Privacy Policy – pinaswin

1. Introduction

Pinaswin ("we," "us," "our," or "the Company") operates the online gaming platform accessible at pinaswin.app ("the Platform"). We are committed to protecting the personal information of every player who registers and uses the pinaswin Platform. This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, disclosure, and protection of your personal data.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Philippine Data Privacy Act of 2012 ("PDPA"), its Implementing Rules and Regulations, and the directives of the National Privacy Commission ("NPC"). It applies to all personal information collected through the Platform, our customer support channels, and any other interaction you have with pinaswin.

By registering for a pinaswin account, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal information as described herein. If you do not agree, please do not register or use the Platform.

2. Personal Information We Collect

Pinaswin collects personal information that is necessary to operate your account, comply with regulatory requirements, and deliver a high-quality gaming experience. The categories of information we collect include:

2.1 Registration & Identity Information

• Full legal name as it appears on a valid Philippine government-issued ID;
• Date of birth (to verify the 21+ age requirement);
• Residential address;
• Email address and mobile phone number;
• Username and hashed password (we do not store your password in plain text).

2.2 Identity Verification (KYC) Documents

• Scanned or photographed copies of a valid Philippine government-issued ID (e.g., SSS, UMID, PhilHealth ID, Passport, Driver's License);
• Proof of payment method ownership (e.g., GCash account screenshot showing matching name and number);
• Selfie or liveness check image where required by our KYC process.

2.3 Financial Transaction Data

• Deposit and withdrawal amounts, dates, and associated payment method identifiers (e.g., GCash reference numbers, bank transaction IDs);
• Running account balance and transaction history.

2.4 Gaming Activity Data

• Game session logs, wager amounts, game outcomes, and session durations;
• Bonus redemption history and wagering contribution records;
• Responsible gaming tool usage (deposit limits set, cool-off periods activated, etc.).

2.5 Technical & Device Data

• IP address and approximate geolocation at the time of login;
• Device type, operating system, browser type and version;
• Cookies and similar tracking technologies (see Section 6).

2.6 Communications Data

• Records of live chat conversations, email correspondence, and support ticket content with our customer service team.

3. How Pinaswin Uses Your Personal Information

We use the personal information we collect for the following purposes:

• Account Management: To create, maintain, and operate your pinaswin account, including processing your pinaswin login authentication and session management.
• Identity Verification & KYC Compliance: To verify your identity and age (21+) as required by PAGCOR regulations and the Philippine Anti-Money Laundering Act (AMLA). This is a mandatory legal obligation — we cannot process withdrawals without completing KYC.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment channels. Transaction records are retained as required by AMLA.
• Regulatory Reporting: To comply with PAGCOR's reporting requirements as a licensed online gaming operator, including player activity reports and suspicious transaction reporting under AMLA.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling behaviour, administer player-requested responsible gaming tools, and respond to self-exclusion requests.
• Platform Improvement: To analyse aggregated usage data and improve the functionality, performance, and game offerings of the pinaswin Platform.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, account takeover attempts, and other prohibited conduct.
• Customer Support: To respond to your queries, resolve disputes, and improve our service quality.
• Marketing Communications: To send you promotional offers, tournament announcements, and bonus notifications — but only if you have opted in to receive such communications. You may opt out at any time.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act, pinaswin relies on the following legal bases for processing your personal information:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you agreed to upon registration — including account operation, payment processing, and game delivery.
• Legal Obligation: Processing is required to comply with PAGCOR licensing conditions, AMLA obligations, NPC directives, and other applicable Philippine laws.
• Legitimate Interest: Processing for fraud prevention, security monitoring, and platform improvement, where these interests do not override your privacy rights.
• Consent: Processing for optional marketing communications, where you have explicitly opted in. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Sharing Your Personal Information

Pinaswin does not sell your personal data to third-party marketers or data brokers. We may share your personal information only in the following circumstances:

