Privacy Policy

1. Introduction

phlwen ("phlwen," "we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who use the phlwen platform (the "Platform"). This Privacy Policy ("Policy") describes how phlwen collects, uses, stores, shares, and protects your personal information when you access or use the Platform, including when you register an account, make deposits or withdrawals, place bets, participate in promotions, or contact our support team.

This Policy is intended to comply with the Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission. By accessing or using the phlwen Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

If you do not agree with the terms of this Policy, please do not use the phlwen Platform. For questions or concerns, please contact us at [email protected].

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2. Personal Data We Collect

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

Identity and Contact Data:

• Full legal name
• Date of birth
• Residential address (including city, province, and postal code)
• Email address
• Philippine mobile number
• Government-issued identification document details (e.g., driver's license, Philippine passport, PhilSys National ID, SSS ID, UMID)

Financial Data:

• GCash account details
• PayMaya account details
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks)
• Transaction history, including deposits, withdrawals, and wager records

Technical and Usage Data:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Login timestamps and session duration
• Pages visited, games played, and features used on the Platform
• Cookies and similar tracking technology data (see Section 9)

Communications Data:

• Records of your communications with phlwen support, including chat logs and email correspondence
• Survey responses and feedback submitted through the Platform

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3. How We Collect Your Data

phlwen collects your personal data through the following means:

• Direct collection: When you register an account, complete your player profile, submit KYC documents, make a deposit or withdrawal, contact support, or participate in a promotion.
• Automated collection: Through cookies, web beacons, log files, and similar technologies when you access and use the Platform. See Section 9 for more details on our use of cookies.
• Third-party sources: From identity verification service providers, payment processors (such as GCash and PayMaya), and fraud prevention partners, where necessary to verify your identity or process transactions.

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4. How We Use Your Personal Data

phlwen uses your personal data for the following purposes:

• Account management: To register and maintain your phlwen player account, verify your identity, and manage your account settings and preferences.
• Service delivery: To provide access to games, sports betting markets, and all other features of the phlwen Platform.
• Transaction processing: To process deposits, withdrawals, and other financial transactions via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Legal compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, know-your-customer (KYC) requirements, and reporting obligations to relevant regulatory authorities.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming behavior and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer support: To respond to your inquiries, complaints, and support requests.
• Marketing and promotions: To send you information about phlwen promotions, bonuses, and new features, where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyze usage patterns and improve the design, functionality, and performance of the phlwen Platform.

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5. Legal Basis for Processing

phlwen 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 you and phlwen (i.e., to provide the Platform services you have registered for).
• Legal obligation: Processing is necessary to comply with applicable Philippine laws and regulations, including AML and KYC requirements.
• Legitimate interests: Processing is necessary for phlwen's legitimate interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and interests.
• Consent: Where required by law, phlwen will obtain your explicit consent before processing your personal data for specific purposes, such as direct marketing communications.

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6. Data Sharing and Disclosure

phlwen does not sell, rent, or trade your personal data to third-party marketers. phlwen 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, to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and identity verification service providers engaged by phlwen to verify your identity and age.
• Fraud prevention and security partners: Service providers that assist phlwen in detecting and preventing fraud, money laundering, and other prohibited activities.
• Technology and infrastructure providers: Cloud hosting, data storage, and platform technology providers that support the operation of the phlwen Platform.
• Regulatory and law enforcement authorities: Where required by applicable Philippine law, court order, or regulatory requirement, phlwen may disclose your personal data to government agencies, law enforcement authorities, or regulatory bodies, including PAGCOR and the Anti-Money Laundering Council (AMLC).
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by phlwen in connection with the operation of its business.

All third parties with whom phlwen shares personal data are required to maintain appropriate technical and organizational security measures and to process your data only for the purposes for which it was shared.

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7. Data Retention

phlwen retains your personal data for as long as your player account remains active and for such additional period as is necessary to comply with applicable legal obligations. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Communications data is retained for a period of two (2) years from the date of the communication.
• Technical and usage data collected via cookies and log files is retained for a period of up to twelve (12) months.

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

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8. Data Security

phlwen implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the phlwen Platform.
• Encryption of sensitive data at rest, including financial data and government ID details.
• Role-based access controls limiting access to personal data to authorized phlwen personnel on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform.
• 24/7 monitoring of the Platform for suspicious activity and potential security incidents.
• Staff training on data protection and information security best practices.

While phlwen takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phlwen will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

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9. Cookies and Tracking Technologies

phlwen uses cookies and similar tracking technologies (such as web beacons and pixel tags) on the Platform. Cookies are small text files placed on your device when you visit the Platform. They help phlwen recognize your device, keep you logged in, remember your preferences, and analyze how the Platform is used.

phlwen uses the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Functional cookies: These cookies remember your preferences and settings (such as language and display preferences) to provide a more personalized experience on the Platform.
• Analytics cookies: These cookies collect anonymized information about how players use the Platform, such as which pages are visited most frequently and how players navigate between pages. This data helps phlwen improve the Platform's design and performance.
• Marketing cookies: These cookies are used to deliver promotional content and offers that are relevant to your interests, based on your activity on the Platform. You may opt out of marketing cookies through your account settings.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phlwen Platform.

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10. Your Data Rights

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

• Right to be informed: You have the right to be informed about how phlwen collects and processes your personal data, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data that phlwen holds about you.
• Right to rectification: You have the right to request that phlwen correct any inaccurate or incomplete personal data it holds about you.
• Right to erasure: You have the right to request that phlwen delete your personal data, subject to applicable legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You have the right to request that phlwen provide your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe that phlwen has violated your data privacy rights.

To exercise any of these rights, please contact phlwen at [email protected]. phlwen will respond to your request within thirty (30) days of receipt. phlwen may request proof of identity before processing your request.

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11. Children's Privacy

The phlwen Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. phlwen does not knowingly collect personal data from individuals under the age of 21. If phlwen becomes aware that it has inadvertently collected personal data from a person under 21, it will take immediate steps to delete that data and close the associated account. If you believe that phlwen may have collected data from a minor, please contact us immediately at [email protected].

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12. International Data Transfers

phlwen primarily stores and processes your personal data within the Philippines. In certain circumstances, your personal data may be transferred to and processed by service providers located outside the Philippines, such as cloud infrastructure providers or technology partners. Where such transfers occur, phlwen ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012, including contractual data protection clauses with the relevant service providers.

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13. Changes to This Privacy Policy

phlwen reserves the right to update or amend this Privacy Policy at any time. When material changes are made, phlwen will post a notice on the Platform and update the "Last Updated" date at the top of this Policy. Where required by law, phlwen will seek your consent before implementing material changes to how your personal data is processed. Your continued use of the phlwen Platform following the posting of any changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to stay informed about how phlwen protects your data.

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14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or phlwen's data practices, please contact our Data Protection Officer:

• Email: [email protected]
• Support Hours: 24 hours a day, 7 days a week

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. For more information, visit the NPC's official resources.