winzer Privacy Policy

Effective Date: January 1, 2026

1. Introduction

winzer ("winzer," "we," "us," or "our") operates the online gaming platform accessible at winzer.app. We are committed to protecting the privacy and personal data of every individual who accesses or uses the winzer Platform, including registered Players, visitors, and prospective users (collectively, "you" or "Data Subject").

This Privacy Policy ("Policy") describes how winzer collects, uses, stores, shares, and protects your personal information in connection with your use of the winzer website, mobile interface, games, and all related services (the "Platform"). It also explains the rights available to you under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and how to exercise those rights.

This Policy should be read together with the winzer Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference. By registering an Account or using the winzer Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2. Data Controller

For the purposes of the Philippine Data Privacy Act and applicable data protection legislation, winzer is the personal information controller responsible for your personal data collected through the Platform. winzer has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection laws.

If you have any questions about this Policy or wish to exercise your data subject rights, you may contact the winzer DPO at: [email protected]

3. Personal Data We Collect

winzer collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify that you are at least 21 years of age)
• Residential address in the Philippines (barangay, city/municipality, province)
• Email address
• Mobile number (Philippine mobile number)
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, UMID, PhilSys ID, driver's license, PRC ID)
• Proof of address documents (e.g., utility bill, bank statement, barangay certificate)
• Selfie or facial image for identity verification purposes

3.3 Financial & Transaction Data

• GCash account number or registered mobile number
• PayMaya account details
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where applicable
• Deposit and withdrawal transaction history
• Wagering history and game activity records

3.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, pages visited, and features used on the Platform
• Login timestamps and access logs
• Cookie identifiers and similar tracking technologies

3.5 Communications Data

• Records of communications between you and winzer support staff
• Feedback, complaints, and survey responses submitted through the Platform
• Email and in-platform notification preferences

winzer does not intentionally collect sensitive personal information as defined under the DPA (such as health data, political opinions, or religious beliefs) unless specifically required for responsible gaming assessments or as mandated by applicable law.

4. How We Collect Your Data

winzer collects personal data through the following means:

• Directly from you – when you register an Account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions.
• Automatically – through cookies, web beacons, and similar tracking technologies when you browse or use the Platform.
• From third parties – including identity verification service providers, payment processors (GCash, PayMaya, banks), fraud prevention services, and regulatory authorities where required by law.

5. How We Use Your Personal Data

winzer uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Registration & Identity Data
Age and identity verification (KYC)	Identity Verification Data, Date of Birth
Processing deposits and withdrawals	Financial & Transaction Data
Providing and improving Platform services	Technical & Usage Data
Fraud prevention and security monitoring	All categories as necessary
Responsible gaming monitoring and intervention	Wagering history, session data
Regulatory compliance and reporting	Identity, KYC, and Transaction Data
Customer support and dispute resolution	Communications Data, Account Data
Marketing and promotional communications (with consent)	Email address, notification preferences
Analytics and platform performance improvement	Technical & Usage Data (aggregated)

winzer will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

6. Legal Basis for Processing

winzer processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity – processing is necessary to perform the contract between you and winzer (i.e., to operate your Account, process transactions, and provide gaming services).
• Legal obligation – processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) requirements, KYC obligations, and gaming regulatory requirements.
• Legitimate interests – processing is necessary for winzer's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided those interests are not overridden by your rights and freedoms.
• Consent – where winzer relies on your consent as the legal basis for processing (e.g., 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.

7. Sharing Your Personal Data

winzer 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:

7.1 Service Providers

winzer engages trusted third-party service providers to assist in operating the Platform, including identity verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), cloud hosting providers, customer support platforms, and analytics services. These providers are contractually bound to process your data only on winzer's instructions and in accordance with applicable data protection law.

7.2 Regulatory and Law Enforcement Authorities

winzer may disclose your personal data to Philippine government agencies, regulatory bodies, law enforcement authorities, or courts where required to do so by law, court order, or regulatory directive. This includes disclosures required under the Anti-Money Laundering Act (AMLA), the Terrorism Financing Prevention and Suppression Act, and applicable gaming regulations.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of winzer's business, your personal data may be transferred to the acquiring entity as part of that transaction. winzer will notify you of any such transfer and ensure that the receiving entity is bound by privacy obligations no less protective than those set out in this Policy.

