phwine Privacy Policy

phwine ("phwine", "we", "us", "our") is the operator of the online gaming platform accessible at phwine.vip and acts as the Personal Information Controller as defined under Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), with respect to the personal data of registered users and visitors of the phwine Platform.

As the Personal Information Controller, phwine determines the purposes and means by which your personal data is collected and processed. phwine is committed to handling all personal data in compliance with the DPA, its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC").

For all privacy-related inquiries, requests to exercise your data subject rights, or concerns regarding this Privacy Policy, please contact phwine's designated Data Protection Officer ("DPO") using the contact details in Section 15 of this Policy.

phwine collects the following categories of personal data from registered players and, in limited cases, from Platform visitors. Data collection is proportionate to the purpose for which it is collected and limited to what is reasonably necessary for each processing activity.

phwine collects personal data through the following channels:

Data you provide directly to phwine when you register an Account, complete the KYC verification process, make a deposit or withdrawal request, contact customer support, respond to surveys or promotions, or update your Account profile settings.

Technical data — including IP address, device identifiers, browser information, and session activity logs — is collected automatically when you access or interact with phwine.vip. This data is generated through server logs, cookies, and similar technologies as described in Section 7 of this Policy.

In limited circumstances, phwine may receive personal data from third parties to supplement information you have provided directly. This includes:

• Payment processors (GCash, Maya, BPI, BDO, Metrobank, and other listed providers) — for transaction confirmation and fraud prevention purposes
• Identity verification service providers — to assist in KYC document authentication where phwine uses a certified third-party verification system
• Fraud detection services — aggregated risk signals used to identify and prevent fraudulent account activity
• Regulatory authorities — where disclosure of data to phwine is required or authorised by Philippine law

phwine processes personal data only where a lawful basis exists under the Data Privacy Act of 2012. The following legal bases apply to phwine's processing activities:

• Consent: Where you have provided your freely given, specific, informed, and unambiguous consent to the processing of your personal data for a defined purpose — such as receiving marketing communications or participating in optional surveys. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Contractual Necessity: Processing necessary for the performance of the contract between you and phwine — principally, the operation of your Account, processing of deposits and withdrawals, and provision of gaming services.
• Legal Obligation: Processing required for phwine to comply with its obligations under Philippine law, including the Anti-Money Laundering Act (AMLA), the Data Privacy Act, PAGCOR regulations, and any applicable court orders or regulatory directions.
• Legitimate Interests: Processing necessary for the pursuit of phwine's legitimate interests, where such interests are not overridden by your rights and freedoms — including fraud prevention, security monitoring, platform improvement, and responsible gaming compliance.

phwine uses the personal data it collects for the following specified, explicit, and legitimate purposes:

phwine does not use personal data for automated decision-making that produces significant legal effects on you without a human review process, except where such processing is strictly required for fraud prevention in real time.

phwine does not sell, rent, or trade your personal data. phwine shares personal data only in the following circumstances and only to the extent strictly necessary for each purpose:

phwine engages certified third-party service providers who process personal data on phwine's behalf under written data processing agreements that require equivalent data protection standards. These include payment processors, KYC verification providers, cloud hosting services, game providers, and fraud detection platforms. All such providers are contractually prohibited from using your data for any purpose beyond the services they provide to phwine.

phwine will disclose personal data to Philippine regulatory authorities (including PAGCOR and the Anti-Money Laundering Council), the National Privacy Commission, law enforcement agencies, or courts where such disclosure is required or authorised by Philippine law, including mandatory AMLA reporting obligations and responses to valid legal process.

In the event of a merger, acquisition, or sale of all or substantially all of phwine's assets, your personal data may be transferred to the successor entity, subject to that entity assuming equivalent data protection obligations. You will be notified of any such transfer that materially affects your privacy rights.

phwine may share your personal data with additional third parties where you have given your express prior consent for a specific sharing arrangement. Such consent may be withdrawn at any time with effect going forward.

phwine uses cookies and similar tracking technologies to provide essential Platform functionality, maintain authenticated sessions, and improve user experience. phwine does not use cookies to serve third-party advertising or to sell behavioural data to external networks.

• Essential Cookies: Necessary for the basic functioning of phwine.vip — including maintaining your login session, remembering your language and display preferences, and enabling security features. These cannot be disabled without disrupting core Platform functionality.
• Analytical Cookies: Used to measure Platform performance — page load times, error rates, and aggregate navigation patterns. Data collected is anonymised and used solely for internal Platform improvement purposes.
• Functional Cookies: Enhance your experience by remembering preferences such as your most recently played games and notification settings. These are optional.

