win3max Privacy Policy

01 Introduction & Scope

This Policy applies to all personal information collected by win3max through any channel, including the win3max website, mobile-optimised platform, customer support communications, email, SMS, and any third-party integrations through which you interact with win3max services.

This Policy should be read alongside the win3max Terms & Conditions, which govern the overall contractual relationship between you and win3max. In the event of any conflict between this Policy and the Terms & Conditions on a privacy-related matter, this Policy prevails.

By registering a win3max Account or using any feature of the Platform, you acknowledge that you have read this Policy and consent to the collection and use of your personal information as described herein. Where processing is based on your consent, you may withdraw that consent at any time, though this will not affect the lawfulness of processing carried out prior to withdrawal.

02 Data Controller

Win3max acts as the personal information controller for all personal data collected through the Platform. As data controller, win3max determines the purposes and means by which your personal information is processed.

Win3max has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Policy. You may contact the win3max DPO for any privacy-related queries at the contact details provided in Section 15 of this Policy.

03 Personal Data We Collect

Win3max collects the following categories of personal information from players and platform users:

3.1 Identity Data

• Full legal name as it appears on government-issued identification
• Date of birth
• Gender (where provided)
• Government-issued identification documents (e.g., PhilSys National ID, passport, driver's licence, SSS ID, UMID, voter's ID)
• Photograph or selfie image (where required for KYC liveness checks)

3.2 Contact Data

• Philippine mobile number (Globe, Smart, or DITO)
• Email address
• Residential address (city and province level, where provided)

3.3 Financial Data

• GCash mobile number and account details (where linked)
• Maya account details (where used)
• Bank account number and bank name (BPI, BDO, Metrobank, or other, where used for withdrawal)
• Deposit and withdrawal transaction records
• Source of funds declarations (where required for enhanced due diligence)

3.4 Account and Gaming Data

• Account username and encrypted password hash
• Account registration date and history of account status changes
• Game session records including games played, wagers placed, wins, and losses
• Bonus usage and promotional activity history
• Responsible gaming settings and any self-imposed limits or exclusions

3.5 Technical Data

• IP address and geolocation data at login
• Device type, operating system, and browser information
• Session timestamps and session duration data
• Login history and device identifiers for recognised-device authentication

3.6 Communications Data

• Records of live chat, email, and support ticket interactions with win3max
• Survey responses and feedback submissions
• Complaint records and resolution history

04 How We Collect Your Data

Win3max collects personal data through the following channels:

4.1 Direct Collection

Data you provide to win3max directly when you: register an Account; complete KYC identity verification; make a deposit or request a withdrawal; contact customer support via live chat or email; participate in promotions or surveys; or update your account settings.

4.2 Automated Collection

Data collected automatically when you use the Platform, including via cookies, log files, and platform analytics tools. This includes IP addresses, device identifiers, session data, game interaction data, and browsing behaviour within the win3max Platform.

4.3 Third-Party Sources

Win3max may receive data from third parties including payment processors (GCash, Maya, BPI, BDO), identity verification service providers engaged for KYC purposes, fraud detection and anti-money laundering screening services, and PAGCOR's centralised player database where applicable.

05 Legal Basis for Processing

Win3max processes your personal data under the following legal bases as established by the Data Privacy Act of 2012:

06 How We Use Your Personal Data

Win3max uses your personal data for the following specific purposes:

6.1 Account Operation

To create and manage your win3max Account, verify your identity and age, authenticate your login sessions, and maintain the security and integrity of your Account.

6.2 Payment Services

To process GCash, Maya, bank transfer, and other deposits and withdrawals; to verify that payment accounts are registered in your name; and to maintain transaction records as required by PAGCOR and the Anti-Money Laundering Council (AMLC).

6.3 Regulatory Compliance

To fulfil win3max's obligations under PAGCOR licensing, Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments, the Data Privacy Act of 2012, and other applicable Philippine law. This includes filing Covered Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) with the AMLC where legally required.

6.4 Responsible Gaming

To monitor account activity for signs of problem gambling; to enforce deposit limits, session limits, cooling-off periods, and self-exclusions that you have set; and to comply with PAGCOR's mandatory responsible gaming requirements for licensed operators.

6.5 Fraud Prevention and Security

To detect and prevent fraudulent account activity, duplicate accounts, bonus abuse, money laundering, and unauthorised access to win3max accounts.

6.6 Customer Support

To respond to your queries, resolve complaints, process requests, and maintain records of interactions with the win3max support team.

6.7 Marketing and Promotions

To send you information about win3max promotions, bonuses, new games, and platform updates — subject to your marketing preferences and, where required, your explicit consent. You may opt out of marketing communications at any time through your account settings.

6.8 Platform Improvement

To analyse usage patterns, game performance, payment flow efficiency, and support interactions to improve the win3max Platform for all players.

07 Sharing Your Personal Data

Win3max does not sell your personal data. We share personal data only in the following limited circumstances:

7.1 Payment Processors

Win3max shares transaction data with payment service providers including GCash (GXI), Maya (Voyager Innovations), BPI, BDO, Metrobank, Coins.ph, and 7-Eleven (CLIQQ) solely to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial data protection regulations.

7.2 KYC and Identity Verification Providers

Win3max may engage accredited third-party identity verification service providers to assist with KYC document checks, liveness verification, and database screening. These providers operate under data processing agreements and are permitted to use your data only for the purpose of identity verification on behalf of win3max.

