MaxWinPH Privacy Policy

1 Introduction

MaxWinPH ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all individuals who use our online gaming platform. This Privacy Policy describes how MaxWinPH collects, uses, stores, shares, and protects your personal information when you access or use the MaxWinPH website, mobile application, and all associated services (collectively, the "Services").

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines, and its Implementing Rules and Regulations. MaxWinPH acts as the personal information controller in respect of the personal data it collects from users of the platform.

This Privacy Policy should be read together with our Terms & Conditions, which govern your use of the MaxWinPH platform. By registering an account or otherwise using our Services, you confirm your acceptance of this Privacy Policy in full.

2 Personal Data We Collect

MaxWinPH collects the following categories of personal data from users of the platform:

Registration and Identity Data:

• Full legal name
• Date of birth (used to verify that you are 21 years of age or older, as required under Philippine law)
• Email address
• Mobile phone number
• Residential address, including city (e.g., Manila, Cebu, Davao, Quezon City, Makati) and province
• Username and encrypted password

Identity Verification (KYC) Data:

• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's licence, UMID)
• Proof of address documents
• Selfie or photograph for identity verification purposes

Financial Data:

• Payment method details (e.g., GCash account number, PayMaya account, BPI, BDO, or Metrobank account details)
• Transaction history, including deposits, withdrawals, and bonus activity

Technical and Usage Data:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, features used, and time spent on the platform
• Game history and wagering activity
• Cookie identifiers and session data

Communications Data:

• Records of your communications with MaxWinPH customer support
• Feedback, complaints, and survey responses

3 How We Collect Your Data

MaxWinPH collects personal data through the following means:

• Directly from you: When you register an account, complete identity verification, make a deposit or withdrawal, contact customer support, or respond to a survey or promotion.
• Automatically: When you access and use the MaxWinPH platform, we automatically collect technical and usage data through cookies, web beacons, log files, and similar tracking technologies.
• From third-party payment providers: When you make a deposit or withdrawal via GCash, PayMaya, BPI, BDO, or Metrobank, we may receive confirmation and transaction reference data from those providers.
• From identity verification services: MaxWinPH may use third-party KYC and identity verification service providers to assist in verifying the identity and age of players. These providers may share verification results and associated data with us.
• From fraud prevention and security services: We may receive data from third-party fraud detection and security monitoring services to help protect the integrity of the MaxWinPH platform.

4 How We Use Your Personal Data

MaxWinPH uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and manage your MaxWinPH player account, including processing your registration and verifying your identity.
• Age verification: To confirm that you are at least 21 years of age, as required under Philippine law governing casino-style gambling.
• Service delivery: To provide you with access to our games, process your deposits and withdrawals, and deliver the full range of MaxWinPH services.
• Customer support: To respond to your enquiries, complaints, and support requests in a timely and effective manner.
• Regulatory compliance: To comply with our obligations under Philippine anti-money laundering laws, data protection laws, and any applicable gaming regulations, including Know Your Customer (KYC) requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the platform.
• Responsible gaming: To monitor gaming activity and identify players who may be exhibiting signs of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Platform improvement: To analyse usage patterns, conduct research, and improve the functionality, performance, and user experience of the MaxWinPH platform.
• Marketing communications: To send you promotional offers, bonuses, and news about MaxWinPH, where you have consented to receive such communications. You may opt out of marketing communications at any time.
• Legal proceedings: To establish, exercise, or defend legal claims where necessary.

5 Legal Basis for Processing

MaxWinPH processes your personal data on the following legal bases under the Data Privacy Act of 2012 of the Philippines:

• Contractual necessity: Processing is necessary to perform our contract with you — that is, to provide you with access to the MaxWinPH platform and its services.
• Legal obligation: Processing is necessary to comply with our legal obligations under Philippine law, including anti-money laundering regulations, KYC requirements, and gaming regulations.
• Legitimate interests: Processing is necessary for the legitimate interests of MaxWinPH, including fraud prevention, platform security, and improving our services, provided that such interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent as the legal basis for processing — for example, for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

MaxWinPH does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, solely to facilitate your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers engaged to assist MaxWinPH in verifying player identities.
• IT and platform service providers: Cloud hosting, data storage, cybersecurity, and technical support providers who process data on our behalf under strict data processing agreements.
• Fraud prevention and analytics providers: Third-party services used to detect fraud, monitor platform security, and analyse usage data.
• Regulatory and law enforcement authorities: Philippine government agencies, regulatory bodies, courts, and law enforcement authorities where we are required by law to disclose your data, or where disclosure is necessary to protect the rights, property, or safety of MaxWinPH, our players, or the public.
• Professional advisers: Lawyers, auditors, and other professional advisers where necessary for the conduct of our business.

