win4life Privacy Policy

The personal information controller in respect of your personal data is the operator of win4life, operating the Platform at win4life.win under PAGCOR licensing authority in the Republic of the Philippines ("win4life," "we," "us," "our").

For all data privacy inquiries, requests to exercise data subject rights, and notifications of suspected data breaches, you may contact our Data Protection Officer (DPO) at:

Win4life is registered with the National Privacy Commission of the Philippines as a personal information controller in accordance with the requirements of Republic Act No. 10173 and NPC Circular 17-01.

Win4life collects the following categories of personal data:

2.1 Registration & Identity Data. When you create a win4life Account, we collect your full legal name, date of birth, gender, nationality, residential address (including barangay, city/municipality, province), email address, and mobile phone number. You may be asked to provide this information in the context of Metro Manila, Cebu City, Davao City, or other Philippine addresses as part of our KYC process.

2.2 Identity Verification (KYC) Data. To comply with PAGCOR regulations and anti-money laundering requirements, we collect government-issued identification documents such as PhilSys National ID, SSS/GSIS ID, Passport, Driver's Licence, or UMID. We may also collect a selfie photograph for liveness verification and a utility bill or bank statement as proof of address.

2.3 Financial Data. We collect information related to deposits and withdrawals, including GCash account reference numbers, Maya (PayMaya) account identifiers, bank account details (account name, bank name, last four digits), and Visa/Mastercard card details (name on card, card number last four digits, expiry). Full card numbers are processed exclusively by PCI-DSS-compliant payment processors and are not stored by win4life.

2.4 Gaming Activity Data. We maintain records of all game sessions, bet amounts, win/loss outcomes, game types played, session timestamps, and active bonus status on the win4life Platform.

2.5 Technical & Device Data. When you access win4life, we automatically collect your IP address, browser type and version, operating system, device type and identifier, screen resolution, referring URL, and session timestamps.

2.6 Communications Data. We retain records of live chat transcripts, email correspondence, and support ticket interactions between you and win4life's customer support team.

2.7 Responsible Gaming Data. If you use win4life's responsible gaming tools — including deposit limits, loss limits, session time limits, or self-exclusion — we record the parameters you set and the dates on which they are applied or modified.

Win4life processes your personal data for the following purposes:

• Account Creation & Management: To register, verify, and maintain your win4life Account, including processing your win4life Login credentials securely;
• KYC & Regulatory Compliance: To verify your identity and age (21+), comply with PAGCOR licensing conditions, and meet anti-money laundering obligations under RA 9160 (AMLA), as amended;
• Payment Processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, GrabPay, InstaPay, PesoNet, 7-Eleven CLiQQ, and card networks;
• Game Provision: To deliver and operate the game services available on the win4life Platform, personalise your game lobby, and manage your session state;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance via live chat and email;
• Responsible Gaming: To implement and monitor the responsible gaming tools you activate on your Account, and to comply with any PAGCOR-mandated player protection obligations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, account compromise, collusion, bonus abuse, and other prohibited activities;
• Marketing & Promotions: Where you have given explicit consent, to send you information about win4life promotions, bonuses, game launches, and relevant offers via email or SMS. You may withdraw consent at any time;
• Platform Analytics: To analyse Platform usage patterns, improve user experience, and develop new features based on aggregated, anonymised insights.

Win4life processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between win4life and the Account Holder (i.e., to provide gaming services, process payments, and manage your Account);
• Legal Obligation: Processing is required to comply with PAGCOR licensing conditions, RA 9160 (Anti-Money Laundering Act), RA 10173 (Data Privacy Act), and other applicable Philippine law;
• Legitimate Interests: Processing is necessary for win4life's legitimate interests in fraud prevention, platform security, and responsible gaming compliance, where such interests are not overridden by your rights;
• Consent: For optional processing activities such as direct marketing communications, win4life relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting prior lawful processing.

Win4life uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device that help us recognise you, maintain your session, and improve your experience.

Strictly Necessary Cookies are required for the Platform to function. They maintain your win4life Login session state, preserve your game progress, and ensure Platform security. These cannot be disabled.

Functional Cookies remember your preferences such as language settings, responsible gaming tool configurations, and game lobby filters.

Analytics Cookies collect anonymised, aggregated data about how players navigate the win4life Platform, which pages are most visited, and where errors occur. This data is used solely to improve the Platform.

