winqh Privacy Policy

1. Introduction

This Privacy Policy governs the collection, processing, storage, and disclosure of personal information by winqh, an online gaming platform accessible at https://winqh.net, in connection with the provision of its services to registered Filipino players and site visitors across the Philippines.

winqh takes its obligations under Republic Act No. 10173 (the Data Privacy Act of 2012, or "DPA") and the implementing rules and regulations issued by the National Privacy Commission ("NPC") very seriously. This Privacy Policy is intended to give you clear, honest, and complete information about how your personal data is handled — because at winqh, we believe that privacy is not a checkbox, it is a responsibility.

By accessing the winqh platform, creating an Account, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree, please discontinue use of the platform and contact us to request Account closure.

2. Who We Are

winqh is a PAGCOR-regulated online gaming platform serving Filipino players across the Philippines. As the operator of this platform, winqh acts as the Personal Information Controller ("PIC") as defined under Section 3(h) of the Philippine Data Privacy Act — meaning we determine the purposes and means of processing your personal data.

Where winqh engages third-party service providers (such as payment processors, game studios, and KYC verification partners) to process personal data on our behalf, those parties act as Personal Information Processors ("PIP") under our instructions and are contractually bound to handle your data with the same standard of care we apply ourselves.

winqh has appointed a Data Protection Officer ("DPO") in compliance with NPC requirements. You may contact our DPO directly regarding any privacy-related concern at the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

3.1 Information You Provide Directly

When you register an Account, complete KYC verification, make deposits or withdrawals, or contact our support team, you provide us with personal data including but not limited to:

• Full legal name as it appears on your Philippine government-issued identification;
• Date of birth (used to verify the 21+ age requirement);
• Residential address within the Philippines (barangay, city or municipality, province);
• Valid email address and Philippine mobile number;
• Government-issued photo identification documents (e.g., PhilSys National ID, passport, UMID, driver's license, Voter's ID, SSS ID);
• Proof of address documents (e.g., utility bill, bank statement, barangay certificate);
• Payment method details — GCash registered name, Maya account, BPI/BDO/UnionBank account name, or Coins.ph wallet information (we do not store full card numbers or PINs);
• Self-exclusion preferences and responsible gaming limit settings;
• Communications submitted via live chat, email, or support tickets.

3.2 Information Collected Automatically

When you visit or use the winqh platform, certain technical data is collected automatically through cookies, server logs, and similar technologies:

• IP address and approximate geographic location;
• Device type, operating system, and browser version;
• Session duration, pages visited, game titles launched, and betting activity logs;
• Referring URL and search terms used to find the winqh site;
• Cookie identifiers and local storage data as described in Section 7.

3.3 Information from Third Parties

winqh may receive personal data about you from third parties in limited circumstances, including:

• KYC and identity verification service providers who confirm your identity against Philippine government records;
• Payment processors confirming transaction status and account ownership;
• Fraud prevention and anti-money laundering screening services that flag high-risk patterns;
• PAGCOR and other regulatory bodies that share information relevant to our compliance obligations.

4. How We Use Your Personal Data

winqh uses the personal data we collect for the following specific, legitimate purposes:

Purpose	Data Used
Account registration and identity verification (KYC)	Name, date of birth, address, government ID, contact details
Processing deposits, withdrawals, and transaction records	Payment method details, account balance records, transaction logs
Delivering gaming services and maintaining platform functionality	Account data, device info, session logs, game activity
Customer support and dispute resolution	Contact details, support ticket history, account records
Fraud detection, anti-money laundering screening, and security	IP address, device fingerprint, transaction patterns, identity documents
Regulatory reporting to PAGCOR and other Philippine authorities	Identity data, transaction history, account activity as required by law
Responsible gaming — enforcing deposit limits, self-exclusion, and cooling-off periods	Account settings, gameplay duration, betting patterns
Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts)	Email address, mobile number
Sending promotional communications (where you have consented)	Email address, communication preferences
Platform improvement and analytics	Anonymized or aggregated usage data, cookie data

