windph Privacy Policy

1. Introduction and Data Controller Identity

This Privacy Policy ("Policy") is issued by windph ("windph," "we," "us," or "our"), the operator of the online gaming platform accessible at windph.vip (the "Platform"). windph acts as the data controller in respect of personal data collected through the Platform and through any associated customer support or communication channels.

windph is committed to processing personal data responsibly, transparently, and in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, the issuances of the National Privacy Commission ("NPC"), and applicable PAGCOR regulations governing online gaming operators in the Philippines.

This Policy applies to all registered players and visitors of the windph Platform. By creating a windph account or continuing to use the Platform, you acknowledge that you have read and understood this Policy.

2. Personal Data We Collect

windph collects the following categories of personal data from players and prospective players:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., passport number, PhilSys number, SSS/GSIS number, driver's licence number).
• Contact Data: Mobile phone number (Philippine mobile number required for OTP verification), email address, and residential address (province, city/municipality, barangay).
• Account Data: Username, hashed password, account registration date, login history, session records, and account preferences.
• Financial Data: GCash-registered mobile number (for payment verification purposes), bank account name and number (for withdrawal processing), deposit and withdrawal transaction records, and account balance history. windph does not store full GCash PINs or online banking passwords.
• Verification Data: Copies of government-issued identification documents and supporting documents submitted during Know Your Customer (KYC) verification.
• Gameplay and Betting Data: Game session records, wagering history, game preferences, bonus usage records, and responsible gaming tool settings.
• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and mobile network provider.
• Communications Data: Records of your communications with windph support via live chat, email, Viber, or Facebook Messenger, including support ticket contents and resolution records.

3. How We Collect Your Data

windph collects personal data through the following means:

• Directly from you — when you register a windph account, complete KYC verification, make a deposit or withdrawal, contact support, or respond to surveys or promotions.
• Automatically through your use of the Platform — via server logs, session cookies, and similar technologies that record your IP address, device identifiers, and navigation patterns when you access windph.
• From third-party payment processors — when you initiate a GCash, PayMaya, or bank transfer transaction, our payment processing partners transmit transaction confirmation data and your registered payment account name to windph for verification purposes.
• From identity verification service providers — windph may engage accredited third-party KYC service providers to assist with document verification and identity authentication, as required by PAGCOR anti-money laundering guidelines.

4. Legal Basis for Processing

windph processes your personal data on the following legal bases as recognised under the DPA:

• Contractual necessity — Processing is necessary to perform the contract between you and windph (i.e., providing access to the Platform, processing deposits and withdrawals, and maintaining your account).
• Compliance with a legal obligation — windph is required under Philippine law, PAGCOR regulations, and Anti-Money Laundering Act (AMLA) obligations to collect, verify, and retain certain personal data.
• Legitimate interests — windph processes certain data (e.g., technical logs, fraud signals) to protect the security and integrity of the Platform, detect cheating or abuse, and improve Platform performance, provided such interests do not override your fundamental rights.
• Consent — Where windph seeks to use your data for purposes not covered above (e.g., optional marketing communications), we will request your explicit, informed, and freely given consent and provide a clear mechanism to withdraw it.

5. How We Use Your Personal Data

windph uses collected personal data for the following purposes:

• Creating, verifying, and maintaining your windph account in compliance with PAGCOR age and identity requirements. 21+
• Processing deposits and withdrawal requests via GCash, PayMaya, BDO, BPI, and Metrobank, including verifying payment method ownership.
• Conducting KYC and anti-money laundering (AML) checks as required by Philippine law and PAGCOR regulations.
• Detecting and preventing fraud, cheating, collusion, money laundering, and unauthorised account access.
• Providing customer support and resolving disputes or complaints.
• Administering bonuses, promotions, and loyalty programs in accordance with their respective terms.
• Enforcing windph's Terms & Conditions and Responsible Gaming Policy, including processing self-exclusion requests.
• Analysing aggregated, anonymised Platform usage data to improve game offerings, user experience, and Platform performance.
• Sending you transactional communications (account confirmations, withdrawal notifications, security alerts) via SMS or email.
• Sending promotional communications (bonus offers, new game announcements) where you have provided consent and have not subsequently opted out.

6. Sharing and Disclosure of Data

windph does not sell, rent, or trade your personal data to any third party for their own commercial purposes. windph may share your data only in the following limited circumstances:

• Payment processors: GCash (Globe Fintech Innovations, Inc.), PayMaya Philippines, Inc., BDO Unibank, Bank of the Philippine Islands, and Metrobank, solely for the purpose of processing your transactions.
• KYC and identity verification service providers: Accredited third-party providers engaged to verify identity documents during the KYC process, subject to data processing agreements.
• Game content providers: Third-party game studios that supply content to the windph Platform may receive anonymised session identifiers for gameplay integrity verification; they do not receive your identity or financial data.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities, where windph is legally required to disclose information.
• Professional advisers: Lawyers, auditors, and compliance consultants acting under professional confidentiality obligations, where reasonably necessary for windph's legal and compliance obligations.
• Business successors: In the event of a merger, acquisition, or sale of the windph business, personal data may be transferred to the successor entity, subject to equivalent privacy protections and prior notice to affected players.

