WinPH 4 Privacy Policy — How We Keep Your Personal Data Safe and Private

1Who We Are

This Privacy Policy is issued by WinPH 4, the operator of the online gaming platform accessible at winph4.click (the "Platform"). WinPH 4 acts as the Personal Information Controller (PIC) as defined under Republic Act 10173, the Philippine Data Privacy Act of 2012, and its Implementing Rules and Regulations.

For any privacy-related inquiries, requests, or concerns, you may reach our Data Protection Officer (DPO) directly at privacy@winph4.click or via the live chat available on the Platform at any time.

2Data We Collect

WinPH 4 collects the following categories of personal data from players. We collect only what is necessary for a specific, defined purpose:

Registration & Identity Data

• Full legal name as it appears on a government-issued ID
• Date of birth (to verify that you meet the 21-year minimum age requirement)
• Gender (optional, for personalisation purposes)
• Nationality and country of residence
• Current residential address in the Philippines

Contact Data

• Mobile phone number (Philippine format, used for account verification and support)
• Email address (used for account communications, transaction confirmations, and promotions where consent has been given)

Financial & Payment Data

• GCash or Maya mobile wallet account details (wallet number only — WinPH 4 never stores your GCash or Maya PIN or password)
• Bank account details for players using InstaPay, PESONet, or bank transfer (account name and number only)
• Partial card details for Visa/Mastercard transactions (tokenised — WinPH 4 does not store full card numbers)
• Transaction history: deposits, withdrawals, bonus credits, wager amounts, and game outcomes

Identity Verification (KYC) Data

• Copy of government-issued photo ID (PhilSys ID, passport, UMID, driver's licence, or equivalent)
• Selfie photograph for facial verification against submitted ID
• Proof of address (utility bill or bank statement not older than three months), where required

Technical & Device Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Session timestamps and duration
• Pages visited, games played, and in-session bet and win data

3How We Collect It

WinPH 4 collects personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or update your profile settings
• Automatically through the Platform — technical and device data is collected automatically when you access winph4.click or use any WinPH 4 game or feature
• From payment processors — GCash, Maya, and other payment partners share transaction confirmation data with WinPH 4 for the purpose of crediting your account and maintaining financial records
• From identity verification services — WinPH 4 may use licensed third-party KYC service providers to assist with document verification. These providers operate under strict data processing agreements with WinPH 4.

4Why We Process Your Data

WinPH 4 uses your personal data for the following specific purposes. Every purpose listed here corresponds to a legitimate legal basis described in Section 5:

5Legal Basis for Processing

Under R.A. 10173 and its implementing rules, WinPH 4 processes personal data on the following legal grounds:

• Contract performance — processing is necessary to fulfil the WinPH 4 Terms and Conditions you accepted at registration, including account operation and payment processing
• Legal obligation — WinPH 4 is required by Philippine law (including AMLA, gaming regulations, and tax law) to collect and retain certain data, regardless of your preferences
• Legitimate interest — WinPH 4 has a legitimate interest in preventing fraud, securing the Platform, monitoring for problem gambling behaviour, and improving the player experience. These interests do not override your fundamental privacy rights.
• Consent — for non-essential processing such as marketing communications and optional analytics cookies, WinPH 4 will obtain your explicit consent and provide a clear, easy mechanism to withdraw it at any time

6Sharing Your Data

WinPH 4 does not sell your personal data to third parties. We share your data only in the following limited circumstances, and only to the extent necessary for the stated purpose:

• Payment processors — GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, InstaPay/PESONet operators, and Visa/Mastercard payment networks receive the minimum data required to process your transaction
• KYC and identity verification providers — licensed third-party services that assist WinPH 4 in document verification under a strict data processing agreement
• Game providers — JILI Gaming and other game developers receive anonymised game session data (no personal identity data is transmitted) for technical and RNG audit purposes
• Regulatory and law enforcement authorities — the Anti-Money Laundering Council (AMLC), Bureau of Internal Revenue (BIR), and other Philippine government agencies, where legally required
• IT and security service providers — cloud infrastructure and cybersecurity vendors operating under data processing agreements that prohibit any independent use of your data

All third-party data processors engaged by WinPH 4 are contractually bound to process personal data only for the purposes instructed by WinPH 4, to maintain appropriate security standards, and to comply with R.A. 10173.

7International Data Transfers

WinPH 4 operates primarily within the Philippines and seeks to keep your data within Philippine jurisdiction where possible. However, certain technology infrastructure — including cloud hosting and cybersecurity services — may involve data storage or processing in other countries.

