winsir Privacy Policy

1. Introduction

winsir ("winsir", "we", "us", "our") operates the online gaming platform accessible at winsir.org. We are committed to protecting the privacy and personal data of all users ("you", "your") who access or use our platform, particularly Filipino players across Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond.

This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. It describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

By registering for a winsir account or using any part of our platform, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of the winsir platform immediately.

2. Personal Data We Collect

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

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify you are 21 years of age or older)
• Nationality and country of residence
• Email address and mobile phone number
• Residential address (barangay, city/municipality, province)

2.2 Identity Verification Data (KYC)

• Copies of government-issued identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID)
• Proof of address documents
• Selfie or liveness verification images where required

2.3 Financial Data

• GCash or PayMaya / Maya account reference (masked)
• Bank account details for withdrawal processing (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank)
• Debit card details (masked card number, expiry)
• Transaction history, deposit and withdrawal records

2.4 Gaming & Behavioural Data

• Game play history, wager amounts, win/loss records
• Session duration, login timestamps, and frequency of play
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, self-exclusion status)

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Platform access logs and error reports

2.6 Communications Data

• Records of your communications with winsir customer support
• Feedback, survey responses, and complaint records
• Email and in-platform message history

3. How We Collect Your Data

winsir collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the winsir platform, including cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Data received from identity verification providers, payment processors, fraud prevention services, and regulatory databases where permitted by law.

4. How We Use Your Personal Data

winsir uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Identity, contact, KYC data
Age verification (21+ compliance)	Date of birth, KYC documents
Processing deposits and withdrawals	Financial data, identity data
Anti-money laundering (AML) compliance	Financial, identity, transaction data
Fraud detection and prevention	Technical, behavioural, financial data
Responsible gaming monitoring	Gaming, behavioural, account data
Customer support and dispute resolution	Communications, account, transaction data
Platform improvement and analytics	Technical, behavioural data (aggregated)
Marketing and promotional communications	Contact data (with your consent)
Legal and regulatory compliance	All categories as required

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to fulfil our obligations under the winsir Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, PAGCOR regulatory requirements, and tax reporting.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent.

6. Data Sharing & Disclosure

winsir does not sell your personal data to third parties. We may share your data with the following categories of recipients only where necessary and lawful:

• Payment processors: GCash, PayMaya / Maya, and banking partners for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and comply with regulatory requirements.
• Regulatory authorities: PAGCOR and other Philippine government agencies where disclosure is required by law or court order.
• Fraud prevention services: Specialist providers engaged to detect and prevent fraudulent activity on the winsir platform.
• IT and infrastructure providers: Cloud hosting, data storage, and platform technology providers operating under strict data processing agreements.
• Professional advisers: Legal, accounting, and compliance advisers bound by professional confidentiality obligations.

All third parties with whom winsir shares personal data are required to process such data in accordance with applicable data protection laws and winsir's data processing standards.

7. Cookies & Tracking Technologies

winsir uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies we use include:

• Strictly necessary cookies: Essential for the platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login state to improve your experience.
• Analytics cookies: Collect aggregated, anonymised data about how users interact with the winsir platform to help us improve performance and usability.
• Marketing cookies: Used to deliver relevant promotional content within the winsir platform, 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 winsir platform.

8. Data Retention

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

As a general guide:

• Account and KYC data is retained for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Marketing consent records are retained until you withdraw consent, plus a reasonable period thereafter for compliance purposes.

Upon expiry of the applicable retention period, winsir will securely delete or anonymise your personal data.

9. Data Security

winsir implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the winsir platform
• Encryption of sensitive data at rest, including financial and identity information
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Regular security assessments and penetration testing of the winsir platform
• Multi-factor authentication options for user accounts
• Incident response procedures for detecting and responding to data security breaches

10. Your Data Rights

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

• Right to be informed: The right to be told how your personal data is being collected and processed.
• Right of access: The right to request a copy of the personal data winsir holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact winsir's Data Protection Officer using the contact details in Section 14. We will respond to all verified requests within thirty (30) calendar days.

11. Children's Privacy

The winsir platform is strictly for adults aged 21 years and older, in accordance with Philippine law. winsir does not knowingly collect personal data from persons under 21 years of age. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe your child has registered on the winsir platform, please contact us immediately at the details provided in Section 14 so we can investigate and take appropriate action.

12. International Data Transfers

winsir's primary operations and data storage are based in the Philippines. In certain circumstances, your personal data may be transferred to, stored, or processed in countries outside the Philippines — for example, where we engage cloud infrastructure or technology service providers operating internationally.

Where such transfers occur, winsir ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual clauses, data processing agreements, or reliance on adequacy decisions where applicable.

13. Changes to This Privacy Policy

winsir reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered users via email or in-platform notification.

We encourage you to review this Privacy Policy periodically to stay informed about how winsir protects your personal data. Your continued use of the winsir platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by winsir, please contact our Data Protection Officer:

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