7.4 With Your Consent

winzer may share your personal data with other third parties where you have given your explicit consent to such sharing. You may withdraw this consent at any time by contacting the winzer DPO.

8. Cookies & Tracking Technologies

winzer uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the Platform, maintain session security, analyze usage patterns, and deliver relevant content. Cookies are small text files stored on your device when you visit the winzer website.

winzer uses the following types of cookies:

• Strictly necessary cookies – essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies – remember your preferences and settings (such as language and display preferences) to improve your experience.
• Analytics cookies – collect aggregated, anonymized data about how Players use the Platform, helping winzer identify areas for improvement.
• Marketing cookies – used to deliver relevant promotional content based on your interests, subject to your consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the winzer Platform. Strictly necessary cookies cannot be disabled as they are essential to the Platform's operation.

9. Data Retention

winzer retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce agreements. The following general retention periods apply:

• Account and KYC data – retained for the duration of your Account and for a minimum of five (5) years following Account closure, as required by Philippine AML regulations.
• Transaction and wagering records – retained for a minimum of five (5) years from the date of the transaction, in accordance with applicable financial record-keeping requirements.
• Communications data – retained for up to three (3) years from the date of the communication, unless a longer period is required for dispute resolution or legal proceedings.
• Technical and usage data – retained for up to two (2) years from collection, after which it is anonymized or deleted.
• Marketing consent records – retained for the duration of your consent and for one (1) year following withdrawal of consent.

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

10. Data Security

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

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the winzer Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls ensuring that only authorized winzer personnel can access personal data on a need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of the Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Staff training on data protection obligations and secure data handling practices.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While winzer takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your winzer login credentials and for notifying winzer immediately if you suspect unauthorized access to your Account.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by winzer. To exercise any of these rights, please contact the winzer DPO at [email protected]. winzer will respond to all verified requests within thirty (30) days of receipt.

• Right to be informed – you have the right to be informed about how your personal data is collected and processed, as set out in this Policy.
• Right of access – you have the right to request a copy of the personal data winzer holds about you, along with information about how it is being used.
• Right to rectification – you have the right to request correction of any inaccurate or incomplete personal data winzer holds about you.
• Right to erasure – you have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to winzer's legal retention obligations.
• Right to object – you have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on winzer's legitimate interests.
• Right to data portability – you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible.
• Right to lodge a complaint – you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe winzer has violated your data privacy rights.

winzer may need to verify your identity before processing a data subject rights request. winzer reserves the right to decline requests that are manifestly unfounded, excessive, or that would require winzer to violate its legal obligations.

12. Children's Privacy

The winzer Platform is strictly restricted to individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. winzer does not knowingly collect personal data from individuals under the age of 21. If winzer becomes aware that personal data has been collected from a person under 21, that Account will be immediately suspended, the data will be deleted, and the matter may be referred to the relevant regulatory authority.

If you are a parent or guardian and believe that a minor has registered an Account on winzer or provided personal data to winzer without your consent, please contact the winzer DPO immediately at [email protected].

13. Cross-Border Data Transfers

winzer's primary operations and data storage are based in the Philippines. In certain circumstances, your personal data may be transferred to, stored in, or processed by service providers located outside the Philippines – for example, cloud infrastructure providers or identity verification services operating in other jurisdictions.

Where such cross-border transfers occur, winzer ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that impose data protection obligations on the receiving party equivalent to those required under the Philippine DPA. winzer will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

14. Changes to This Privacy Policy

winzer reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. The most current version of this Policy will always be available at winzer.app/privacy-policy. The effective date at the top of this document will be updated to reflect the date of the most recent revision.

Where changes are material, winzer will notify registered Players via the email address on file or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the winzer Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must cease using the Platform and may request Account closure.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way winzer handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.

This Privacy Policy was last updated on January 1, 2026. If any provision of this Policy is found to be invalid or unenforceable under applicable law, the remaining provisions shall continue in full force and effect. This Policy is governed by the laws of the Republic of the Philippines.