All third parties with whom MaxWinPH shares personal data are required to handle that data in accordance with applicable Philippine data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

7 Data Retention

MaxWinPH retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

In general, MaxWinPH applies the following retention periods:

• Account data: Retained for the duration of your account and for a period of at least five (5) years following account closure, in accordance with Philippine anti-money laundering regulations.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable Philippine law.
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer support communications: Retained for a period of two (2) years from the date of the communication, unless a longer period is required for the resolution of a dispute or legal claim.
• Technical and usage data: Retained for a period of up to two (2) years, after which it is anonymised or deleted.

Where personal data is no longer required for any of the above purposes, MaxWinPH will securely delete or anonymise it in accordance with our data disposal procedures.

8 Data Security

MaxWinPH takes the security of your personal data seriously and has implemented a range of technical and organisational measures designed to protect your data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the MaxWinPH platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Access controls limiting access to personal data to authorised personnel only, on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of our systems.
• Secure data storage with reputable cloud infrastructure providers.
• Staff training on data protection and information security best practices.

While MaxWinPH takes all reasonable steps to protect your personal data, no method of transmission over the internet or method of 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, MaxWinPH will notify you and the National Privacy Commission of the Philippines in accordance with our obligations under the Data Privacy Act of 2012.

9 Cookies and Tracking Technologies

MaxWinPH uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the platform, remember your preferences, and collect analytical data about how the platform is used.

We use the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the operation of the MaxWinPH platform and cannot be disabled. They include cookies that enable you to log in to your account and navigate the platform securely.
• Performance and analytics cookies: These cookies collect information about how visitors use the MaxWinPH platform, such as which pages are visited most frequently. This data is used in aggregate form to improve the platform.
• Functionality cookies: These cookies allow the platform to remember your preferences, such as your language settings and display preferences, to provide a more personalised experience.
• Marketing cookies: These cookies may be used to deliver promotional content that is relevant to your interests. They are only placed where you have provided your consent.

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the MaxWinPH platform. For more information on how to manage cookies, refer to your browser's help documentation.

10 Your Data Protection Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by MaxWinPH:

• Right to be informed: You have the right to be informed about how your personal data is being collected and processed, which is the purpose of this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data that MaxWinPH holds about you.
• Right to rectification: You have the right to request that MaxWinPH correct any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our 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 receive a copy of 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 of the Philippines if you believe that MaxWinPH has not handled your personal data in accordance with applicable law.

To exercise any of the above rights, please contact our Data Protection Officer at: [email protected]. We will respond to all valid data subject requests within thirty (30) days of receipt.

11 Children's Privacy

The MaxWinPH platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law governing casino-style gambling. MaxWinPH does not knowingly collect personal data from any person under the age of 21.

If MaxWinPH becomes aware that it has inadvertently collected personal data from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the MaxWinPH platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

12 Third-Party Links

The MaxWinPH platform may contain links to third-party websites or services, including payment providers such as GCash and PayMaya. This Privacy Policy applies solely to the MaxWinPH platform and does not cover the privacy practices of any third-party websites or services.

MaxWinPH is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party services you access through or in connection with the MaxWinPH platform.

13 Changes to This Privacy Policy

MaxWinPH reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the services we offer. Where changes are material, we will notify registered players by email or through a prominent notice on the MaxWinPH platform prior to the changes taking effect.

The date at the top of this Privacy Policy indicates when it was last updated. We encourage you to review this Privacy Policy periodically to stay informed about how MaxWinPH protects your personal data. Your continued use of the MaxWinPH platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way MaxWinPH handles your personal data, please contact our Data Protection Officer. We are committed to addressing all privacy-related enquiries promptly and transparently.

You may reach us by email at: [email protected]

Please include your registered account username and a clear description of your query or request to help us assist you as efficiently as possible. MaxWinPH aims to respond to all privacy-related enquiries within thirty (30) days of receipt.