Privacy Policy – win hq

1. Introduction and Scope

win hq ("win hq," "we," "us," or "our") is committed to protecting the privacy and personal data of every player and visitor who interacts with our online gaming platform at win-hq.app (the "Platform"). This Privacy Policy ("Policy") describes how win hq collects, processes, stores, shares, and safeguards your personal information in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA) of the Philippines, and its Implementing Rules and Regulations.

This Policy applies to all personal data collected through the win hq Platform, including our website, mobile-optimised interface, customer support channels, and any other services we provide. By registering an account or continuing to use the win hq Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

If you do not agree with any part of this Policy, you should discontinue use of the win hq Platform and contact us to request closure of your account.

2. Data Controller Information

For the purposes of the Data Privacy Act of 2012 and this Policy, win hq acts as the Personal Information Controller in respect of the personal data you provide when using the Platform. Our designated Data Protection Officer (DPO) can be reached through the contact details provided in Section 14 of this Policy.

win hq takes its obligations as a Personal Information Controller seriously and has implemented appropriate organisational and technical measures to ensure the security and confidentiality of all personal data under its control.

3. Personal Data We Collect

win hq collects the following categories of personal data from players and visitors:

win hq does not intentionally collect sensitive personal information as defined under the DPA (such as health data, religious beliefs, or political affiliations) unless specifically required for regulatory compliance purposes, in which case your explicit consent will be sought.

4. How We Collect Your Data

win hq collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the Platform, including cookies, web beacons, pixel tags, and server logs. See Section 7 for more details on our use of cookies.
• Third-party sources: Data received from payment processors (e.g., GCash, PayMaya), identity verification service providers, fraud prevention agencies, and analytics partners, where permitted by applicable law.
• Publicly available sources: In limited circumstances, win hq may supplement your profile with data from publicly available sources for fraud prevention or regulatory compliance purposes.

5. Purposes and Legal Basis for Processing

win hq processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

• Account management and service delivery: To create and maintain your win hq account, process transactions, and provide access to games and features. (Contractual necessity)
• Identity and age verification: To verify that you are at least 21 years of age and to confirm your identity in compliance with applicable regulations. (Legal obligation)
• Anti-money laundering (AML) and fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other financial crimes. (Legal obligation / Legitimate interest)
• Responsible gaming: To monitor gaming behaviour, enforce deposit limits, and administer self-exclusion requests. (Legal obligation / Legitimate interest)
• Customer support: To respond to your enquiries, resolve disputes, and improve our support services. (Contractual necessity / Legitimate interest)
• Marketing and promotions: To send you relevant offers, bonuses, and updates about win hq, where you have provided consent or where permitted by law. You may opt out at any time. (Consent)
• Platform improvement and analytics: To analyse usage patterns, improve game performance, and enhance the overall player experience. (Legitimate interest)
• Legal and regulatory compliance: To comply with applicable Philippine laws, regulatory requirements, and court orders. (Legal obligation)

6. Sharing and Disclosure of Personal Data

win hq does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions.
• Identity verification providers: Third-party KYC and age verification service providers engaged to assist with regulatory compliance.
• Fraud prevention and security agencies: Organisations that assist win hq in detecting and preventing fraudulent activity and ensuring platform security.
• Game software providers: Licensed game developers and content providers whose games are hosted on the win hq Platform, to the extent necessary for game operation and audit purposes.
• Regulatory and law enforcement authorities: Government agencies, regulators, and law enforcement bodies where disclosure is required by law, court order, or regulatory directive, including PAGCOR and the National Privacy Commission (NPC).
• Professional advisers: Lawyers, auditors, and consultants engaged by win hq, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the successor entity, subject to equivalent data protection commitments.

All third parties with whom win hq shares personal data are required to process such data in accordance with applicable data protection laws and win hq's data processing standards.

7. Cookies and Tracking Technologies

win hq uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather analytics data. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security tokens. These cannot be disabled.
• Performance and analytics cookies: Used to collect anonymised data about how players interact with the Platform, helping us identify areas for improvement.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalise your experience.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content and track the effectiveness of our marketing campaigns.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the win hq Platform. By continuing to use the Platform without adjusting your cookie settings, you consent to our use of cookies as described in this Policy.

8. Data Retention

win hq retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. Specific retention periods include:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing data: Retained until you withdraw your consent or opt out of marketing communications.

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

9. Data Security

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

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the win hq Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Multi-factor authentication for administrative access to systems containing personal data.
• Incident response procedures to detect, contain, and report data breaches in accordance with the requirements of the National Privacy Commission.

While win hq takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are encouraged to use a strong, unique password for your win hq account and to notify us immediately at [email protected] if you suspect any unauthorised access.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by win hq:

• Right to be informed: The right to be notified of how your personal data is being collected and processed, as set out in this Policy.
• Right of access: The right to request a copy of the personal data win hq holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure or blocking: The right to request deletion or blocking of your personal data where processing is no longer necessary or lawful, subject to applicable legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. win hq will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with the DPA and its Implementing Rules.

11. Children's Privacy

The win hq Platform is strictly intended for adults aged 21 years and above. win hq does not knowingly collect, process, or store personal data from individuals under the age of 21. If win hq becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete such data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the win hq Platform or provided us with personal data without your consent, please contact us immediately at [email protected] so that we may take appropriate action.

12. Cross-Border Data Transfers

In the course of providing our services, win hq may transfer your personal data to service providers or partners located outside the Philippines, including but not limited to game software providers, cloud infrastructure providers, and fraud prevention agencies operating in other jurisdictions.

Where such transfers occur, win hq ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that impose data protection obligations equivalent to those required under the Data Privacy Act of 2012. By using the win hq Platform, you consent to such cross-border transfers of your personal data, subject to the protections described in this Policy.

13. Changes to This Privacy Policy

win hq reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. Material changes to this Policy will be communicated to registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the win hq Platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. We encourage you to review this Policy periodically to stay informed about how win hq protects your personal data.

14. How to Contact Us

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