Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") sets out how wnph ("wnph", "we", "us", "our") collects, uses, stores, discloses, and otherwise processes the personal data of individuals ("you", "User", "Player") who access or use the wnph online gaming platform at wnph.org, including all associated services, games, promotions, and customer support functions.

wnph respects your privacy and is committed to compliance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA) of the Philippines, its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC). This Policy applies to all personal data processed by wnph in connection with your use of the platform, whether you are a registered player, a visitor browsing wnph.org, or a person who contacts our support team.

By registering an account on wnph or by continuing to use our platform, you acknowledge that you have read and understood this Policy. If you do not agree with the terms of this Policy, please discontinue use of the wnph platform immediately.

2. Data Controller Information

wnph operates wnph.org and acts as the data controller in respect of the personal data of its players and users. As data controller, wnph determines the purposes and means of processing personal data collected through the platform. wnph's designated Data Privacy Officer (DPO) can be contacted via the details provided in Section 14 of this Policy.

3. Personal Data We Collect

wnph collects the following categories of personal data from players and users:

• Identity Data: Full legal name, date of birth, nationality, gender, and government-issued identification number (e.g., PhilSys ID, passport number, driver's licence number, UMID).
• Contact Data: Residential address (including barangay, city/municipality, province), email address, and Philippine mobile number.
• Account Data: Username, account ID, password (stored in hashed, non-reversible format), account preferences, and player tier information.
• Financial Data: Payment method details (e.g., GCash-linked mobile number, PayMaya account reference, bank account number for BPI, BDO, or Metrobank withdrawals), transaction history, deposit amounts, withdrawal amounts, and balance records.
• Gaming Data: Game session history, bet records, win/loss records, game preferences, and time spent on platform.
• Technical Data: IP address, device type and model, operating system, browser type and version, session timestamps, and geolocation data (city or region level).
• Communications Data: Records of live chat conversations, emails, and support tickets submitted to wnph customer support.
• Responsible Gaming Data: Self-exclusion status, deposit limit settings, session time limit configurations, and cooling-off period records.

4. How We Collect Your Data

wnph collects personal data through the following means:

• Direct Collection: Data you provide when registering an account, completing identity verification, making a deposit, submitting a withdrawal request, or contacting customer support.
• Automated Collection: Technical data collected automatically when you access wnph.org, including through cookies, web beacons, session tracking, and server log files.
• Third-Party Sources: Data received from payment service providers (e.g., GCash, PayMaya, BPI, BDO, Metrobank) in connection with deposit and withdrawal transactions; identity verification data from third-party Know Your Customer (KYC) service providers; and fraud prevention data from anti-money laundering (AML) screening services.

5. Purposes and Legal Bases for Processing

wnph processes your personal data for the following purposes, each supported by a lawful basis under the DPA:

• Account Registration and Management — to create, maintain, and administer your wnph account. Legal basis: performance of a contract.
• Identity Verification (KYC) — to verify your identity, age (21+), and eligibility to use the platform in compliance with PAGCOR requirements. Legal basis: compliance with a legal obligation.
• Payment Processing — to process deposits, withdrawals, and refunds in PHP via GCash, PayMaya, and bank transfer. Legal basis: performance of a contract.
• Fraud Prevention and AML Compliance — to detect, investigate, and prevent fraudulent transactions, money laundering, and other illegal activity. Legal basis: compliance with a legal obligation and legitimate interests.
• Customer Support — to respond to your queries, complaints, and requests submitted via live chat or email. Legal basis: performance of a contract.
• Responsible Gaming — to monitor gaming behaviour, enforce self-exclusion and deposit limits, and provide support to at-risk players. Legal basis: compliance with regulatory requirements and legitimate interests.
• Platform Improvement — to analyse platform usage, improve game performance, and personalise the user experience. Legal basis: legitimate interests.
• Marketing Communications — to send you promotional offers and platform updates where you have provided your consent. Legal basis: consent. You may withdraw consent at any time by contacting wnph support.

6. Disclosure of Personal Data to Third Parties

wnph does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing financial transactions on your account.
• KYC and Identity Verification Services: Third-party providers engaged to verify the identity and age of wnph account holders.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law, court order, or regulatory direction.
• IT and Security Service Providers: Third-party technology providers supporting platform infrastructure, data hosting, and cybersecurity — all bound by strict contractual data protection obligations.
• Fraud Prevention and AML Screening Services: Providers that assist wnph in detecting and preventing fraudulent or illegal activity on the platform.