• PAGCOR & Regulatory Authorities: As required by our operating licence, we share player data with PAGCOR and other Philippine regulatory bodies upon lawful request or as part of mandatory periodic reporting.
• AMLA Compliance: We are legally required to report suspicious transactions and provide player data to the Anti-Money Laundering Council ("AMLC") when legally compelled.
• Payment Processors: We share the minimum necessary transaction data with GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers to process your deposits and withdrawals. These providers process your data under their own privacy policies and applicable financial regulations.
• KYC Service Providers: We may use third-party identity verification services to assist with KYC processing. These providers are contractually bound to handle your data securely and exclusively for KYC purposes.
• Game Software Providers: Game providers such as JILI, PG Soft, and Pragmatic Play receive anonymised session identifiers for the purposes of game delivery. They do not receive your full personal details.
• Law Enforcement: We may disclose personal information to law enforcement agencies in the Philippines when required by a valid legal order or to protect the safety of our players and the integrity of the Platform.

6. Cookies & Tracking Technologies

Pinaswin uses cookies and similar tracking technologies on the Platform to enable core functionality and improve your experience. The categories of cookies we use include:

• Strictly Necessary Cookies: Required for the Platform to function — including session authentication, security tokens, and pinaswin login state management. These cannot be disabled.
• Performance Cookies: Collect anonymised data on how players navigate the Platform, which pages are visited most frequently, and where errors occur. This data is used to improve the Platform.
• Functional Cookies: Remember your preferences such as language settings, last visited game category, and notification preferences.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your pinaswin account. Pinaswin does not use third-party advertising cookies or cross-site tracking cookies.

7. Data Retention

Pinaswin retains your personal information for as long as your account is active and for the periods required by applicable law thereafter:

• Account and KYC records are retained for a minimum of five (5) years from account closure, as required by AMLA.
• Transaction records are retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications are retained for two (2) years from the date of the interaction.
• Gaming session logs are retained for three (3) years in accordance with PAGCOR reporting requirements.

After the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an individual player.

8. Security Measures

Pinaswin implements technical and organisational security measures appropriate to the risk level of the personal information we process. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the pinaswin Platform;
• Salted cryptographic hashing of all stored passwords — pinaswin staff cannot read your password;
• Two-factor authentication (2FA) via SMS OTP, available to all registered players;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Real-time fraud detection and anomaly monitoring for all pinaswin login sessions and financial transactions;
• Regular security audits and penetration testing of Platform infrastructure;
• Incident response procedures in compliance with NPC breach notification requirements.

9. Your Data Privacy Rights

As a data subject under the Philippine Data Privacy Act, you have the following rights with respect to your personal information held by pinaswin:

• Right to be Informed: The right to know that your personal data is being collected and how it will be used — which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal information pinaswin holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal information in your pinaswin account.
• Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations under AMLA and PAGCOR regulations.
• Right to Object: The right to object to processing based on legitimate interest, including direct marketing. You may opt out of marketing communications at any time.
• Right to Data Portability: The right to receive a structured, commonly used copy of your personal data for transfer to another service provider, where technically feasible.
• 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 the above rights, contact our Data Privacy Officer at: [email protected]. We will respond to verified requests within 15 business days.

10. Children & Minors

The pinaswin Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. Pinaswin does not knowingly collect personal information from individuals under the age of 21. If we become aware that a person under 21 has registered an account or provided personal information, we will immediately suspend the account, delete the associated personal data, and report the incident to PAGCOR as required.

Parents and guardians are encouraged to monitor the online activity of minors in their care and to use available parental control tools to prevent access to online gambling platforms.

11. Third-Party Links

The pinaswin Platform may contain links to third-party websites or services in the context of regulatory references or partner payment processors. Pinaswin is not responsible for the privacy practices of third-party sites. We encourage you to review the privacy policies of any third-party site you visit. This Policy applies exclusively to the pinaswin Platform.

12. Changes to This Privacy Policy

Pinaswin may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or Platform functionality. When material changes are made, we will notify registered players by email to their registered address and display a prominent notice on the Platform at least seven (7) days before the changes take effect. The updated Policy will be published on this page with a revised "Last Updated" date. Continued use of the Platform after the effective date constitutes acceptance of the revised Policy.

13. Contact Our Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or pinaswin's data processing practices, please contact our designated Data Privacy Officer:

• Email: [email protected] (subject line: "Data Privacy Request")
• Live Chat: Available 24/7 on the pinaswin Platform

For unresolved privacy complaints, you may also contact the National Privacy Commission of the Philippines.