winoh Casino Privacy Policy

winoh Casino is the personal information controller in respect of all personal data collected through the winoh platform at winoh.club. As the data controller, winoh determines the purposes and means of processing your personal information and is responsible for ensuring that processing activities comply with the Data Privacy Act of 2012 and applicable PAGCOR regulatory requirements.

For all data privacy matters, including requests to exercise your data subject rights, you may contact winoh's designated Data Protection Officer (DPO) using the contact details provided in Section 13 of this Policy.

winoh collects the following categories of personal data from players:

winoh does not collect sensitive personal information (as defined under the Data Privacy Act, such as racial or ethnic origin, political opinions, or health data) unless specifically required for responsible gaming compliance purposes (e.g., self-exclusion documentation).

winoh collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, or contacting the winoh support team.
• Automated collection: Technical and usage data collected automatically when you access and interact with the winoh platform, including via cookies and similar tracking technologies (see Section 9).
• Third-party sources: Identity verification data from KYC/AML service providers; payment confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank; fraud prevention data from fraud detection partners.
• Regulatory sources: Information received from PAGCOR or other regulatory bodies in the discharge of compliance obligations.

winoh processes your personal data for the following purposes and on the following legal bases under the Data Privacy Act of 2012:

• Account registration and management — Necessary for the performance of the contract between you and winoh (the Terms & Conditions).
• Identity and age verification (KYC) — Compliance with legal obligations under PAGCOR requirements and anti-money laundering regulations. This includes verifying that all players are 21 years of age or older.
• Payment processing — Necessary for the performance of the contract; enables deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank.
• Fraud detection and prevention — Legitimate interests of winoh in maintaining platform integrity and protecting players from unauthorized account access.
• Customer support — Necessary for the performance of the contract; enables winoh to respond to your inquiries and resolve disputes.
• Responsible gaming compliance — Compliance with legal obligations; monitoring of gaming behaviour to detect potential problem gambling in accordance with PAGCOR guidelines.
• Regulatory reporting — Compliance with legal obligations to report certain activities to PAGCOR and other regulatory or law enforcement authorities.
• Platform improvement and analytics — Legitimate interests of winoh in understanding how the platform is used in order to improve user experience for Filipino players.
• Direct marketing — With your consent (which may be withdrawn at any time), to send you promotional offers, bonus notifications, and game updates relevant to your account.

winoh does not sell your personal data. winoh may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank — to process your deposit and withdrawal transactions.
• Identity verification providers: KYC and AML service providers engaged by winoh to verify your identity and age in compliance with PAGCOR requirements.
• Game content providers: Game studios and live dealer operators whose titles are made available through the winoh platform, for the purpose of game session management and RNG integrity verification.
• Fraud prevention partners: Third-party fraud detection and security services engaged by winoh to protect the platform and its players.
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), law enforcement authorities, and courts, where disclosure is required by law or regulatory directive.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers engaged to operate the winoh platform, subject to contractual data processing agreements.

All third-party data processors engaged by winoh are required by contract to process personal data only on winoh's instructions and in compliance with applicable Philippine data protection law.

winoh retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and applicable AML regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with anti-money laundering record-keeping obligations.
• Gaming history: Retained for a minimum of two (2) years from the date of the gaming session, subject to longer retention where required by regulatory audit obligations.
• Support communications: Retained for a minimum of two (2) years from the date of the last communication.
• Marketing consent records: Retained for the duration of your account plus two (2) years following account closure.

Upon expiry of the applicable retention period, winoh will securely delete or anonymise your personal data in a manner that prevents reconstruction or identification.

winoh's security measures include, without limitation:

• SSL/TLS 256-bit encryption for all data transmitted between your device and the winoh platform;
• Encrypted storage of passwords using industry-standard hashing algorithms — winoh staff cannot access your password in plain text;
• Two-factor authentication (2FA) via SMS OTP for new device logins;
• Role-based access controls limiting staff access to personal data to those with a legitimate operational need;
• Regular security audits and penetration testing of the winoh platform;
• Incident response procedures for notifying the National Privacy Commission (NPC) and affected players in the event of a personal data breach, in accordance with NPC Circular 16-03.

Notwithstanding the security measures in place, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your winoh account credentials and for notifying winoh immediately if you suspect any unauthorised access to your account.

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by winoh:

• Right to be informed: The right to know how your personal data is being collected, processed, and used — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data winoh holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure (right to be forgotten): The right to request deletion of your personal data, subject to winoh's legal retention obligations under PAGCOR regulations and AML law.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes. Withdrawal of consent for marketing does not affect the lawfulness of processing for other purposes.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe winoh has processed your personal data in violation of the Data Privacy Act.

To exercise any of your rights, please contact winoh's Data Protection Officer using the contact details in Section 13. winoh will respond to verified requests within thirty (30) days of receipt, subject to identity verification requirements.

winoh uses cookies and similar tracking technologies to operate and improve the platform. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the platform to function — these maintain your login session, remember your preferences, and protect the platform from fraud. These cookies cannot be disabled.
• Performance cookies: Collect anonymised data about how players use the winoh platform (pages visited, features used, error events) to enable platform improvements. No personally identifiable information is collected through performance cookies.
• Functional cookies: Remember your platform settings (language preference, game lobby display settings) to provide a more personalised experience.

You may manage your cookie preferences through your browser settings. Disabling non-essential cookies may affect the functionality of some platform features. winoh does not use third-party advertising cookies or share behavioural tracking data with advertising networks.

If you believe that a minor has accessed or registered on the winoh platform, please notify winoh's support team immediately via live chat or by email at [email protected].

Some of winoh's service providers and game content partners are located outside the Philippines. Where personal data is transferred to a jurisdiction outside the Philippines, winoh ensures that appropriate safeguards are in place to protect your data, including:

• Data processing agreements incorporating standard contractual clauses approved by the National Privacy Commission or equivalent;
• Transfers only to jurisdictions that provide an adequate level of data protection as assessed by the NPC;
• Contractual obligations requiring overseas processors to handle your data to the same standard required under Philippine law.

Where required by Philippine law, winoh will seek your prior consent before transferring sensitive personal information to overseas processors.

winoh reserves the right to update this Privacy Policy from time to time to reflect changes in applicable law, PAGCOR regulatory requirements, or winoh's data processing practices. Material changes will be communicated to registered players via email notification or an on-site notice at least fourteen (14) days before the changes take effect.

The effective date at the top of this Policy indicates when it was last updated. Your continued use of the winoh platform following the effective date of a revised Privacy Policy constitutes your acknowledgement of the updated Policy.

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

• 24/7 Live Chat: Available directly on the winoh Casino platform at winoh.club
• Email: [email protected]
• Messenger & Viber: Contact via Live Chat for current details

winoh aims to respond to all privacy-related requests within thirty (30) calendar days. Complex requests may require up to sixty (60) days, in which case winoh will notify you of the extended timeline within the initial 30-day period.

If you are not satisfied with winoh's response to your data privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.