Privacy Policy
How phwen Handles Your Data

1. Data Controller & Overview

1.1 phwen is the data controller responsible for the personal data collected through phwen.one. As data controller, phwen determines the purposes and means by which your personal data is processed.

1.2 phwen processes personal data in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, as administered by the National Privacy Commission (NPC) of the Philippines. Where phwen processes data for purposes connected to PAGCOR-regulated gaming operations, such processing is also subject to applicable PAGCOR data governance requirements.

1.3 This Policy should be read alongside phwen's Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference.

2. Personal Data We Collect

2.1 Registration & Identity Data

When you create a phwen account, we collect:

• Full legal name;
• Date of birth (to verify the 21+ age requirement);
• Philippine mobile number;
• Email address;
• Username and encrypted password hash;
• Province or city of residence (used for PAGCOR reporting and responsible gaming geo-targeting).

2.2 Identity Verification (KYC) Data

To comply with PAGCOR requirements and anti-money laundering regulations under Republic Act No. 9160 (Anti-Money Laundering Act), phwen collects:

• Copies of government-issued photo identification (PhilSys National ID, UMID, Driver's License, Passport, or equivalent);
• Proof of address documents (utility bills, bank statements, or government correspondence);
• Selfie or liveness verification images, where required for enhanced verification;
• Source of funds information, where required for high-value account profiles.

2.3 Financial & Transaction Data

phwen collects financial data necessary to process deposits and withdrawals, including:

• GCash mobile number or Maya account identifier;
• Bank account name and account number (for BPI, BDO, Metrobank, and other bank transfer withdrawals);
• Transaction reference numbers and timestamps;
• Deposit and withdrawal amounts in PHP;
• Complete transaction history associated with your phwen account.

phwen does not store raw card numbers or full banking credentials. Payment processing is handled by certified Philippine payment partners whose data security practices are independently assessed.

2.4 Gaming Activity Data

• Game session records (game titles played, session start and end times, wager amounts, win/loss outcomes);
• Sports betting slip history (markets, odds, stake amounts, outcomes);
• Bonus and promotional activity logs;
• Responsible gaming tool settings (deposit limits, session alerts, self-exclusion status).

2.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Session identifiers and authentication tokens;
• Log data (page views, errors, timestamps).

2.6 Communications Data

• Live chat transcripts with phwen's support team;
• Email correspondence;
• Records of any formal complaint or dispute submitted to phwen.

3. How We Collect Your Data

3.1 Directly from you — when you register, complete KYC, make a deposit or withdrawal, use live chat, or contact phwen support.

3.2 Automatically — through cookies, session tokens, and server-side logging when you access phwen.one.

3.3 From third parties — from payment processors (GCash, Maya, BPI, BDO, Metrobank) to confirm transaction status; from identity verification service providers where enhanced KYC is required; and from fraud detection partners.

4. Purposes of Processing

4.1 phwen processes your personal data for the following purposes:

• Account Management: Creating, verifying, and maintaining your phwen player account;
• Identity Verification: Fulfilling KYC obligations required by PAGCOR and anti-money laundering regulations;
• Payment Processing: Executing GCash, Maya, and bank transfer deposits and withdrawals;
• Gaming Services: Delivering the phwen Casino games, sportsbook, bingo, and sabong services to you;
• Regulatory Compliance: Meeting reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission;
• Responsible Gaming: Operating deposit limit systems, session alerts, cooling-off periods, and self-exclusion tools;
• Fraud Prevention & Security: Detecting and preventing unauthorized access, multi-accounting, bonus abuse, and money laundering;
• Customer Support: Responding to inquiries, complaints, and disputes submitted via live chat or email;
• Service Improvement: Analyzing aggregated usage data to improve phwen's platform and game library;
• Direct Marketing: Sending promotional communications about phwen offers, where you have consented to receive them and have not subsequently opted out.

5. Legal Basis for Processing

5.1 phwen processes your personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to fulfill phwen's obligations under the Terms & Conditions you accepted at registration (account management, payments, game delivery);
• Legal Obligation: Processing required to comply with applicable Philippine law (PAGCOR regulations, Anti-Money Laundering Act, Data Privacy Act);
• Legitimate Interest: Processing for fraud prevention, platform security, and service improvement, where phwen's legitimate interest does not override your privacy rights;
• Consent: Processing for direct marketing communications, where you have explicitly opted in. You may withdraw marketing consent at any time by contacting [email protected].

6. Sharing & Disclosure of Personal Data

6.1 phwen does not sell your personal data to third parties. phwen shares personal data only in the following circumstances:

• Payment Processors: GCash (Mynt), Maya (PayMaya Philippines), GrabPay, QR Ph network banks, BPI, BDO, Metrobank — to process transactions. Each processor is bound by their own privacy policy and applicable Philippine law;
• Identity Verification Providers: Third-party KYC service providers contracted by phwen to perform document verification and liveness checks;
• Game Providers: PG Soft, JILI, Pragmatic Play, and other certified game studios receive session identifiers and RNG seed data necessary to operate their games within the phwen platform. They do not receive your full identity data;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where phwen is required by law or regulation to make such disclosures;
• Law Enforcement: Philippine law enforcement agencies, courts, or other competent authorities where required by lawful order;
• Professional Advisors: phwen's lawyers, auditors, and accountants, where necessary and subject to confidentiality obligations.

