phwen Privacy Policy

1. Introduction

phwen ("we," "us," "the Platform," "phwen") respects the privacy of every individual who interacts with our platform. This Privacy Policy is issued in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and the applicable issuances of the National Privacy Commission ("NPC").

This Policy describes the personal data we collect from players and visitors to phwen.bio, the purposes for which that data is processed, the parties with whom it may be shared, the measures we take to keep it secure, and the rights available to data subjects under Philippine law. By registering for and using the phwen platform, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

phwen acts as the personal information controller ("PIC") for data collected through phwen.bio and its related services. For purposes of the Philippine DPA, phwen is responsible for determining the means and purposes of personal data processing described in this Policy.

phwen has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with the DPA and this Policy. Contact details for the phwen DPO are provided in Section 14 of this Policy.

3. Personal Data We Collect

phwen collects the following categories of personal data in connection with your use of the Platform:

3.1 Identity & Contact Data

• Full legal name as it appears on government-issued identification;
• Date of birth (to verify that you are 21 years of age or older);
• Nationality and country of residence;
• Email address;
• Philippine mobile number;
• Registered residential address.

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine National ID, passport, driver's license, SSS/GSIS card, voter's ID);
• Proof of address documentation;
• Selfie or live photo for biometric verification where required;
• Proof of payment method ownership.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records including amounts, timestamps, and payment method references;
• GCash, PayMaya, BPI, BDO, and Metrobank account reference numbers (not full account credentials);
• Account balance history;
• Bonus and promotional credit records.

3.4 Gaming Activity Data

• Game session logs including game title, stake size, outcome, and duration;
• Betting history across all phwen product categories (slots, live casino, bingo, BetterLive Live, Triple);
• Responsible gaming settings applied to your account.

3.5 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser version;
• Login timestamps and session duration;
• Pages visited and features used within phwen;
• Cookie and analytics identifiers (see Section 9).

3.6 Communications Data

• Customer support chat transcripts and email correspondence;
• Feedback, survey responses, and complaints submitted to phwen.

4. How We Collect Your Data

phwen collects personal data through the following means:

• Directly from you: during account registration, KYC verification, deposit and withdrawal transactions, customer support interactions, and when you update your account settings;
• Automatically: through cookies, server logs, and analytics tools as you interact with phwen.bio (see Section 9);
• From third parties: identity verification service providers used to conduct KYC checks; payment processors confirming transaction details; and fraud prevention services used to screen for suspicious activity.

5. Purpose and Legal Basis for Processing

phwen processes personal data only where there is a lawful basis to do so under the Philippine DPA. The following table sets out the primary purposes of data processing and the corresponding legal basis:

Purpose	Legal Basis (DPA)
Account registration and administration	Performance of contract (Sec. 12(b))
Identity verification (KYC/AML)	Compliance with legal obligation (Sec. 12(c)); PAGCOR licensing condition
Processing deposits and withdrawals	Performance of contract (Sec. 12(b))
Providing gaming services and customer support	Performance of contract (Sec. 12(b))
Responsible gaming monitoring and intervention	Legitimate interests (Sec. 12(f)); PAGCOR regulatory obligation
Fraud prevention and security monitoring	Legitimate interests (Sec. 12(f)); legal obligation (Sec. 12(c))
Sending transactional communications (e.g., deposit confirmations)	Performance of contract (Sec. 12(b))
Sending marketing communications (where consented)	Consent (Sec. 12(a))
Platform analytics and improvement	Legitimate interests (Sec. 12(f))
Regulatory record-keeping and reporting	Legal obligation (Sec. 12(c)); PAGCOR licensing condition

6. Data Sharing and Disclosure

phwen does not sell your personal data. phwen may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash (GXI), PayMaya (Maya Bank), BPI, BDO, Metrobank, and other payment service providers, solely to process your deposit and withdrawal transactions;
• KYC and identity verification providers: third-party services used to verify your identity documents in compliance with our PAGCOR obligations and the Anti-Money Laundering Act;
• Fraud prevention and security services: providers assisting in detecting and preventing fraudulent account activity;
• Game content providers: game studios whose titles are featured on phwen, to the extent required to operate and log gameplay sessions;
• PAGCOR and Philippine government authorities: as required by our gaming license, AML regulations, and any lawful order from a Philippine court or regulatory body;
• Professional advisers: lawyers, auditors, and accountants under confidentiality obligations, where required for business operations.