7.3 Regulatory Authorities

Win3max is required to disclose certain player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies where legally required. Win3max will comply with all lawful requests from these authorities.

7.4 Game Providers

Game providers whose titles are hosted on the win3max Platform may receive limited technical data (such as session identifiers) necessary to operate the game session. Game providers do not receive your identity data, payment data, or contact information unless you have separately consented to share this with them.

7.5 Legal and Law Enforcement

Win3max may disclose personal data to law enforcement agencies, courts, or legal advisers where required by law, court order, or in connection with legal proceedings in which win3max is a party or is required to provide evidence.

08 Cookies & Tracking Technologies

Win3max uses cookies and similar technologies on the Platform to provide, secure, and improve the user experience. Cookies are small text files stored on your device when you visit the Platform.

8.1 Types of Cookies Used

• Essential Cookies: Required for the Platform to function. These include session authentication cookies and security cookies. They cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, remembered device status for 2FA, and responsible gaming notification intervals.
• Analytics Cookies: Used by win3max to understand how players use the Platform — which games are most popular, where users encounter difficulties, and how to improve navigation. Analytics data is aggregated and does not identify individual users.
• Security Cookies: Used to detect suspicious login activity, recognise trusted devices, and support fraud detection.

8.2 Managing Cookies

You may configure your browser to refuse or delete cookies. Note that disabling essential cookies will prevent you from logging in to your win3max Account and accessing the Platform. Instructions for managing cookies are available through your browser's help settings.

09 Data Security

Win3max implements technical and organisational security measures appropriate to the sensitivity of the personal data we process. Our security framework includes the following controls:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the win3max Platform
• Encryption at rest for all personal data stored in win3max databases
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis
• Two-factor authentication for all win3max administrative and operational systems
• Regular security assessments and penetration testing by independent third-party security firms
• Intrusion detection and anomaly monitoring systems operating continuously
• Data pseudonymisation techniques applied to analytics datasets
• Staff training on data protection obligations under the Data Privacy Act

While win3max employs rigorous security measures, no digital system can guarantee absolute security. In the event of a data breach that is likely to harm your rights or interests, win3max will notify the National Privacy Commission and affected players within 72 hours of becoming aware of the breach, in accordance with the Data Privacy Act.

10 Data Retention

Win3max retains personal data for the minimum period necessary to fulfil the purposes described in this Policy, subject to regulatory retention requirements:

Upon expiry of the applicable retention period, win3max will securely delete or anonymise personal data in a manner that prevents reconstruction of the original data.

11 Your Data Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by win3max:

Exercising Your Rights

To exercise any of your data rights, submit a written request to the win3max Data Protection Officer at [email protected] with the subject line "Data Rights Request". Win3max will acknowledge your request within 3 business days and respond substantively within 30 calendar days, or within the timeframe required by the NPC where a different period applies.

Win3max may ask you to verify your identity before processing a data rights request to ensure that personal data is not disclosed to unauthorised persons.

12 Children's Privacy

The win3max Platform is strictly restricted to individuals aged 21 years or older. Win3max does not knowingly collect personal data from persons under the age of 21. The Platform's registration system includes mandatory age verification, and accounts found to have been registered by underage individuals are immediately suspended.

If you believe that personal data has been collected from a person under 21 through the win3max Platform, please notify us immediately at [email protected]. Win3max will investigate and, where confirmed, will delete the data and close the account without delay.

13 Cross-Border Data Transfers

Win3max's primary data infrastructure is located in the Philippines. Certain service providers — including game providers, cloud infrastructure vendors, and cybersecurity services — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, win3max ensures that appropriate safeguards are in place to protect your data to a standard equivalent to Philippine data protection law. These safeguards include contractual data processing agreements with standard data protection clauses, and selection of vendors that maintain internationally recognised security certifications.

Win3max will not transfer personal data to jurisdictions that do not provide adequate protections for personal data without implementing appropriate additional safeguards and, where required, obtaining your consent.

14 Changes to This Privacy Policy

Win3max may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory requirements, data processing practices, or Platform features. The effective date and last updated date at the top of this Policy will be revised accordingly.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — win3max will notify registered players by email at least 14 days before the changes take effect. For minor or clarificatory changes, the updated Policy will be posted on the Platform and the effective date revised, which constitutes sufficient notice.

Continued use of the win3max Platform after the effective date of any revised Policy constitutes your acknowledgment of the changes. If you do not accept the revised Policy, you must stop using the Platform and may close your Account in accordance with the Terms & Conditions.

15 Contact & Complaints

15.1 Data Protection Officer

For any privacy-related queries, data rights requests, or concerns about how win3max handles your personal data, please contact the win3max Data Protection Officer:

• Email: [email protected] (subject: "Privacy / Data Rights")
• Live Chat: Available 24/7 via the win3max Platform — ask to be connected to the Data Protection team

15.2 Regulatory Complaints

If you believe that win3max has failed to handle your personal data in compliance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC provides a formal complaint mechanism for data subjects whose privacy rights have been violated.

15.3 Gaming and Licensing Complaints

For complaints relating to win3max's gaming operations, fair play, or PAGCOR-regulated activities (as opposed to data privacy), please refer to the win3max Terms & Conditions for the applicable complaint procedure and PAGCOR escalation process. For general help and frequently asked questions, visit the win3max FAQ page.