phwi Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") applies to all personal data collected and processed by phwi ("phwi," "we," "us," or "our") in connection with your use of the phwi website at https://phwi.bio and all associated services, games, features, and communications (collectively, the "Platform").

By registering a phwi account, accessing the Platform, or otherwise providing personal information to us, you acknowledge that you have read and understood this Policy. If you do not agree with the practices described herein, you must not use the phwi Platform.

This Policy should be read alongside the phwi Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. phwi processes personal data of players located in the Republic of the Philippines and is committed to compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

2. Data Controller

For the purposes of applicable data protection law, phwi is the data controller in respect of personal data collected through the Platform. This means phwi determines the purposes for which, and the means by which, your personal data is processed.

If you have any questions about how phwi handles your personal data, or if you wish to exercise your data subject rights, you may contact our designated Data Privacy Officer (DPO) at: [email protected].

3. Personal Data We Collect

phwi may collect and process the following categories of personal data:

• Identity Data: full legal name, date of birth, nationality, government-issued identification number (e.g., Philippine National ID, passport, SSS/GSIS number), and selfie or photograph for KYC purposes;
• Contact Data: Philippine mobile number, email address, and residential address (city, province);
• Financial Data: GCash account number, Maya account number, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records;
• Account Data: username, encrypted password, account registration date, account status, login history, and IP address at login;
• Gaming Data: game session records, bet amounts, game outcomes, bonus utilisation, and win/loss history;
• Device and Technical Data: IP address, browser type and version, device type, operating system, screen resolution, and referring URL;
• Communications Data: records of support interactions, live chat transcripts, and any correspondence you send to phwi;
• Responsible Gaming Data: self-imposed deposit limits, session time restrictions, self-exclusion status, and cooling-off period records.

4. How We Collect Your Data

phwi collects personal data through the following channels:

• Direct collection: data you provide when registering your phwi account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: data collected automatically as you use the Platform, including cookies, server logs, and analytics tools that record your interactions with our pages and games;
• Third-party sources: identity verification data from KYC service providers; payment confirmation data from GCash, Maya, and other payment processors; fraud detection data from anti-money laundering screening services.

5. Purposes and Legal Bases for Processing

phwi processes your personal data for the following purposes and on the following legal bases under the Philippine Data Privacy Act:

• Contract performance: to create and manage your phwi account, process deposits and withdrawals, deliver games, and fulfil our obligations under the Terms & Conditions;
• Legal obligation: to comply with KYC, AML, and tax reporting requirements under Philippine law, including directives from AMLC and other competent authorities;
• Legitimate interests: to detect and prevent fraud, unauthorised account access, and abuse of the Platform; to analyse usage patterns and improve the Platform; to manage responsible gaming obligations;
• Consent: to send you promotional communications about phwi bonuses, new games, and special offers, where you have opted in to receive such communications. You may withdraw this consent at any time by contacting support.

6. Sharing of Personal Data

phwi does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only where necessary and on a strictly need-to-know basis:

• Payment processors: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), GrabPay, BPI, BDO, Metrobank, and other financial institutions as required to process your transactions;
• Identity verification providers: third-party KYC service providers engaged to verify your identity documents and biometric data in compliance with AML regulations;
• Game software providers: JILI, PG Soft, Pragmatic Play, and other licensed game studios may receive session and wagering data as required for game operation and integrity;
• Regulatory and law enforcement authorities: AMLC, NBI, PNP, and other Philippine government bodies where phwi is legally required to disclose information;
• IT and infrastructure service providers: cloud hosting and cybersecurity vendors who process data on phwi's behalf under data processing agreements.

All third parties with whom phwi shares personal data are required to handle such data in accordance with applicable data protection laws and phwi's data protection standards.

7. Data Retention

phwi retains personal data only for as long as is necessary for the purposes for which it was collected, and in accordance with applicable legal obligations:

• Account and transaction records are retained for a minimum of five (5) years following account closure, as required by Philippine AML regulations;
• KYC verification documents are retained for five (5) years following the end of the business relationship;
• Gaming session data is retained for three (3) years for dispute resolution and regulatory compliance purposes;
• Marketing consent records are retained until consent is withdrawn, plus one (1) year thereafter for compliance demonstration.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with phwi's data disposal procedures.

8. Cookies and Tracking Technologies

phwi uses cookies and similar tracking technologies on the Platform to facilitate essential functionality, improve performance, and analyse user behaviour. The categories of cookies we use are:

• Strictly necessary cookies: required for the Platform to function, including session management, authentication, and security. These cannot be disabled.
• Functional cookies: remember your preferences such as language settings and login state to improve your experience across sessions;
• Analytics cookies: collect aggregated, anonymised data about how players use the Platform to help phwi identify areas for improvement. phwi uses industry-standard analytics tools for this purpose;
• Session recording: anonymised session playback may be used to identify usability issues. No personally identifiable information is recorded in session replays.

You may control non-essential cookies through your browser settings. Note that disabling cookies may affect the functionality of certain features on the phwi Platform.

9. Security of Your Personal Data

phwi implements appropriate technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and phwi servers;
• Encryption of sensitive data at rest, including financial account details and government ID numbers;
• Role-based access controls ensuring that only authorised phwi personnel can access personal data relevant to their function;
• Regular security audits and penetration testing of the Platform infrastructure;
• Two-factor authentication (2FA) available to all phwi account holders to protect account access.

Despite these measures, no internet-based platform can guarantee absolute security. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, phwi will notify the National Privacy Commission (NPC) and affected players in accordance with the Data Privacy Act.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by phwi:

• Right to be informed: to know whether phwi holds your personal data and to receive a copy of this Privacy Policy;
• Right of access: to request a copy of the personal data phwi holds about you;
• Right to rectification: to request correction of inaccurate or incomplete personal data;
• Right to erasure: to request deletion of your personal data where phwi no longer has a lawful basis for processing it, subject to overriding legal retention obligations;
• Right to object: to object to processing of your personal data for direct marketing purposes at any time;
• Right to data portability: to receive a copy of personal data you have provided in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: to file a complaint with the National Privacy Commission (NPC) if you believe phwi has violated your data privacy rights.

To exercise any of these rights, contact phwi's Data Privacy Officer at [email protected]. phwi will respond to all data subject requests within thirty (30) calendar days.

11. Children and Minors

The phwi Platform is strictly for persons aged 21 years and above. phwi does not knowingly collect personal data from individuals below the age of 21. If phwi becomes aware that personal data has been collected from a person under 21, it will take immediate steps to delete such data and close the associated account.

If you are a parent or guardian and believe your minor child has created a phwi account or provided personal data to phwi, please contact our support team immediately at [email protected].

12. Changes to This Privacy Policy

phwi may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or Platform features. Where changes are material, phwi will provide advance notice via email to your registered address or via a prominent notice on the Platform prior to the effective date of the revised Policy.

Your continued use of the phwi Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically.

13. Contact and Complaints

For any queries, data subject access requests, or complaints relating to the handling of your personal data by phwi, please contact our Data Privacy Officer:

Email: [email protected]

phwi is committed to resolving all data privacy concerns promptly and transparently. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.