You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling essential cookies will affect your ability to log in and use key phwine Platform features. Specific instructions for managing cookies are available in the help documentation of your browser (Chrome, Safari, Firefox, Edge, or other browsers you use to access phwine).

phwine retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following specific retention schedules:

Following the expiry of applicable retention periods, phwine will securely delete or irreversibly anonymise personal data so that it can no longer be associated with you as an identifiable individual.

phwine implements technical and organisational security measures appropriate to the risk level of the personal data being processed. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and phwine servers
• AES-256 encryption at rest for sensitive personal data and financial records stored in phwine databases
• Role-based access controls limiting employee access to personal data to those with a demonstrable operational need
• Multi-factor authentication on all phwine internal systems and administrative interfaces
• Automated intrusion detection systems monitoring for anomalous access patterns or data exfiltration attempts
• Regular security audits and penetration testing conducted by independent third-party security professionals
• Staff training on data protection obligations, phishing prevention, and secure data handling procedures
• Data breach response plan maintained and tested periodically, with clear escalation paths to the DPO and NPC notification procedures

While phwine applies robust security measures, no internet-based system is entirely risk-free. You are responsible for maintaining the security of your own phwine Account credentials, including your password and 2FA codes. Do not share your phwine login details with any other person.

Under the Philippine Data Privacy Act of 2012 and its IRR, you have the following rights with respect to your personal data held by phwine. To exercise any of these rights, submit a written request to phwine's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request".

phwine will respond to all verified data subject rights requests within 30 calendar days of receipt. Complex requests may require an extension of up to 60 days, in which case you will be notified of the delay and the reason. phwine may require identity verification before processing any rights request to prevent unauthorised disclosure.

If you believe phwine has failed to adequately address your privacy concerns, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.

The phwine Platform is strictly intended for individuals who are 21 years of age or older, as required under applicable Philippine gaming regulations. phwine does not knowingly collect personal data from individuals under the age of 21.

If phwine becomes aware that a registered Account belongs to a person under the age of 21, the Account will be immediately suspended, all real-money balances will be returned to the depositing payment source following verification, and all personal data associated with that Account will be deleted or anonymised except where retention is mandatorily required by law for regulatory reporting purposes.

If you believe that a minor has created a phwine Account or provided personal information to phwine, please contact our Data Protection Officer immediately at [email protected].

In the course of providing the phwine Platform, some personal data may be transferred to, stored in, or processed by service providers located outside the Philippines. Examples include cloud infrastructure providers and internationally deployed game platform backends maintained by phwine's game provider partners.

phwine ensures that all cross-border transfers of personal data are conducted in accordance with the requirements of the Data Privacy Act and NPC issuances on cross-border data flows. Specifically, phwine implements one or more of the following safeguards for each international transfer:

• Data processing agreements with the recipient incorporating NPC-compliant data protection obligations equivalent to those under Philippine law
• Adequacy assessments confirming that the recipient country or organisation provides an equivalent level of data protection
• Your explicit consent to the specific transfer, where required and appropriate

phwine does not transfer sensitive personal information (including government ID data) to any third party outside the Philippines except where strictly required for KYC verification using a certified international identity verification service operating under adequate contractual safeguards.

The phwine Platform may contain references or links to third-party platforms including game providers' standalone websites, payment provider portals, or responsible gaming support organisations. phwine is not responsible for the privacy practices or content of any third-party platform and does not control the data collection or processing activities of external sites.

When you navigate away from phwine.vip to a third-party platform, you do so at your own risk and subject to that platform's own privacy policy. phwine recommends reviewing the privacy policy of any third-party platform before providing your personal information.

phwine reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, regulatory guidance from the NPC, or Platform features. The effective date of the current version is stated at the top of this Policy and in the update banner above.

Where changes are material — meaning they substantively affect your privacy rights or how phwine processes your personal data — phwine will notify you by email to your registered address and/or through a prominent in-Platform notification at least seven (7) days before the changes take effect.

Minor amendments, including formatting corrections or terminology clarifications that do not affect the substance of the Policy, may be published without advance notice. The date of last update will always be updated to reflect the most recent revision.

Your continued use of the phwine Platform after the effective date of any Policy revision constitutes your acknowledgement of the updated Privacy Policy. If you do not accept the revised Policy, you must cease using the Platform and contact phwine to request Account closure.

For all privacy-related inquiries, requests to exercise data subject rights, questions about this Privacy Policy, or to report a suspected privacy concern, please contact phwine's designated Data Protection Officer using the following channels:

• Email: [email protected]
  Please use the subject line: "Privacy / Data Subject Rights Request" or "Privacy Concern" as appropriate.
• Live Chat: The phwine live chat function, accessible on phwine.vip, is staffed 24/7 and can be used to initiate a privacy inquiry. Complex requests will be directed to the DPO team via email for formal processing.

phwine will acknowledge all privacy-related requests within 48 hours of receipt and provide a substantive response within 30 calendar days, or notify you of a required extension if applicable.

If you are not satisfied with phwine's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for the enforcement of the Data Privacy Act in the Philippines.

phwine · phwine.vip · [email protected]
This Privacy Policy is effective as of 1 January 2026 and supersedes all prior versions.