6.2 phwen does not share your personal data with advertising networks, data brokers, or social media platforms for targeting or profiling purposes.

7. Cookies & Tracking Technologies

7.1 phwen uses cookies and similar tracking technologies to operate the phwen.one platform. Cookies are small text files stored on your device by your browser.

7.2 phwen uses the following types of cookies:

• Strictly Necessary Cookies: Required for phwen to function — session authentication, login state persistence, and security tokens. These cannot be disabled without breaking core phwen functionality;
• Functional Cookies: Store your preferences such as language setting, game lobby layout, and responsible gaming alert thresholds;
• Analytics Cookies: Used by phwen's internal analytics tools to understand platform usage patterns. Data collected is aggregated and anonymized before analysis;
• Fraud Detection Cookies: Device fingerprinting tokens used by phwen's fraud prevention systems to identify anomalous login patterns and multi-accounting attempts.

7.3 phwen does not use third-party advertising cookies or tracking pixels that transmit your data to ad networks. You may configure your browser to refuse cookies, but this will prevent phwen from functioning correctly.

8. Data Retention

8.1 phwen retains personal data for as long as your account remains active and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act's transaction record retention obligations.

8.2 KYC documentation is retained for a minimum of five (5) years from the date of submission, or longer where required by applicable regulation.

8.3 Live chat and email support records are retained for three (3) years from the date of the interaction.

8.4 Where personal data is no longer required for any lawful purpose, phwen securely deletes or anonymizes it in accordance with its internal data lifecycle management procedures.

9. Data Security

9.1 phwen implements industry-standard technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phwen.one;
• Encryption at rest for all sensitive personal data stored in phwen's databases;
• Multi-factor authentication for phwen staff accessing player data systems;
• Role-based access controls limiting data access to personnel with a legitimate operational need;
• Regular security assessments and penetration testing of phwen's infrastructure;
• Incident response procedures for the detection, containment, and notification of data breaches.

9.2 In the event of a personal data breach that poses a risk to your rights and freedoms, phwen will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with Section 20 of the Data Privacy Act of 2012.

10. Your Data Rights

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

• Right to be Informed: The right to know what personal data phwen holds about you and how it is processed (fulfilled by this Policy);
• Right of Access: The right to request a copy of the personal data phwen holds about you;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected;
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data, subject to phwen's legal retention obligations under PAGCOR and AML regulations;
• Right to Object: The right to object to processing of your personal data for direct marketing or other purposes based on legitimate interest;
• 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 file a complaint with the National Privacy Commission of the Philippines if you believe phwen has violated your data rights.

10.2 To exercise any of these rights, please contact phwen's Data Protection Officer at [email protected] with the subject line "Data Rights Request." phwen will respond within 15 business days of receiving a valid request. Identity verification may be required before phwen processes a data rights request.

11. Children's Privacy

11.1 phwen's services are strictly for persons aged 21 years or older. phwen does not knowingly collect personal data from any individual under the age of 21. If phwen discovers that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed.

11.2 If you believe a person under 21 has registered a phwen account, please notify phwen immediately at [email protected].

12. Cross-Border Data Transfers

12.1 Some of phwen's service providers — particularly certified game studios — operate servers or infrastructure outside the Philippines. Where personal data is transferred outside the Philippines, phwen ensures that such transfers comply with the requirements of the Data Privacy Act of 2012, including that the recipient country provides an adequate level of protection or that appropriate contractual safeguards are in place.

12.2 Game session data transmitted to game providers is limited to technical session parameters and does not include full identity or financial data. Full identity and financial data remains within Philippine-jurisdiction systems wherever practicable.

13. Changes to This Policy

13.1 phwen may update this Privacy Policy from time to time to reflect changes in our data practices, service offerings, or applicable law. When material changes are made, phwen will post the updated Policy at phwen.one/privacy-policy and update the "Last Updated" date at the top of this page.

13.2 Where changes are material and affect the processing of existing players' personal data, phwen will notify registered players via email or in-platform notification at least 7 days before the changes take effect. Continued use of phwen following such notification constitutes acceptance of the updated Policy.

14. Contact & Data Protection Officer

14.1 phwen has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act of 2012. The DPO is the first point of contact for all data privacy matters.

14.2 To contact phwen's Data Protection Officer or to exercise your data rights:

• Email: [email protected] (subject line: "Data Rights Request" or "Privacy Inquiry")
• Live Chat: Available 24/7 at phwen.one, Philippine Standard Time

14.3 If you are not satisfied with phwen's response to a privacy complaint, you may escalate to the National Privacy Commission of the Philippines via the NPC's official complaint process.