All third parties with whom windph shares personal data are required to process it only for the specified purpose and in accordance with windph's instructions and applicable Philippine data protection law.

7. Data Retention

windph retains personal data only 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.

Specifically:

• Account and KYC data is retained for the duration of your active windph account and for a minimum of five (5) years after account closure, in compliance with AMLA record-keeping requirements.
• Transaction records (deposits, withdrawals, bet history) are retained for a minimum of five (5) years after the date of the transaction.
• Support communications are retained for up to three (3) years from the date of the interaction.
• Technical and log data (IP addresses, session logs) is retained for up to twelve (12) months, unless required for longer periods in connection with a fraud investigation or legal proceeding.
• Marketing consent records are retained until you withdraw consent or for three (3) years from the date of consent, whichever is earlier.

Upon expiry of the applicable retention period, windph will securely delete or anonymise your personal data.

8. Cookies and Tracking Technologies

windph uses the following types of cookies and similar technologies on the Platform:

• Strictly necessary cookies: Required for the Platform to function, including session authentication, login state management, and fraud prevention signals. These cannot be disabled without affecting Platform functionality.
• Performance and analytics cookies: Collect anonymised information about how players use the Platform (e.g., most visited pages, error frequencies) to help windph improve performance. These do not identify individual players.
• Preference cookies: Remember your language preferences, game lobby view settings, and other personalisation choices.

windph does not deploy third-party advertising or behavioural tracking cookies that profile your activities across external websites. You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may prevent some features of the windph Platform from functioning correctly.

9. Your Rights Under the DPA

As a data subject under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by windph:

• Right to be informed — You have the right to know whether windph holds personal data about you and how it is being processed.
• Right of access — You may request a copy of the personal data windph holds about you, along with information about the purposes and legal basis for processing.
• Right to rectification — You may request correction of inaccurate or incomplete personal data. Some corrections (e.g., registered name) may require supporting documentation.
• Right to erasure or blocking — You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to windph's legal retention obligations under AMLA and PAGCOR regulations.
• Right to object — You may object to processing of your personal data for direct marketing purposes at any time, without providing reasons.
• Right to data portability — You may request a structured, machine-readable copy of personal data you have provided to windph where technically feasible.
• Right to file a complaint — You have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe windph has violated your data privacy rights.

To exercise any of these rights, contact windph's Data Protection Officer via live chat or at [email protected]. windph will respond to verified requests within fifteen (15) business days.

10. Data Security

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

• TLS (Transport Layer Security) encryption for all data transmitted between your device and windph servers.
• Hashing of passwords using industry-standard algorithms — plain-text passwords are never stored by windph.
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need.
• Regular security audits and vulnerability assessments of the windph Platform and supporting infrastructure.
• Optional two-factor authentication (2FA) via SMS OTP for player accounts, strongly recommended for all users.

Despite these measures, no data transmission over the internet or storage system can be guaranteed as 100% secure. windph will notify affected players and the NPC in accordance with mandatory data breach notification requirements under the DPA if a breach is determined to pose a real risk of serious harm.

11. Children and Minors

The windph Platform is strictly intended for adults aged twenty-one (21) years and above. 21+ windph does not knowingly collect personal data from any person under the age of 21. Age verification is performed at registration, and windph reserves the right to request additional proof of age at any time.

If windph discovers that personal data has been collected from a person under the age of 21 without verified parental consent, such data will be deleted immediately and the account will be suspended. If you believe a minor has registered on the windph Platform, please contact support immediately via live chat.

12. Changes to This Policy

windph may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory guidance. Material changes will be communicated to registered players via the email or mobile number associated with their windph account, or by prominent notice on the Platform, at least seven (7) days before the changes take effect where practicable.

The "Last updated" date at the top of this Policy indicates when the most recent revision was made. Continued use of the windph Platform after the effective date of a revised Policy constitutes acceptance of the updated terms.

13. Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or windph's handling of your personal data, please contact our Data Protection Officer through the following channels:

• Live Chat: Available 24/7 on the windph Platform. Average response time: 3–5 minutes.
• Email (DPO): [email protected] — please include "Privacy Request" in your subject line. Response within 15 business days.

© 2026 windph. All rights reserved. This Privacy Policy applies exclusively to the windph platform at windph.vip and is governed by the laws of the Republic of the Philippines.