7. Cookies and Tracking Technologies

wnph uses cookies and similar tracking technologies on wnph.org to deliver a functional and personalised experience. The types of cookies we use include:

• Strictly Necessary Cookies: Required for the operation of the platform, including session management, login authentication, and security functions. These cannot be disabled without affecting core platform functionality.
• Performance and Analytics Cookies: Used to collect anonymised data about how players interact with wnph.org, including pages visited and session duration, to help us improve the platform.
• Functionality Cookies: Used to remember your preferences such as language settings and game display options.

You may manage cookie preferences through your browser settings. Note that disabling certain cookies may impact the functionality of the wnph platform.

8. Data Retention

wnph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following retention guidelines:

• Account and identity data is retained for a minimum of five (5) years following the closure of your wnph account, in compliance with PAGCOR record-keeping requirements and AML obligations.
• Financial transaction records are retained for a minimum of five (5) years from the date of each transaction.
• Gaming session data is retained for three (3) years from the date of the relevant session.
• Customer support communications are retained for three (3) years from the date of the relevant interaction.
• Marketing consent records are retained until you withdraw consent or for three (3) years from the last interaction, whichever is earlier.

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

9. Data Security

wnph implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and wnph servers.
• Password hashing using bcrypt or equivalent cryptographic functions — wnph does not store plaintext passwords.
• Two-factor authentication (2FA) available to all registered players.
• Role-based access controls limiting internal staff access to personal data on a need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments of the wnph platform.
• Data breach detection and response procedures in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, wnph will notify you and the NPC within the timeframes prescribed by the DPA and its IRR.

10. Your Rights Under the Data Privacy Act

As a data subject under the Republic Act No. 10173, you are entitled to exercise the following rights in respect of your personal data held by wnph:

• Right to be Informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right to Access: You may request a copy of the personal data wnph holds about you at any time.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data on your wnph account.
• Right to Erasure or Blocking: You may request the deletion or blocking of your personal data where processing is no longer necessary, subject to wnph's legal and regulatory retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to Data Portability: You may request that your personal data be provided in a structured, commonly used, and machine-readable format.
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact the wnph Data Privacy Officer using the details in Section 14. wnph will respond to data subject requests within fifteen (15) calendar days of receipt, as required by the DPA IRR.

11. Children and Minors

wnph does not knowingly collect or process personal data of individuals under the age of 21 years. The wnph platform is strictly restricted to players aged 21 and above in accordance with Philippine gaming laws and PAGCOR regulations. Age verification is conducted as part of the account registration and KYC process.

If wnph becomes aware that personal data of an individual under 21 years of age has been collected, such data will be deleted immediately and the associated account will be closed without refund of any deposited funds, which may be subject to regulatory reporting. If you believe a minor has created an account on wnph, please contact our support team immediately.

12. Cross-Border Data Transfers

wnph primarily processes player data within the Philippines. In certain circumstances, personal data may be transferred to, or accessible by, service providers and partners located outside the Philippines — for example, where wnph uses third-party technology infrastructure or software services hosted internationally.

Where such transfers occur, wnph ensures that appropriate safeguards are in place in accordance with the DPA and NPC guidelines, including contractual data protection clauses that impose obligations on the recipient equivalent to those applicable under Philippine law.

13. Amendments to This Policy

wnph reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered players via email to the address on file and/or by a prominent notice on wnph.org. The updated Policy will take effect upon publication. Your continued use of the wnph platform following publication of a revised Policy constitutes your acknowledgement of the changes. We encourage you to review this Policy periodically. The most current version is always available at wnph.org/privacy-policy.

14. Contact and Data Privacy Officer

For any queries, requests, or complaints relating to this Privacy Policy or the processing of your personal data by wnph, please contact us through the following channels:

• Data Privacy Officer Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week via the wnph platform
• Subject line for data privacy requests: "Data Privacy Request – [Your Account Username]"

wnph will acknowledge receipt of your request within three (3) business days and provide a substantive response within fifteen (15) calendar days, in accordance with NPC requirements.