Where personal data is transferred outside the Philippines, WinPH 4 ensures that the transfer is covered by one of the following safeguards:

• The destination country has been determined by the National Privacy Commission (NPC) to provide an adequate level of data protection
• A data transfer agreement incorporating the NPC's standard contractual clauses is in place between WinPH 4 and the receiving entity
• The transfer is necessary for the performance of your WinPH 4 account contract, including payment processing via global card networks

8Data Retention

WinPH 4 retains personal data for the following periods, after which the data is securely deleted or anonymised:

• Active account data — retained for as long as your WinPH 4 account remains active
• Financial transaction records — retained for a minimum of 5 years from the date of the transaction, as required by Philippine tax law and AMLA record-keeping obligations
• KYC verification documents — retained for a minimum of 5 years from account closure or the last relevant transaction
• Support communications — retained for 3 years from the date of the last communication in a case
• Technical and session logs — retained for 12 months for security analysis and dispute resolution purposes
• Marketing consent records — retained for as long as the consent is active plus 3 years to demonstrate compliance

After the applicable retention period, WinPH 4 will delete or anonymise your data in a manner that prevents reconstruction. Anonymised, aggregated data (from which individual players cannot be identified) may be retained indefinitely for platform analytics and improvement purposes.

9Security Measures

WinPH 4 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or disclosure:

• Transport encryption: 256-bit SSL/TLS encryption on every page and API endpoint of winph4.click
• Data at rest encryption: All databases containing personal data are encrypted using AES-256
• Access controls: Role-based access control (RBAC) limits data access to staff with a verified operational need; all access is logged
• Two-factor authentication: Required for all internal WinPH 4 staff accounts that have access to player data
• Penetration testing: WinPH 4 engages an independent cybersecurity firm to conduct penetration testing at least annually
• Incident response plan: WinPH 4 maintains a documented data breach response plan with defined escalation procedures
• Staff training: All WinPH 4 employees undergo data privacy and security training upon joining and annually thereafter

10Cookies & Tracking Technologies

WinPH 4 uses cookies and similar tracking technologies on winph4.click. A cookie is a small text file placed on your device when you visit the Platform. Cookies help WinPH 4 keep you logged in, remember your preferences, understand how you use the Platform, and deliver relevant promotions.

You can manage your cookie preferences at any time through your WinPH 4 account settings or your browser's cookie management tools. Note that disabling optional cookies does not affect your ability to use the core Platform.

11Your Rights Under R.A. 10173

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by WinPH 4. To exercise any of these rights, contact our DPO at privacy@winph4.click or via live chat. WinPH 4 will respond to verified requests within 15 business days.

12Marketing Communications

WinPH 4 will only send you promotional emails, SMS messages, and in-platform notifications about bonuses, new games, and special offers if you have given explicit consent to receive them. Consent is obtained during registration and can be updated at any time in your account notification settings.

To opt out of all marketing communications from WinPH 4, you may:

• Click the unsubscribe link in any WinPH 4 marketing email
• Update your notification preferences in your account settings panel
• Contact support via live chat or at privacy@winph4.click

Opting out of marketing communications does not affect your receipt of transactional communications — account security alerts, deposit confirmations, withdrawal notifications, and support responses are sent regardless of your marketing preferences as they are necessary for the operation of your account.

WinPH 4 will never send marketing communications to players who are under a responsible gaming cooling-off period or self-exclusion restriction, regardless of their stated marketing preferences.

13Minors' Data

WinPH 4 is strictly an adult gaming platform. The minimum age to register is 21 years old. WinPH 4 does not knowingly collect or process personal data from individuals under 21 years of age. If WinPH 4 discovers that an account has been registered by a minor, the account will be closed immediately and all data associated with it will be securely deleted in accordance with applicable law.

If you believe a minor has registered at WinPH 4 using false information, please contact privacy@winph4.click or the support team via live chat immediately.

14Third-Party Links

The WinPH 4 platform does not contain links to external websites, social media platforms, or third-party services in its player-facing interface. Any promotional or informational content on WinPH 4 refers only to platform-internal pages.

Where WinPH 4's underlying game software is provided by third-party game developers such as JILI Gaming, those providers' servers receive anonymised game session data as described in Section 6. The privacy practices of game providers are governed by their own privacy policies, which WinPH 4 has reviewed and verified as a condition of offering their games on the Platform.

15Policy Updates

WinPH 4 will review this Privacy Policy at least annually and whenever there is a material change to how personal data is collected, used, or protected. When a material update is made, WinPH 4 will:

• Post the updated Privacy Policy at winph4.click/privacy-policy with a revised effective date
• Send an email notification to all registered players at least 7 days before the updated policy takes effect
• Display an in-platform alert for 14 days following any material update

Continued use of the WinPH 4 Platform after the effective date of an updated Privacy Policy constitutes your acceptance of the changes. If you do not accept a material change, you may close your account by contacting support before the effective date and requesting voluntary account closure as described in the Terms and Conditions.

16Contact Our Data Protection Officer

WinPH 4 has appointed a dedicated Data Protection Officer (DPO) in compliance with R.A. 10173. For any privacy-related matter — including data subject right requests, privacy concerns, or questions about this policy — please reach out to the WinPH 4 DPO directly:

• Email: privacy@winph4.click — dedicated DPO inbox, monitored daily
• Live Chat: Available 24/7 — ask to be connected to the Privacy team
• Response time: WinPH 4 commits to acknowledging all privacy requests within 3 business days and providing a substantive response within 15 business days

If your concern is not satisfactorily resolved by WinPH 4, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines. Details on how to file a complaint are available on the NPC's official website.

You can also find answers to the most common questions about accounts, payments, and data on our FAQ page. For full rules governing your use of WinPH 4, please review the Terms and Conditions.