Privacy Policy

1 About This Policy

This Privacy Policy applies to all personal information collected by phlwim through phlwim.net, including during account registration, gameplay, deposit and withdrawal transactions, customer support interactions, and any other engagement with the Platform. It applies to all registered players and non-registered visitors who access any part of phlwim.net.

phlwim acts as the data controller in respect of all personal information processed under this Policy. As data controller, phlwim determines the purposes and means by which your personal data is processed and is responsible for ensuring that such processing is carried out lawfully, fairly, and securely in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173).

2 Data We Collect

phlwim collects personal information that is necessary to operate your account, comply with legal obligations, and deliver a secure gaming experience. The categories of data we collect are set out in the table below:

phlwim does not intentionally collect sensitive personal information beyond what is required for identity verification and KYC compliance. Where sensitive information such as a government ID is collected, it is handled with heightened security controls and access restrictions.

3 How We Use Your Data

phlwim uses the personal information we collect for the following specific purposes:

• Account Management: To create, maintain, and administer your phlwim account, including processing login authentication and account preference settings.
• Transaction Processing: To process deposits and withdrawals in Philippine Peso (PHP) via GCash, PayMaya, BPI, BDO, Metrobank, and OTC channels, and to maintain accurate transaction records.
• Identity Verification (KYC): To verify your identity and age (21+) in compliance with applicable Philippine gaming regulations and anti-money laundering requirements.
• Customer Support: To respond to your enquiries, resolve disputes, and provide assistance via live chat, email, and other support channels.
• Responsible Gaming: To monitor gaming activity for indicators of problem gambling behaviour and to enforce self-exclusion requests and deposit limits set by players.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the functionality, design, and performance of phlwim.net and its games.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, account abuse, bonus misuse, and other prohibited activities.
• Legal Compliance: To fulfil obligations imposed by Philippine law, including the Data Privacy Act, anti-money laundering regulations, and any direction from gaming regulatory authorities.
• Marketing Communications: To send promotional offers, bonus notifications, and game updates to players who have opted in to receive such communications. You may unsubscribe at any time via your account settings or by contacting support.

4 Legal Basis for Processing

phlwim processes your personal information on the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and phlwim, specifically to provide the gaming and betting services you have registered to use, and to process your deposits and withdrawals.
• Legal Obligation: Processing is necessary to comply with applicable Philippine laws, including KYC identity verification requirements, anti-money laundering obligations, and gaming regulatory requirements.
• Legitimate Interests: Processing is carried out in furtherance of phlwim's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and customer support operations, provided such interests do not override your fundamental rights.
• Consent: Where required by law, phlwim will seek your express consent before processing your personal data, particularly for the purpose of sending marketing and promotional communications. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 Data Sharing & Disclosure

phlwim does not sell, rent, or trade your personal information to unaffiliated third parties. We may, however, share your data with the following categories of recipients where necessary and lawful:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and OTC payment partners receive the minimum personal and financial information required to process your deposit and withdrawal transactions securely.
• Identity Verification Partners: Third-party KYC service providers may process your identity documents and personal details to perform age and identity verification on behalf of phlwim. These providers are bound by strict data processing agreements.
• Technology Infrastructure Providers: Cloud hosting, server infrastructure, and cybersecurity service providers who support the operation of phlwim.net may have access to data in the course of providing their services, subject to contractual confidentiality obligations.
• Gaming Software Providers: Game developers and platform software licensors who power specific games on phlwim may receive anonymised or aggregated gameplay data for the purpose of game performance monitoring.
• Regulatory and Law Enforcement Authorities: phlwim may disclose personal information to Philippine gaming regulators, law enforcement agencies, courts, or other government authorities where required by law, court order, or regulatory direction.

Where phlwim engages third-party data processors, it requires them to handle personal data in accordance with the Philippine Data Privacy Act and to implement appropriate security measures. phlwim remains responsible for the lawful handling of your data by these processors.

6 Cookies & Tracking

phlwim.net uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and improve your browsing experience. The types of cookies used on phlwim.net are as follows:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They include session authentication cookies that keep you logged in during your visit and security tokens that protect against cross-site request forgery. These cookies cannot be disabled without affecting core Platform functionality.
• Functional Cookies: These cookies remember your language preferences, display settings, and other account customisation choices to provide a more personalised experience across sessions.
• Analytics Cookies: phlwim uses anonymised analytics to understand how players navigate the Platform, which games are most popular, and where usability improvements can be made. No personally identifiable information is included in analytics reports.
• Session Cookies: Temporary cookies that expire when you close your browser, used to maintain session continuity during gameplay and transaction flows.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to log in and use the Platform. Continuing to use phlwim.net without changing your cookie settings indicates your acceptance of cookies as described in this Policy.

