winq Privacy Policy

1 Introduction

winq ("winq," "we," "us," or "our") operates the online casino and sports betting platform accessible at winq.club. As a data controller, winq is responsible for the personal data of all registered players and website visitors. We take this responsibility seriously and are committed to protecting your privacy at every stage of your interaction with the winq platform.

This Privacy Policy describes our practices regarding the collection, use, storage, sharing, and protection of your personal data. It also outlines the rights available to you under applicable law and explains how you can exercise those rights. We encourage you to read this document carefully and to contact us if anything is unclear.

This Privacy Policy should be read alongside the winq Terms & Conditions, which govern your use of the platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters of data privacy, this Privacy Policy shall prevail.

2 Data We Collect

winq collects personal data that is necessary to provide you with a safe, compliant, and personalised gaming experience. The categories of personal data we collect include:

3 How We Collect Data

winq collects personal data through the following channels:

Direct Collection

You provide data directly to winq when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, participate in a promotion, or respond to a survey. This is the primary source of personal data we hold about you.

Automated Collection

When you access the winq platform, our systems automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. This data helps us maintain platform security, detect fraudulent activity, and improve the overall user experience for Filipino players.

Third-Party Sources

winq may receive personal data about you from third-party sources, including:

• Payment processors (GCash, PayMaya, BPI, BDO, Metrobank) for transaction verification purposes.
• Identity verification service providers used to conduct KYC checks.
• Fraud prevention and AML screening services.
• Publicly available sources, such as government sanction lists and politically exposed persons (PEP) databases.

4 How We Use Your Data

winq uses your personal data only for legitimate, specified purposes. The primary purposes for which we process your data are:

• Account Management: Creating, maintaining, and securing your winq account.
• Identity & Age Verification: Confirming that you meet the 21+ age requirement and verifying your identity in compliance with KYC obligations.
• Payment Processing: Facilitating deposits and withdrawals via GCash, PayMaya, and other accepted Philippine payment channels.
• Regulatory Compliance: Meeting our obligations under Philippine gaming regulations, AML laws, and the Data Privacy Act of 2012.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, money laundering, and other illegal conduct.
• Customer Support: Responding to your enquiries, resolving disputes, and providing technical assistance.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviour and applying responsible gaming tools where appropriate.
• Platform Improvement: Analysing usage data to improve the winq platform, fix bugs, and develop new features.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates – but only where you have given your consent or where we have a legitimate interest to do so.

5 Legal Basis for Processing

winq processes your personal data on the following legal grounds as recognised under the Data Privacy Act of 2012 (Republic Act No. 10173) and applicable Philippine regulations:

• Contractual Necessity: Processing is required to perform the contract between you and winq – specifically, to operate your account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is necessary to comply with applicable laws, including KYC requirements, AML regulations, and gaming licensing conditions.
• Legitimate Interests: winq processes certain data to pursue legitimate business interests, such as fraud prevention, platform security, and responsible gaming monitoring, provided those interests are not overridden by your rights and freedoms.
• Consent: Where winq relies on your consent as the legal basis for processing – for example, for direct 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 Data Sharing & Disclosure

winq does not share your personal data with third parties except in the following circumstances:

Service Providers

winq engages trusted third-party service providers to assist in operating the platform. These include payment processors, identity verification providers, cloud hosting services, and customer support tools. All service providers are contractually bound to process your data only on winq's instructions and in accordance with applicable data protection law.

Regulatory & Law Enforcement Authorities

winq may disclose your personal data to Philippine government agencies, regulatory bodies, or law enforcement authorities where required by law, court order, or regulatory directive. This includes disclosures required under AML reporting obligations.

Business Transfers

In the event of a merger, acquisition, or sale of all or part of winq's business, your personal data may be transferred to the acquiring entity as part of that transaction. winq will notify affected players of any such transfer and the privacy practices of the acquiring entity.

With Your Consent

winq may share your data with third parties in other circumstances where you have given your explicit prior consent to such sharing.

7 Cookies & Tracking Technologies

winq uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and gather analytics data. The types of cookies we use include:

• Essential Cookies: Required for the platform to function correctly. These include session authentication cookies and security tokens. You cannot opt out of essential cookies without affecting platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players interact with the winq platform. This helps us identify popular features, diagnose technical issues, and improve overall performance.
• Preference Cookies: Store your platform preferences, such as language settings and display options, so you do not need to reconfigure them on each visit.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of winq's marketing campaigns. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the winq platform. For a full list of cookies used by winq, please contact our support team.

8 Data Retention

winq retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements. The general retention periods applied by winq are as follows:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• KYC & Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant KYC process.
• Support Communications: Retained for up to three (3) years from the date of the last communication.
• 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, winq will securely delete or anonymise your personal data in accordance with our internal data disposal procedures.

9 Your Rights

Under the Data Privacy Act of 2012 and applicable Philippine regulations, you have the following rights in relation to your personal data held by winq:

• Right to Be Informed: You have the right to be informed about how your personal data is collected and processed. This Privacy Policy fulfils that obligation.
• Right of Access: You may request a copy of the personal data winq 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 we hold about you.
• Right to Erasure: In certain circumstances, you may request that winq delete your personal data. This right is subject to winq's legal obligations to retain certain data under AML and gaming regulations.
• Right to Object: You may object to the processing of your personal data where winq relies on legitimate interests as the legal basis, or where your data is used for direct marketing purposes.
• Right to Data Portability: You may request that winq provide your personal data in a structured, commonly used, machine-readable format for transfer to another service provider.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• 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 winq has processed your personal data in violation of applicable law.

10 Data Security

winq implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the winq platform.
• Encryption of sensitive personal data and financial information at rest using industry-standard encryption protocols.
• Role-based access controls ensuring that only authorised winq personnel can access personal data, and only to the extent necessary for their role.
• Regular security audits, vulnerability assessments, and penetration testing of the winq platform.
• Multi-factor authentication requirements for all winq staff accessing systems that process personal data.
• Incident response procedures to detect, contain, and report personal data breaches in accordance with applicable notification requirements.

While winq takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your winq account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

11 Children's Privacy

The winq platform is strictly intended for individuals aged 21 years and above in accordance with Philippine gaming regulations. winq does not knowingly collect personal data from any person under the age of 21. If winq becomes aware that personal data has been collected from an individual under 21, that data will be immediately deleted and the associated account will be closed.

If you are a parent or guardian and believe that a minor has registered on the winq platform or provided personal data to winq, please contact us immediately at [email protected] so that we can take prompt corrective action.

12 Contact & Policy Updates

Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or winq's data processing practices, please contact our Data Privacy Officer at [email protected]. We aim to acknowledge all privacy-related enquiries within five (5) business days and to provide a substantive response within thirty (30) calendar days.

Policy Updates

winq reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, winq will notify registered players via email or an in-platform notification at least fourteen (14) days before the changes take effect. The "Last Updated" date at the top of this page will always reflect the date of the most recent revision.

Your continued use of the winq platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should cease using the platform and contact us to close your account.