win4life Privacy Policy

1. Who We Are

win4life ("we", "us", "our", "the Company") operates the online gaming platform accessible at win4life.club. win4life is regulated by the Philippine Amusement and Gaming Corporation (PAGCOR) and operates in compliance with applicable Philippine laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

For the purposes of the Data Privacy Act, win4life acts as the Personal Information Controller in respect of the personal data of its registered Players and website visitors. This means we determine the purposes and means by which your personal data is processed.

If you have any questions about this Privacy Policy or how win4life handles your personal data, please contact our Data Protection Officer (DPO) using the details provided in Section 14 of this policy.

2. Personal Data We Collect

win4life collects the following categories of personal data from Players and website visitors:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification — you must be 21 or older);
• Residential address, including city, province, and postal code;
• Email address and mobile phone number;
• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys ID, driver's licence) submitted for KYC verification.

2.2 Financial Data

• GCash account number or registered mobile number;
• PayMaya / Maya account details;
• Philippine bank account details (account name, account number, bank name) for bank transfer transactions;
• Debit card details (card number, expiry date — stored in tokenised form only);
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used.

2.3 Gaming & Activity Data

• Game play history, including games played, wagers placed, wins, and losses;
• Bonus and promotion usage history;
• Session duration and login/logout timestamps;
• Responsible gaming tool settings (deposit limits, self-exclusion status, session reminders).

2.4 Technical & Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type and version;
• Unique device identifiers;
• Cookie data and similar tracking technologies (see Section 7).

2.5 Communications Data

• Records of your communications with our customer support team, including live chat transcripts and email correspondence;
• Feedback, complaints, and survey responses submitted to win4life.

3. How We Collect Your Data

win4life collects personal data through the following means:

• Direct collection: Data you provide when registering an Account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions;
• Automated collection: Data collected automatically when you access the Platform, including through cookies, web beacons, and server logs (see Section 7);
• Third-party sources: Data received from identity verification providers, payment processors (GCash, PayMaya, Philippine banks), fraud prevention services, and PAGCOR as required by regulation;
• Publicly available sources: In limited circumstances, data from publicly available sources may be used to verify information you have provided or to comply with anti-money laundering obligations.

4. How We Use Your Personal Data

win4life uses your personal data for the following purposes:

win4life will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, win4life processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with PAGCOR regulations, anti-money laundering laws, tax obligations, and other applicable Philippine laws;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where we have obtained your prior consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

win4life does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this policy:

• Payment processors: GCash, PayMaya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals;
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and age in compliance with PAGCOR requirements;
• Fraud prevention and AML services: Providers that help us detect and prevent fraudulent activity and money laundering;
• Regulatory authorities: PAGCOR and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation;
• IT and platform service providers: Cloud hosting, data storage, and platform infrastructure providers operating under strict data processing agreements;
• Professional advisers: Lawyers, auditors, and accountants where necessary for legal compliance or dispute resolution.

All third parties with whom win4life shares personal data are required to handle that data in accordance with applicable Philippine data privacy laws and are prohibited from using it for any purpose other than the specific service they provide to win4life.

7. Cookies & Tracking Technologies

win4life uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations to personalise your experience.
• Analytics cookies: Help us understand how Players use the Platform — which games are most popular, where users encounter difficulties, and how to improve the overall experience. Data collected is aggregated and anonymised where possible.
• Marketing cookies: Used to deliver relevant promotional content about win4life games and offers. These are only set with your prior consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of win4life.

8. Data Security

win4life implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encryption at rest for sensitive data stored in our databases, including financial information and government ID documents;
• Access controls: Personal data is accessible only to win4life staff and contractors who require it to perform their duties, and only on a need-to-know basis;
• Regular security audits and penetration testing conducted by independent security professionals;
• Two-factor authentication (2FA) available for all Player accounts and mandatory for internal staff access to systems containing personal data;
• Incident response procedures: In the event of a personal data breach, win4life will notify affected Players and the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, as required by the Data Privacy Act.

While win4life takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account credentials and for notifying us immediately if you suspect any unauthorised access to your Account.

9. Data Retention

win4life retains your personal data for the following periods:

• Account and identity data: Retained for the duration of your Account and for a minimum of five (5) years after Account closure, as required by PAGCOR regulations and anti-money laundering laws;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with Philippine financial regulations;
• Gaming activity data: Retained for three (3) years from the date of the activity, or longer if required for dispute resolution or regulatory purposes;
• Customer support communications: Retained for two (2) years from the date of the last communication;
• Marketing consent records: Retained for the duration of your consent and for one (1) year after withdrawal of consent.

When personal data is no longer required for any of the above purposes, win4life will securely delete or anonymise it in accordance with our data disposal procedures.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by win4life:

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. win4life will respond to all data subject requests within fifteen (15) business days. We may need to verify your identity before processing your request.

11. Children's Privacy & Age Restriction

win4life is strictly an adult gaming platform. We do not knowingly collect personal data from individuals under the age of 21. The minimum age to register and use the win4life Platform is 21 years, in accordance with Philippine gaming regulations.

If win4life discovers that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant Account, delete the personal data, and report the matter to PAGCOR as required. If you believe that a minor has registered on the Platform, please contact us immediately at the details provided in Section 14.

Age verification is a mandatory step in the win4life registration and KYC process. We use government-issued identification documents to confirm that all Players meet the 21+ age requirement before they are permitted to deposit funds or place wagers.

12. International Data Transfers

win4life primarily stores and processes personal data within the Philippines. In limited circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international fraud prevention services.

Where such transfers occur, win4life ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law;
• Transfers only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission;
• Your explicit consent, where required by applicable law.

13. Changes to This Privacy Policy

win4life reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, we will notify registered Players by email or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

The effective date of the current version of this Privacy Policy is clearly indicated at the top of this page. We encourage you to review this policy periodically to stay informed about how win4life protects your personal data. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised policy.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by win4life, please contact our Data Protection Officer:

• Data Protection Officer: win4life DPO
• Email: [email protected]
• General Support: [email protected]
• Response Time: Data subject requests are responded to within 15 business days of receipt.

If you are not satisfied with win4life's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.