phwil Privacy Policy

1 Introduction & Scope

phwil ("we", "us", "our", or the "Company") operates the online gaming platform at phwil.club (the "Platform") under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR). phwil is committed to protecting the personal data of every player, prospective player, and visitor who interacts with the Platform.

This Privacy Policy applies to all personal data processed by phwil in connection with your use of phwil.club, including account registration, identity verification (KYC), payment processing, gameplay, customer support interactions, and marketing communications. It covers data collected via the Platform's website, live chat support, email correspondence, and any other phwil-operated channel.

This Policy is prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission (NPC) of the Philippines. By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, phwil is the Personal Information Controller (PIC) with respect to personal data collected and processed through the Platform. phwil determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law.

phwil has designated a Data Protection Officer (DPO) who oversees the Company's data protection compliance. Contact details for the DPO are provided in Section 15 of this Policy.

3 Personal Data We Collect

3.1 Account Registration Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — minimum 21 years required)
• Philippine mobile number (used as primary account identifier and OTP recipient)
• Email address
• Chosen username and encrypted account password
• Residential address (city/province, Philippines)

3.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine identification documents (see accepted IDs in Terms & Conditions)
• Selfie or liveness check photograph (where required for document matching)
• Taxpayer Identification Number (TIN) where applicable under PAGCOR requirements

3.3 Financial Data

• GCash or Maya account mobile number (for payment processing)
• Bank account details (bank name, account number, account name) where bank transfer is used
• Transaction records: deposit amounts, withdrawal amounts, dates, and payment method used
• Source of funds declarations (where required by AML compliance)

3.4 Gameplay & Platform Usage Data

• Game history, bet amounts, game results, session durations
• Responsible gaming tool settings and self-exclusion records
• Bonus participation and wagering history
• Login timestamps, IP addresses, and device identifiers

3.5 Communications Data

• Content of customer support interactions (live chat transcripts, email correspondence)
• Responses to phwil surveys or feedback requests
• Marketing communication preferences and opt-in/opt-out records

4 How We Collect Personal Data

phwil collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions
• Automatically from your device — via cookies, session tokens, and server logs when you access or navigate the Platform (see Section 10)
• From payment providers — GCash, Maya, and banking partners may share transaction confirmation data with phwil for payment verification purposes
• From identity verification services — third-party KYC and document verification providers engaged by phwil to authenticate identity documents
• From PAGCOR or other regulatory bodies — where disclosure is required to fulfil regulatory obligations

5 Purpose & Legal Basis for Processing

6 How We Use Your Personal Data

phwil uses the personal data described in Section 3 for the following specific purposes:

6.1 Account & Service Delivery

To create and maintain your phwil account, process your phwil login, authenticate your identity during each session, deliver the gaming services you have requested, and manage your PHP wallet balance, deposits, and withdrawals.

6.2 Regulatory Compliance

To fulfil phwil's obligations under PAGCOR licensing conditions, including player identity verification, age verification (21+ requirement), Anti-Money Laundering (AML) monitoring, and mandatory reporting obligations to PAGCOR and the Anti-Money Laundering Council (AMLC) of the Philippines.

6.3 Responsible Gaming

To monitor gameplay patterns for signs of problem gambling, enforce player-set deposit and loss limits, process cooling-off and self-exclusion requests, and communicate responsible gaming information to players where appropriate.

6.4 Security & Fraud Prevention

To detect and prevent unauthorized access to phwil accounts, identify fraudulent transactions, investigate suspected breaches of phwil's Terms and Conditions, and protect the integrity of the Platform.

6.5 Customer Support

To respond to enquiries, resolve account issues, process bonus claims, and provide technical assistance. Support interactions are recorded for quality assurance and staff training purposes.

6.6 Marketing (with Consent)

With your explicit opt-in consent, to send promotional offers, bonus notifications, and platform updates via SMS to your registered Philippine mobile number or via email. You may withdraw marketing consent at any time through your account settings or by contacting support.

7 Data Sharing & Third-Party Disclosure

phwil does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following circumstances:

7.1 Service Providers (Personal Information Processors)

phwil engages third-party service providers who process personal data on our behalf under strict contractual obligations consistent with RA 10173. These include: payment processing partners (GCash, Maya, BPI, BDO, Metrobank), KYC/identity verification providers, cloud infrastructure providers, customer support software providers, and platform analytics services. All processors are required to implement appropriate technical and organizational security measures.

