phwil Privacy Policy

1. Introduction

phwil respects the privacy of every player who uses our online casino and sports betting platform. We understand that when you register and play on phwil, you are trusting us with personal and financial information — and we take that responsibility seriously.

This Privacy Policy is issued in compliance with the Philippine 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. It describes in clear terms the categories of personal data phwil collects, the purposes for which that data is processed, the parties with whom it may be shared, the security measures phwil has in place, and the rights available to you as a data subject under Philippine law.

Please read this Policy carefully. If you have questions about how phwil handles your personal data, contact our Data Protection Officer at the address provided in Section 13.

2. Personal Data We Collect

phwil collects personal data in the following categories, depending on how you interact with the Platform:

2.1 Registration Data

When you create a phwil account, we collect your full legal name, Philippine mobile number, date of birth, email address, and a username and password of your choosing. This information is necessary to establish and manage your account.

2.2 Identity Verification (KYC) Data

As part of our compliance with Philippine anti-money laundering and gaming regulatory requirements, phwil may collect copies of government-issued Philippine identification documents (e.g., PhilSys ID, passport, driver's licence), proof of address documents, and selfie photographs for identity verification purposes.

2.3 Financial Data

phwil collects transaction data related to deposits and withdrawals, including GCash account references, Maya account references, bank account details (where bank transfer is used), transaction amounts, dates, and statuses. phwil does not store full payment card numbers. Payment credentials are processed via our third-party payment partners.

2.4 Gaming Activity Data

phwil records your gaming history on the Platform, including games played, bet amounts, win/loss outcomes, bonus participation, session durations, and responsible gaming settings configured on your account.

2.5 Technical & Device Data

phwil automatically collects technical data when you access the Platform, including your IP address, device type and operating system, browser type and version, referring URLs, pages visited on phwil, and session timestamps. This data is used for security monitoring, platform optimisation, and fraud prevention.

2.6 Communications Data

If you contact phwil customer support, we retain records of that correspondence, including chat transcripts, email exchanges, and call recordings (where applicable), for quality assurance, training, and dispute resolution purposes.

3. How We Use Your Personal Data

phwil uses the personal data it collects for the following purposes:

4. Legal Basis for Processing

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

• Contractual necessity: Processing necessary to fulfil the phwil account agreement with you, including account management, game provision, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including the Anti-Money Laundering Act (AMLA), gaming regulatory requirements, and NPC directives.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your fundamental rights.
• Consent: Processing for marketing communications and optional profile personalisation, where you have provided explicit, informed consent that you may withdraw at any time.

5. Data Sharing & Disclosure

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

• Payment processors: GCash (GXI), Maya (Voyager Innovations), BDO, BPI, Metrobank, and GrabPay, for the processing of deposits and withdrawals. These providers operate under their own privacy policies and applicable Philippine financial regulations.
• Game providers: JILI, Pragmatic Play, Evolution, PG Soft, and other licensed game software providers, who receive anonymised or pseudonymised session data necessary to operate game software on the phwil platform.
• KYC and identity verification services: Third-party identity verification platforms used to validate government-issued Philippine identification documents as part of phwil's KYC process.
• Regulatory and law enforcement authorities: Philippine government agencies, including PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission, where disclosure is required by law or lawful order.
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to confidentiality obligations.

All third-party recipients of phwil player data are contractually required to process that data only for specified purposes and to maintain appropriate data security standards consistent with Philippine law.

6. Cookies & Tracking Technologies

phwil uses cookies and similar tracking technologies on its Platform for the following purposes:

• Essential cookies: Required for the Platform to function, including session management, authentication state, and security features. These cannot be disabled without impairing Platform functionality.
• Analytics cookies: Used to understand how players navigate and use the phwil Platform, enabling us to improve the user experience. Data collected is aggregated and anonymised where possible.
• Performance cookies: Used to optimise Platform loading speed and game performance across different devices and network conditions common in the Philippines.
• Marketing cookies: Used to deliver relevant promotional content to phwil players, subject to your marketing consent preferences. You may opt out of marketing cookies at any time via your phwil account settings.

