win3max Privacy Policy

1Introduction

win3max ("we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our platform. This Privacy Policy describes how win3max collects, processes, stores, shares, and protects personal information in connection with your use of the win3max website, mobile interface, games, and all related services (collectively, the "Services").

This Policy is issued in compliance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). Where applicable, we also observe internationally recognised data protection principles.

By registering an account or using any part of the win3max platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2Data We Collect

win3max collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name as it appears on a valid government-issued identification document.
• Date of birth (to verify you are 21 years of age or older).
• Philippine mobile number and/or email address.
• Username and encrypted password.
• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence) submitted during Know Your Customer (KYC) verification.

2.2 Financial Data

• GCash or PayMaya account number (last digits only, for transaction matching).
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where provided for withdrawal processing.
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references.

2.3 Gaming & Activity Data

• Game session logs, including games played, wagers placed, outcomes, and session duration.
• Bonus and promotion usage history.
• Responsible gaming tool settings (deposit limits, self-exclusion status, cooling-off periods).

2.4 Technical & Device Data

• IP address and approximate geolocation (country and region level).
• Device type, operating system, browser type and version.
• Cookie identifiers and session tokens.
• Platform access logs and timestamps.

2.5 Communications Data

• Records of your communications with win3max customer support, including live chat transcripts and email correspondence.
• Feedback, survey responses, and complaints submitted to win3max.

3How We Use Your Data

win3max processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your win3max account, including identity verification and age verification (21+ requirement).
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver promotions and bonuses you have opted into.
• Legal & Regulatory Compliance: To comply with applicable Philippine laws, including anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, and reporting obligations to relevant regulatory authorities.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, money laundering, and other illegal conduct.
• Responsible Gaming: To monitor gaming behaviour for indicators of problem gambling and to administer responsible gaming tools including deposit limits, self-exclusion, and cooling-off periods.
• Customer Support: To respond to your enquiries, resolve disputes, and improve the quality of our support services.
• Platform Improvement: To analyse usage patterns, conduct internal research, and improve the functionality, performance, and user experience of the win3max platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent. You may withdraw consent at any time by contacting support.

4Legal Basis for Processing

win3max processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and win3max (i.e., the Terms and Conditions), including account creation, payment processing, and game delivery.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to win3max, including AML/KYC obligations and regulatory reporting requirements.
• Legitimate Interests: Where processing is necessary for the legitimate interests of win3max, including fraud prevention, platform security, and responsible gaming monitoring, provided such interests are not overridden by your rights and freedoms.

5Data Sharing & Disclosure

win3max does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged to verify your identity and screen against sanctions and watchlists.
• Game Providers: Licensed game software providers whose titles are available on the win3max platform, to the extent necessary to deliver game services and resolve disputes.
• Regulatory Authorities: Philippine government agencies and regulatory bodies, including the National Privacy Commission, where disclosure is required by law or court order.
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers engaged by win3max to operate and secure the platform, all of whom are bound by confidentiality obligations.
• Professional Advisers: Legal, accounting, and auditing firms engaged by win3max, subject to professional confidentiality obligations.

All third parties with whom win3max shares personal data are required to process such data in accordance with applicable data protection laws and win3max's data processing instructions.

6Cookies & Tracking Technologies

win3max uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the platform to function, including session authentication and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics Cookies: Collect anonymised data about how players use the platform to help us improve performance and user experience.
• Security Cookies: Used to detect and prevent fraudulent activity and unauthorised access attempts.

You may manage non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the win3max platform.

7Data Retention

win3max retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Gaming activity logs are retained for a minimum of three (3) years from the date of the session.
• Customer support communications are retained for a minimum of two (2) years from the date of the last interaction.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with win3max's data disposal procedures.

8Data Security

win3max implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the win3max platform is encrypted in transit.
• Encryption at Rest: Sensitive personal data, including identity documents and financial information, is encrypted when stored.
• Two-Factor Authentication (2FA): Available to all players to add an additional layer of security to account login.
• Access Controls: Personal data is accessible only to win3max personnel and authorised third parties who require it to perform their functions, on a strict need-to-know basis.
• Real-Time Fraud Monitoring: Automated systems monitor account activity 24/7 for indicators of fraud, unauthorised access, and suspicious transactions .
• Regular Security Audits: win3max conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities in the platform.

While win3max takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying win3max immediately if you suspect any unauthorised access to your account.

9Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by win3max:

• Right to be Informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data win3max holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have 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: You have 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: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days in accordance with NPC guidelines. We may require you to verify your identity before processing your request.

10Children's Privacy

The win3max platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gambling regulations applicable to casino-style gaming. win3max does not knowingly collect, process, or store personal data from individuals under the age of 21.

If win3max becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. All funds associated with an underage account will be handled in accordance with applicable regulations.

If you are a parent or guardian and believe that your child has registered on the win3max platform, please contact us immediately at [email protected] so that we can take appropriate action without delay.

11International Data Transfers

win3max primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers located outside the Philippines, including cloud infrastructure providers and game software vendors operating in other jurisdictions.

Where such international transfers occur, win3max ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission.
• Entering into data processing agreements with international service providers that incorporate standard contractual clauses consistent with NPC requirements.
• Conducting due diligence on the data protection practices of all international service providers before engaging their services.

By using the win3max platform, you acknowledge and consent to the transfer of your personal data to service providers outside the Philippines where necessary for the delivery of our Services, subject to the safeguards described above.

12Changes to This Privacy Policy

win3max reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or platform features. When material changes are made, we will notify registered players via the email address or mobile number on file, or by displaying a prominent notice on the platform, at least seven (7) days before the changes take effect.

The "Last Updated" 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 win3max protects your personal data.

Your continued use of the win3max platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the platform and close your account.

13Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by win3max, please contact our Data Protection Officer using the details below: