Privacy Policy
for 24phwin Players

24phwin is an online casino and sports betting platform operated at https://24phwin.org, serving Filipino players across the Philippines — from Manila and Makati to Cebu, Davao, and Quezon City. For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173), 24phwin acts as the Personal Information Controller in respect of the personal data you provide when using our platform.

This Privacy Policy applies to all personal data collected through the 24phwin website, mobile application, customer support channels, and any other touchpoints through which you interact with our platform. It should be read alongside our Terms & Conditions and Responsible Gaming policy.

24phwin collects the following categories of personal data from players and platform visitors:

We do not intentionally collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. We do not collect data relating to racial or ethnic origin, political opinions, religious beliefs, or health information unless directly relevant to a responsible gaming assessment you have requested.

24phwin collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the platform, including through cookies, web beacons, server logs, and similar tracking technologies (see Section 7).
• Third-party payment providers: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, and Metrobank when you process deposits or withdrawals.
• Identity verification partners: Data returned by our KYC and anti-fraud service providers when verifying your identity documents.
• Regulatory sources: Information received from PAGCOR or other competent authorities in connection with regulatory compliance obligations.

24phwin processes your personal data for the following specific purposes:

• Account registration and management: To create, maintain, and administer your 24phwin player account.
• Identity verification (KYC): To verify your identity, age (21+), and eligibility to use the platform in compliance with PAGCOR requirements.
• Transaction processing: To process deposits, withdrawals, and bonus credits accurately and securely via GCash, PayMaya, and Philippine bank transfers.
• Regulatory compliance: To meet our obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, and unauthorized account access.
• Customer support: To respond to your queries, complaints, and support requests efficiently and accurately.
• Responsible gaming: To monitor gaming patterns, enforce self-exclusion requests, and provide responsible gaming tools to players who may be at risk.
• Platform improvement: To analyze usage patterns and improve the performance, features, and user experience of the 24phwin platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have opted in to receive such communications. You may opt out at any time.

Under the Data Privacy Act of 2012, 24phwin processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your player account, process transactions, and deliver gaming services.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AMLA obligations, KYC requirements, and other applicable Philippine laws and regulations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and optional analytics features, where you have given explicit, freely withdrawable consent.

Where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

24phwin does not sell your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank, to process your financial transactions.
• KYC and identity verification providers: Third-party services that assist us in verifying your identity and age in compliance with PAGCOR requirements.
• Anti-fraud and security providers: Services that help us detect and prevent fraudulent activity, money laundering, and account compromise.
• Cloud infrastructure providers: Hosting and data storage providers who process data on our behalf under strict contractual data protection obligations.
• Customer support platforms: Tools used to manage live chat and support ticket communications.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or regulatory directive.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order or legal process.

All third-party service providers who process personal data on behalf of 24phwin are required to implement appropriate technical and organizational security measures and to process data only in accordance with our documented instructions.

24phwin uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyze usage patterns. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies and security tokens. They cannot be disabled without breaking core platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the platform, helping us identify areas for improvement. These are only set with your consent.
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the 24phwin platform. For analytics cookies, you may withdraw consent at any time through your account settings.

24phwin retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Active account data: Retained for the duration of your account relationship with 24phwin, plus a minimum of five (5) years following account closure, as required by AMLA and PAGCOR record-keeping obligations.
• KYC documents: Retained for a minimum of five (5) years from the date of verification, in compliance with AMLA requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support communications: Retained for three (3) years from the date of the last interaction, unless a longer period is required for an ongoing dispute or regulatory matter.
• Technical and usage logs: Retained for up to twelve (12) months for security and fraud prevention purposes, after which they are anonymized or deleted.
• Marketing consent records: Retained for the duration of your consent, plus three (3) years thereafter as evidence of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data destruction procedures.

24phwin 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:

• Transport Layer Security (TLS): All data transmitted between your device and 24phwin is encrypted using TLS 1.2 or higher.
• Encryption at rest: Sensitive personal data, including financial information and KYC documents, is encrypted at rest using AES-256 or equivalent standards.
• Access controls: Access to personal data is restricted to authorized 24phwin personnel and service providers on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Regular security audits: 24phwin conducts periodic security assessments, penetration testing, and vulnerability scans to identify and remediate potential weaknesses.
• Incident response: We maintain a documented data breach response procedure. In the event of a breach affecting your personal data, we will notify you and the National Privacy Commission within 72 hours of becoming aware of the incident.
• Staff training: All 24phwin personnel with access to personal data receive regular data privacy and security training.

While we take all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

As a data subject under Republic Act No. 10173, you have the following rights in respect of your personal data held by 24phwin:

• Right to be informed: The right to know what personal data we collect, why we collect it, 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 we hold about you, along with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold 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 our 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, machine-readable format and to transmit it to another controller.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. We will respond to all verified requests within fifteen (15) business days. We may need to verify your identity before processing your request.

24phwin is strictly an adult platform. In accordance with PAGCOR regulations, our services are available only to individuals who are 21 years of age or older. We do not knowingly collect personal data from individuals under the age of 21.

Our registration process includes mandatory age verification steps. If we become aware that personal data has been collected from an individual under 21, we will immediately suspend the relevant account, delete the associated personal data, and return any deposited funds to the payment source.

If you are a parent or guardian and believe that a minor has registered on 24phwin, please contact our support team immediately at [email protected] so that we can take prompt action.

Some of 24phwin's third-party service providers — including cloud infrastructure and KYC verification partners — may process personal data outside of the Philippines. Where such transfers occur, 24phwin ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012.

These safeguards may include:

• Contractual clauses requiring the recipient to process data in accordance with Philippine data privacy standards.
• Transfers to jurisdictions that the National Privacy Commission has recognized as providing an adequate level of data protection.
• Binding corporate rules where data is transferred within a group of companies.

You may request details of the specific safeguards in place for any international transfer of your personal data by contacting our Data Protection Officer.

24phwin may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email and/or a prominent notice on the platform at least seven (7) days before the changes take effect.

The effective date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how 24phwin protects your personal data.

Your continued use of the 24phwin platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you should cease using the platform and contact us to close your account.

24phwin has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 on the 24phwin platform. Our support agents are fluent in English and Filipino.
• Email (DPO): [email protected] — please include "Data Privacy Request" in the subject line.

We aim to acknowledge all data privacy requests within 24 hours and to provide a substantive response within fifteen (15) business days. For complex requests, we may require additional time and will notify you accordingly.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through its official channels.