You may configure your browser to refuse or delete cookies, but please note that disabling essential cookies will prevent you from logging in to phwil and using the Platform's core functions.

7. Data Security

phwil implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phwil's servers
• Encrypted storage of passwords using industry-standard hashing algorithms; phwil staff cannot view your password in plain text
• Multi-factor authentication options for phwil account access
• Role-based access controls limiting which phwil personnel can access player personal data
• Regular security assessments and penetration testing of the phwil Platform
• Real-time monitoring for suspicious login activity, including geo-anomaly detection

In the event of a personal data breach affecting phwil player data, phwil will notify the National Privacy Commission and affected players in accordance with the timeframes and procedures required under the Philippine Data Privacy Act and NPC Circular No. 16-03.

8. Data Retention

phwil retains your personal data for the following periods:

• Account data and KYC records: For the duration of your phwil account plus a minimum of 5 years following account closure, as required by Philippine AML and gaming regulatory obligations.
• Financial transaction records: Minimum 5 years from the date of the transaction, as required by the Anti-Money Laundering Act.
• Gaming activity logs: 24 months from the date of activity, or longer where required for dispute resolution or regulatory investigation purposes.
• Customer support records: 24 months from the date of the support interaction, or longer where the matter is subject to ongoing dispute or legal proceedings.
• Marketing consent records: For the period your consent remains active plus 12 months following withdrawal of consent.

Upon expiry of the applicable retention period, phwil will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9. Your Data Subject Rights

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

• Right to be informed: You have the right to be informed of how phwil processes your personal data — which this Policy fulfils.
• Right of access: You have the right to obtain a copy of the personal data phwil holds about you.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data phwil holds about you.
• Right to erasure: You have the right to request deletion of your personal data, subject to phwil's legal retention obligations.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used format.
• Right to object: You have the right to object to phwil processing your personal data for direct marketing purposes at any time.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phwil has processed your data in violation of the Data Privacy Act.

To exercise any of the above rights, contact phwil's Data Protection Officer at [email protected]. phwil will respond to data subject access requests within 15 business days.

10. Children's Privacy

The phwil Platform is strictly intended for adults aged 21 years or above, in accordance with applicable Philippine gaming age restrictions. phwil does not knowingly collect personal data from individuals under 21 years of age. If phwil becomes aware that a player is under 21, the account will be immediately suspended, all balances will be investigated, and the personal data of the underage individual will be deleted from phwil's systems in accordance with this Policy.

If you believe a minor has registered on phwil, please notify us immediately at [email protected].

11. Marketing Communications

With your consent, phwil may send you promotional communications regarding bonuses, new game releases, tournaments, and platform updates via SMS to your registered Philippine mobile number and/or email. You may withdraw your consent to marketing communications at any time by:

• Updating your communication preferences in your phwil account settings after login
• Replying "STOP" to any phwil SMS
• Contacting phwil support at [email protected]

Withdrawal of marketing consent does not affect the validity of any consent given prior to withdrawal. Essential service communications — such as transaction confirmations, security alerts, and KYC requests — are not subject to marketing consent and will continue to be sent regardless of your marketing preferences.

12. Changes to This Policy

phwil reserves the right to update or modify this Privacy Policy at any time. Material changes to this Policy will be communicated to registered players via the contact details on their phwil account, with at least 7 calendar days' notice prior to the effective date, except where immediate changes are required by law.

The current version of this Privacy Policy is always available at phwil.org/privacy-policy. Your continued use of the phwil Platform following the effective date of any amendment constitutes acceptance of the revised Policy.

13. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or phwil's handling of your personal data, please contact phwil's designated Data Protection Officer:

If you are not satisfied with phwil's response to your data privacy concern, you have the right to escalate to the National Privacy Commission of the Philippines.