All third-party service providers engaged by phwen are required to handle personal data in accordance with the Philippine DPA and to implement appropriate security measures.

7. Data Retention

phwen retains personal data for as long as necessary to fulfil the purposes for which it was collected, and in accordance with the following minimum retention periods:

• Account and KYC data: retained for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing conditions and the Anti-Money Laundering Act;
• Transaction records: retained for a minimum of five (5) years, consistent with Philippine AML requirements;
• Gaming activity logs: retained for a minimum of two (2) years for dispute resolution and regulatory audit purposes;
• Customer support records: retained for two (2) years from the date of the last interaction;
• Marketing consent records: retained for as long as the consent is active and for one (1) year following withdrawal of consent.

Following the expiry of applicable retention periods, personal data will be securely deleted or anonymized in accordance with phwen's data disposal procedures.

8. Security Measures

phwen implements technical and organizational security measures appropriate to the risk posed by the personal data we process. These include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and phwen's servers;
• Encryption of sensitive data at rest, including identity documents and payment method references;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication for internal system access;
• Regular security audits and penetration testing;
• Incident response procedures aligned with NPC breach notification requirements under the DPA.

In the event of a personal data breach that is likely to give rise to a real risk of serious harm to data subjects, phwen will notify the National Privacy Commission and affected players within the timeframes prescribed by the DPA and NPC Circular No. 16-03.

9. Cookies and Tracking Technologies

phwen uses the following categories of cookies and similar technologies on phwen.bio:

• Essential cookies: Required for the Platform to function — session authentication, account security tokens, and payment state management. These cannot be disabled without preventing Platform access.
• Analytical cookies: Used to understand aggregate usage patterns on phwen.bio (e.g., page visit counts, navigation flows, error rates). Data is processed in anonymized or pseudonymized form. These can be declined via your browser settings.
• Preference cookies: Store your language and display preferences for a more consistent experience across sessions.

phwen does not deploy third-party advertising or social media tracking cookies. You can manage your cookie preferences through your browser settings. Disabling essential cookies will affect Platform functionality.

10. 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 phwen:

• Right to be informed: You have the right to know how your personal data is being collected and processed — which this Policy fulfils;
• Right of access: You may request a copy of the personal data phwen holds about you;
• Right to rectification: You may request correction of inaccurate or incomplete personal data;
• Right to erasure: You may request deletion of your personal data, subject to phwen's legal and regulatory retention obligations;
• Right to object: You may object to processing based on legitimate interests, including direct marketing;
• Right to data portability: You may request your personal data in a structured, commonly used format;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact phwen's Data Protection Officer at the contact details in Section 14. phwen will respond to verified data subject requests within fifteen (15) calendar days, or within such extended period as permitted under the DPA and NPC regulations.

11. Children's Privacy

phwen does not knowingly collect personal data from individuals under 21 years of age. Age verification is conducted during account registration, and any account found to belong to a person under 21 will be immediately suspended in accordance with PAGCOR regulations. If phwen becomes aware that it has inadvertently collected personal data from a minor, that data will be deleted without delay. Parents or guardians who believe their child has registered with phwen should contact phwen's support team immediately.

12. Cross-Border Data Transfers

phwen's primary data storage and processing infrastructure is located within the Philippines or in jurisdictions that provide comparable data protection standards. Where personal data is transferred to a third-party service provider located outside the Philippines — for example, a KYC verification platform operating internationally — phwen ensures that appropriate contractual safeguards are in place, including data processing agreements that require the recipient to comply with standards equivalent to the Philippine DPA.

13. Changes to This Privacy Policy

phwen may update this Privacy Policy from time to time to reflect changes in legal requirements, PAGCOR regulatory guidance, or phwen's data processing practices. Material changes will be communicated to registered players via the email address on record and through a notice on the Platform. The "Effective Date" at the top of this Policy indicates when the current version took effect. Your continued use of the phwen Platform following notification of a revised Policy constitutes your acceptance of the revised terms.

14. Contact & Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact phwen's Data Protection Officer:

Email: [email protected]

Subject line: DPO – Privacy Request

Support hours: 24/7 via Live Chat on the phwen Platform

You also have the right to file a complaint directly with the National Privacy Commission of the Philippines if you believe phwen has not addressed your concern adequately.

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