Win4life does not sell, rent, or trade your personal data to unaffiliated third parties for their own commercial purposes. We share your data only in the following circumstances:

• Payment Processors: GCash, Maya (PayMaya), BPI, BDO, Metrobank, GrabPay, InstaPay, PesoNet, and card network processors receive the minimum financial data necessary to execute transactions;
• Game Software Suppliers: Game providers such as Evolution Gaming, Pragmatic Play, PG Soft, and Jili Games may receive your Account ID and session data necessary to operate their games within the win4life Platform. These providers are contractually prohibited from using this data for their own marketing;
• PAGCOR & Regulatory Authorities: Win4life shares player data with PAGCOR as required by our operating licence, and with the Anti-Money Laundering Council (AMLC) as required by RA 9160;
• Law Enforcement: In response to a valid court order, subpoena, or lawful request from Philippine law enforcement authorities;
• Service Providers: Identity verification providers, cloud hosting services, customer support platform operators, and fraud detection technology providers acting as data processors under written data processing agreements with win4life, subject to equivalent data protection obligations;
• Corporate Transactions: In the event of a merger, acquisition, or sale of win4life business assets, personal data may be transferred to the acquiring entity subject to the same privacy protections described in this Policy.

Certain win4life service providers and game software suppliers operate infrastructure outside of the Philippines. Where personal data is transferred outside Philippine territory, win4life ensures that such transfers are protected by contractual safeguards equivalent to those required under RA 10173, including standard contractual clauses approved by the National Privacy Commission or equivalent data protection authorities.

Win4life will not transfer your personal data to any jurisdiction that does not provide an adequate level of data protection without your explicit consent or without implementing appropriate contractual safeguards.

Win4life retains your personal data for as long as your Account is active and for a period thereafter as required by applicable law or regulatory obligation:

• Account & KYC Data: Retained for a minimum of five (5) years following Account closure, as required by PAGCOR licensing conditions and AMLA record-keeping obligations;
• Financial Transaction Records: Retained for a minimum of five (5) years following each transaction, as required by RA 9160 (AMLA);
• Gaming Activity Logs: Retained for a minimum of three (3) years following the relevant session;
• Customer Support Records: Retained for three (3) years from the date of the relevant interaction;
• Marketing Consent Records: Retained for the duration of the consent and for three (3) years following withdrawal of consent.

Upon expiry of the applicable retention period, win4life will securely delete or anonymise your personal data in accordance with its data disposal procedures.

As a data subject under the Philippines' Data Privacy Act of 2012, you have the following rights with respect to your personal data held by win4life:

• Right to be Informed: To be told what personal data win4life collects, for what purpose, and the basis for processing — which is the purpose of this Policy;
• Right of Access: To request a copy of the personal data win4life holds about you, and information about how it is processed;
• Right to Rectification: To request correction of inaccurate or incomplete personal data;
• Right to Erasure or Blocking: To request deletion or blocking of your personal data where processing is unlawful or the data is no longer necessary for the original purpose, subject to win4life's legal retention obligations;
• Right to Object: To object to processing of your personal data, particularly for direct marketing purposes. Withdrawal of consent for marketing does not affect the lawfulness of prior processing;
• Right to Data Portability: To receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller;
• Right to Lodge a Complaint: To file a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, contact win4life's DPO at support@win4life.win with the subject line "Data Privacy Request." Win4life will respond to verified requests within fifteen (15) working days in accordance with NPC guidelines.

Win4life implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit, including the win4life Login process and all financial transactions;
• AES-256 encryption for sensitive data at rest, including KYC documents and financial account references;
• Role-based access controls restricting employee access to personal data to those with a documented operational need;
• Multi-factor authentication for all win4life staff accounts with access to production data systems;
• Regular penetration testing and vulnerability assessments conducted by independent third-party security firms;
• PCI-DSS compliant card payment processing — full card numbers are never stored by win4life directly;
• Incident response procedures for detecting, containing, and reporting personal data breaches to the NPC within 72 hours of discovery as required by NPC Circular 16-03.

The win4life Platform is strictly intended for persons who are 21 years of age or older, in compliance with PAGCOR regulations and Philippine law. Win4life does not knowingly collect personal data from persons under 21 years of age. If win4life becomes aware that an Account has been registered by a person under 21, or that personal data has been collected from such a person, win4life will immediately close the Account, forfeit any balances in accordance with PAGCOR guidelines, and delete the associated personal data.

If you believe that a person under 21 has registered on the win4life Platform, please notify our DPO immediately at support@win4life.win.

12.1 Changes to this Policy. Win4life may update this Privacy Policy from time to time to reflect changes in our processing practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, win4life will notify registered Account Holders via the email address on their Account at least seven (7) days before the updated Policy takes effect. The "Last Updated" date at the top of this Policy will be revised accordingly. Continued use of the win4life Platform after the effective date of the updated Policy constitutes acceptance of the changes.

12.2 Contact. For any questions, concerns, or requests relating to this Privacy Policy or win4life's data processing activities, please contact:

Win4life is committed to resolving all data privacy concerns promptly and transparently, in a manner consistent with our obligations under the Data Privacy Act of 2012 and our duties to the Filipino players who trust us with their personal information.