered user of the Platform, or until you withdraw your consent, whichever is earlier.

When personal data is no longer required, 26phwin will securely delete or anonymize it in accordance with our data retention and disposal procedures.

9. Data Security

26phwin implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 26phwin Platform.
• AES-256 encryption for personal data stored in our databases.
• Role-based access controls limiting access to personal data to authorized personnel only.
• Regular security assessments, penetration testing, and vulnerability scanning.
• Multi-factor authentication for administrative access to systems containing personal data.
• Staff training on data privacy and security obligations.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 26phwin will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 26phwin:

To exercise any of these rights, please contact our Data Protection Officer (DPO) using the contact details provided in Section 14. We will respond to your request within thirty (30) days of receipt. We may need to verify your identity before processing your request.

11. Children's Privacy

The 26phwin Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine law and PAGCOR regulations. 26phwin does not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a person under 21, we will immediately delete such data and close the associated account.

If you are a parent or guardian and believe that your child has provided personal data to 26phwin, please contact us immediately at the details provided in Section 14 so that we can take appropriate action.

12. International Data Transfers

26phwin primarily stores and processes 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 international KYC service providers). Where such transfers occur, 26phwin ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that impose data protection obligations equivalent to those required under Philippine law, in accordance with NPC guidelines on cross-border data transfers.

13. Updates to This Privacy Policy

26phwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered users via the email address associated with their account and/or by posting a prominent notice on the Platform. The revised Privacy Policy will take effect on the date specified in the notice.

We encourage you to review this Privacy Policy periodically to stay informed about how 26phwin protects your personal data. Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated policy.

14. Contact Us and Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or 26phwin's data processing practices, or if you wish to exercise any of your data privacy rights, please contact our Data Protection Officer (DPO):

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that your data privacy rights have been violated. The NPC can be reached through its official website at privacy.gov.ph.

🎗️ Responsible Gaming Reminder: Gambling is addictive. Know when to stop. 26phwin is strictly for players aged 21 years and older. Visit our Responsible Gaming page for tools and resources to help you play safely.