7.2 Regulatory & Law Enforcement Authorities

phwil is required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities when required by law, regulation, court order, or lawful regulatory direction.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of phwil's business assets, your personal data may be transferred to the acquiring entity, subject to the same data protection obligations under this Policy and applicable Philippine law.

7.4 No Unauthorized Disclosure

phwil will not disclose your personal data to any third party outside the categories described above without your prior written consent, except where required by Philippine law.

8 Data Retention

phwil retains personal data for as long as is necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods required by Philippine law and PAGCOR regulations:

• Account and KYC records: Minimum five (5) years from account closure, as required by PAGCOR and AMLC regulations
• Financial transaction records: Minimum five (5) years from the date of transaction, pursuant to RA 9160 (AMLA) requirements
• Customer support communications: Two (2) years from the date of the last interaction
• Marketing consent records: Until consent is withdrawn plus one (1) year for audit purposes
• Responsible gaming and self-exclusion records: Duration of exclusion plus five (5) years

Upon expiry of the applicable retention period, phwil will securely delete or anonymize personal data in accordance with NPC-approved data disposal procedures.

9 Data Security

phwil implements the following technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption on all data transmitted between your device and phwil's servers
• Encrypted storage of all sensitive personal data, including passwords (hashed with bcrypt) and identity document files
• Access controls — personal data is accessible only to authorized phwil personnel on a need-to-know basis
• Two-factor authentication (2FA) for all phwil staff accounts with access to personal data systems
• Regular security audits and penetration testing of Platform infrastructure
• Incident response procedures aligned with NPC breach notification requirements under RA 10173

10 Cookies & Tracking Technologies

phwil uses cookies and similar tracking technologies on phwil.club for the following purposes:

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may impair your ability to log in to your phwil account or use core Platform features.

11 Your Rights Under the Data Privacy Act of 2012

As a data subject under RA 10173, you have the following rights with respect to your personal data held by phwil:

• Right to be Informed — the right to know what personal data phwil collects and how it is used (this Policy fulfils that right)
• Right to Access — the right to obtain a copy of the personal data phwil holds about you
• Right to Rectification — the right to have inaccurate or incomplete personal data corrected
• Right to Erasure / Blocking — the right to request deletion or blocking of personal data that is no longer necessary or was unlawfully processed (subject to legal retention obligations)
• Right to Object — the right to object to processing of your personal data for marketing purposes or where processing is based on legitimate interest
• Right to Data Portability — the right to receive your personal data in a structured, commonly used, and machine-readable format
• Right to Lodge a Complaint — the right to file 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 these rights, contact phwil's Data Protection Officer using the contact details in Section 15. phwil will respond to verified data subject requests within fifteen (15) working days of receipt.

12 Children & Minors

phwil's Platform is strictly for persons aged 21 years and above, as mandated by PAGCOR regulations. phwil does not knowingly collect personal data from persons under the age of 21. If phwil becomes aware that an account has been registered by an underage individual, the account will be immediately suspended and any personal data associated with it deleted or blocked in accordance with RA 10173, except where retention is required by law.

If you believe that a minor has registered on phwil, please notify phwil's support team or Data Protection Officer immediately.

13 Cross-Border Data Transfers

phwil's primary data processing infrastructure is located in the Philippines. Where phwil engages service providers located outside the Philippines (for example, cloud infrastructure or KYC technology providers), any transfer of personal data to these providers is subject to the following safeguards in accordance with Section 21 of RA 10173:

• Data Processing Agreements (DPAs) requiring the receiving party to maintain data protection standards equivalent to those required under RA 10173
• Standard contractual clauses approved by the NPC where applicable
• Assessment of the recipient country's data protection laws to ensure adequate protection

phwil does not transfer personal data to countries that lack adequate legal protections for personal data without implementing the safeguards described above.

14 Changes to This Privacy Policy

phwil may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Material changes will be communicated to registered players via SMS to their registered Philippine mobile number and/or a prominent notice upon next phwil login.

The effective date at the top of this Policy indicates when the current version took effect. The most current version of this Privacy Policy is always available at phwil.club/privacy-policy. Continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Policy.

15 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or phwil's processing of your personal data, please contact phwil's Data Protection Officer through the following channels:

• Email (DPO): [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the phwil Platform (phwil login required)

If you are not satisfied with phwil's response to your data protection concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the government body responsible for administering and enforcing RA 10173.