winna Privacy Policy

This Privacy Policy ("Policy") describes how winna ("winna," "we," "us," or "our"), the operator of the online gaming platform at winna.bid, collects, uses, stores, and protects the personal data of individuals ("you," "Player," or "User") who access or use the winna platform, including its website, mobile interface, games, and related services.

winna is committed to protecting the privacy and personal data of all Filipino players in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). By registering on or using the winna platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

winna collects the following categories of personal data from players:

Identity & Contact Data:

• Full legal name
• Date of birth (for age verification — must be 21 or older)
• Email address and mobile number
• Residential address (city, province, region within the Philippines)
• Government-issued ID details (e.g., Philippine passport, SSS ID, driver's license number)

Financial Data:

• GCash account details, PayMaya account details, or bank account information (BPI, BDO, Metrobank) used for deposits and withdrawals
• Transaction history, deposit amounts, withdrawal amounts, and account balances

Technical & Usage Data:

• IP address, device type, operating system, and browser type
• Login timestamps, session duration, and pages visited on the winna platform
• Game history, betting activity, and wagering patterns
• Cookies and similar tracking technologies (see Section 9)

Communications Data:

• Records of your communications with winna customer support via live chat or email
• Feedback, complaints, and survey responses submitted to winna

winna collects personal data through the following means:

• Direct collection: Information you provide when registering a winna account, completing identity verification, making deposits or withdrawals, or contacting customer support .
• Automated collection: Technical and usage data collected automatically when you access and interact with the winna platform, including through cookies, log files, and analytics tools.
• Third-party sources: Identity verification data from accredited KYC (Know Your Customer) service providers, and fraud prevention data from payment processors such as GCash and PayMaya.
• Public sources: Publicly available information used to verify your identity or comply with anti-money laundering obligations under Philippine law.

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

• Account management: To register, verify, and maintain your winna player account, including age verification to confirm you are 21 years of age or older.
• Service delivery: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank; to provide access to games and betting markets; and to deliver customer support.
• Legal and regulatory compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Philippine Data Privacy Act of 2012, and other applicable Philippine laws and regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other prohibited conduct on the winna platform.
• Responsible gaming: To monitor gaming activity and identify players who may be exhibiting signs of problem gambling, and to administer self-exclusion and deposit limit tools.
• Platform improvement: To analyze usage patterns, troubleshoot technical issues, and improve the features and performance of the winna platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided consent or where permitted by applicable law. You may opt out at any time.
• Dispute resolution: To investigate and resolve complaints, disputes, and legal claims involving your winna account.

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

• Contractual necessity: Processing is necessary to perform the contract between you and winna — specifically, to operate your player account and deliver the gaming services you have requested.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act of 2012.
• Legitimate interests: Processing is necessary for winna's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and non-essential cookies, winna relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

winna 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 only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Accredited KYC service providers engaged by winna to verify your identity and age in compliance with PAGCOR requirements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or court order.
• Technology service providers: Cloud hosting, cybersecurity, and analytics providers engaged by winna under strict data processing agreements that prohibit unauthorized use of your data.
• Professional advisers: Legal counsel, auditors, and compliance consultants engaged by winna, subject to professional confidentiality obligations.

All third parties with whom winna shares personal data are required to implement appropriate technical and organizational security measures and to process your data only in accordance with winna's instructions and applicable Philippine law.

winna retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Specific retention periods include:

• Account data: Retained for the duration of your active winna account, and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act (AMLA) and BSP regulations.
• Customer support communications: Retained for three (3) years from the date of the last interaction, or longer if required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your consent and for three (3) years thereafter as evidence of compliance.

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

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the winna platform.
• Encryption of sensitive data at rest, including financial information and government ID details.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the winna platform.
• Multi-factor authentication (MFA) for administrative access to winna's internal systems.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While winna takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your winna login credentials and for notifying us immediately at [email protected] if you suspect any unauthorized access to your account.

winna uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and deliver relevant content. The types of cookies we use include:

• Strictly necessary cookies: Essential for the operation of the winna platform, including maintaining your login session and enabling secure transactions. These cannot be disabled.
• Performance and analytics cookies: Used to collect anonymized data about how players use the winna platform, helping us identify areas for improvement.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalize your winna experience.
• Marketing cookies: Used to deliver relevant promotional content about winna games and offers. These are only set with your consent.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the winna platform. For more information on managing cookies in popular Philippine mobile browsers, refer to your device's browser help documentation.

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

• Right to be informed: The right to know what personal data winna collects about you and how it is used — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data winna holds about you.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data in your winna account.
• Right to erasure: The right to request deletion of your personal data, subject to winna's legal retention obligations under PAGCOR regulations and the AMLA.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe winna has violated your data privacy rights.

To exercise any of these rights, please contact winna's Data Protection Officer at [email protected]. winna will respond to all valid data rights requests within fifteen (15) business days, in accordance with NPC guidelines.

The winna platform is strictly intended for individuals aged 21 years and above, in compliance with PAGCOR regulations governing online gaming in the Philippines. winna does not knowingly collect personal data from individuals under the age of 21.

If winna becomes aware that personal data has been collected from an individual under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and report the matter to the relevant regulatory authorities as required. If you believe a minor has registered on the winna platform, please notify us immediately at [email protected].

winna 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 PAGCOR regulatory requirements. When we make material changes to this Policy, we will notify registered players via email or through a prominent notice on the winna platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this Policy. Your continued use of the winna platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. We encourage all players to review this Policy periodically to stay informed of how winna protects their personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by winna, please contact our Data Protection Officer (DPO):

• Email: [email protected]
• Live Chat: Available 24/7 via the winna platform
• Response Time: Within 2 hours during normal operating hours; data rights requests within 15 business days

If you are not satisfied with winna's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through their official channels.

For matters related to responsible gaming and player protection, please also visit our Responsible Gaming page.