7 Data Retention

phlwim retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention principles apply:

• Active Account Data: Personal information associated with an active phlwim account is retained for the duration of the account's active status and for a minimum of five (5) years following permanent account closure, in accordance with applicable anti-money laundering and gaming record-keeping requirements.
• Transaction Records: Financial transaction records, including deposit and withdrawal history in PHP, are retained for a minimum of five (5) years to comply with Philippine financial recordkeeping regulations.
• KYC Documents: Identity verification documents submitted during the KYC process are retained for the duration of the account relationship and for five (5) years after closure.
• Support Communications: Live chat transcripts and email correspondence are retained for a period of three (3) years for quality assurance, dispute resolution, and regulatory compliance purposes.
• Technical and Log Data: Server logs and technical access data are typically retained for a rolling period of twelve (12) months for security monitoring and fraud investigation purposes.

After the applicable retention period has elapsed, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

8 Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by phlwim:

• Right to Be Informed: You have the right to know what personal data phlwim holds about you, the purpose for which it is being processed, and how it is being handled. This Privacy Policy fulfils that obligation.
• Right of Access: You may request a copy of the personal data phlwim holds about you at any time. Access requests can be submitted via live chat or by emailing our support team. phlwim will respond within a reasonable timeframe not exceeding thirty (30) days.
• Right to Rectification: If any personal information held by phlwim is inaccurate or incomplete, you have the right to request that it be corrected. You may update basic contact information directly through your account settings.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to phlwim's legal and regulatory retention obligations. Erasure requests that conflict with applicable record-keeping requirements may be declined or partially fulfilled.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. Upon receipt of an objection, phlwim will cease processing your data for that purpose without delay.
• Right to Data Portability: Where technically feasible and permitted by law, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: If you believe that phlwim has processed your personal data in a manner that violates the Philippine Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

9 Data Security

phlwim implements a range of technical, organisational, and procedural security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Encryption: All data transmitted between your device and phlwim.net is encrypted using 256-bit SSL/TLS protocols. Sensitive data stored in phlwim's systems is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to systems containing personal data is restricted to authorised phlwim personnel on a strict need-to-know basis. Multi-factor authentication is required for all administrative system access.
• Security Monitoring: phlwim operates continuous security monitoring, intrusion detection systems, and regular vulnerability assessments to identify and address potential threats.
• Staff Training: All phlwim staff who handle personal data receive regular data privacy and security training and are bound by confidentiality obligations.
• Incident Response: phlwim maintains a documented data breach response procedure. In the event of a personal data breach affecting your rights and freedoms, phlwim will notify affected players and the National Privacy Commission as required by law.

While phlwim implements robust security measures, no online platform can guarantee absolute security. Players are encouraged to use strong, unique passwords for their phlwim accounts and to enable SMS OTP two-factor authentication where available.

10 Children's Privacy

phlwim.net is strictly intended for adults aged 21 and above. phlwim does not knowingly collect personal information from any person under the age of 21. The 21+ age requirement is enforced through age verification during registration and KYC processes.

If phlwim becomes aware that personal information has been collected from an individual under the age of 21, that account will be immediately suspended, all associated data will be reviewed, and any confirmed real-money balance will be returned to the deposit payment method. The personal data of the underage individual will be deleted from phlwim's systems as soon as practicable, subject to any legal obligations.

Parents and guardians who believe a minor may have registered on phlwim.net are encouraged to contact our support team immediately via live chat so that appropriate action can be taken.

11 Third-Party Services

phlwim.net may contain references to third-party payment platforms such as GCash and PayMaya, and may integrate with third-party gaming software providers. When you interact with these third-party services — for example, by initiating a GCash deposit — you are also subject to the privacy policies of those third parties.

phlwim is not responsible for the privacy practices of third-party services and encourages players to review the privacy policies of any external service they use in connection with their phlwim account. phlwim selects its third-party partners carefully and requires them to handle any shared personal data in accordance with applicable data protection standards.

12 Changes to This Policy

phlwim reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data handling practices, applicable law, or operational requirements. The "Last Updated" date at the top of this page will be revised whenever a change is made.

Where changes are material — for example, where phlwim begins processing personal data for a new purpose — phlwim will provide advance notice to registered players via the email address on file or through a prominent notice on the Platform. For non-material updates such as corrections to wording or clarifications that do not affect the substance of the Policy, notice may be provided solely by publishing the updated Policy on this page.

Your continued use of phlwim.net following the effective date of any update constitutes your acknowledgement of the revised Privacy Policy. If you do not agree to the updated terms, you should cease use of the Platform and may request account closure via live chat support.

13 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by phlwim, please contact our support team through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly from phlwim.net. Our Filipino support team is fully equipped to handle data privacy enquiries and requests.
• Email: [email protected] — Please include "Privacy Request" in your subject line so that your enquiry is routed to the appropriate team. Responses are typically provided within 24 hours.

If you are not satisfied with phlwim's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines, the independent government body responsible for enforcing the Data Privacy Act of 2012.