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, winqh processes your personal data on the following legal bases:

• Contractual Necessity: Processing is required to fulfill our obligations under the Terms and Conditions you agreed to upon Account registration — including Account management, payment processing, and game delivery;
• Legal Obligation: Processing is required to comply with Philippine law, including PAGCOR regulatory requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself;
• Legitimate Interests: Processing is necessary for winqh's legitimate interests in fraud prevention, platform security, and responsible gaming enforcement, provided these interests are not overridden by your privacy rights;
• Consent: For optional processing activities such as direct marketing communications and non-essential cookies, winqh relies on your freely given, specific, and informed consent. You may withdraw consent at any time without penalty.

6. Data Sharing and Disclosure

6.1 Service Providers and Processors

winqh shares personal data with carefully selected third-party service providers who process data on our behalf as Personal Information Processors. These include payment gateway operators (GCash/Maya integration partners, banking rails), KYC and identity verification providers, game content studios, cloud hosting and infrastructure providers, and customer support platform vendors. All such processors are contractually bound to process your data only as instructed by winqh and to maintain appropriate security measures.

6.2 Regulatory and Law Enforcement Authorities

winqh is required by Philippine law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities when required to do so by law, court order, or regulatory directive. winqh will disclose the minimum data necessary to satisfy such requirements.

6.3 No Sale of Personal Data

winqh does not sell, rent, lease, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes. Any data sharing outside the categories described in this Section 6 will only occur with your explicit prior consent.

6.4 Business Transfers

In the event of a merger, acquisition, or transfer of winqh's business operations, player personal data may be transferred as part of that transaction. In such circumstances, winqh will notify affected players and ensure the acquiring entity is bound by privacy obligations at least as protective as those in this Policy.

7. Cookies and Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device when you visit the winqh platform. They help the platform remember your preferences, maintain your session, detect fraud, and understand how Filipino players use our site so we can continue to improve the experience.

7.2 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the platform to function — maintaining your login session, remembering your language preference, and keeping your account secure. These cannot be disabled without breaking core functionality.
• Performance and Analytics Cookies: Collect anonymized data about how players navigate the platform — which pages are most popular, where users drop off, and which games are most-played. This data is used in aggregate form to improve winqh.
• Functional Cookies: Remember your preferences such as display settings, last-played games, and responsible gaming limit configurations.
• Marketing Cookies: Used only where you have consented, to deliver relevant promotions on the winqh platform. winqh does not use third-party cross-site advertising cookies.

7.3 Managing Cookies

You may manage or disable cookies through your browser settings at any time. Note that disabling strictly necessary cookies may affect the functionality of the winqh platform, including your ability to log in and maintain a session. Instructions for managing cookies are available in the help documentation of all major browsers.

8. Data Retention

winqh retains personal data for the period necessary to fulfill the purposes described in this Privacy Policy and to comply with our legal and regulatory obligations under Philippine law. The following general retention periods apply:

• Active Account Data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLC record-keeping requirements;
• KYC Documents: Retained for the duration of the Account relationship and for five (5) years after Account closure;
• Support and Communication Records: Retained for two (2) years from the date of the last interaction;
• Marketing Consent Records: Retained for the period of the consent and for one (1) year after withdrawal of consent, to evidence compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC-approved data disposal procedures.

9. Data Security

winqh implements a comprehensive set of technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• Encryption of data in transit using TLS 1.2 or higher across all platform connections;
• Encryption of sensitive personal data at rest in our databases;
• Role-based access controls limiting personal data access to authorized winqh personnel on a need-to-know basis;
• Multi-factor authentication requirements for all internal systems handling personal data;
• Regular security audits, vulnerability assessments, and penetration testing of platform infrastructure;
• Incident response procedures for personal data breaches, including NPC notification within 72 hours of discovery of a notifiable breach as required by NPC Circular 16-03.

10. Your Data Privacy Rights

Under Republic Act No. 10173 (the Philippine Data Privacy Act of 2012), you are entitled to the following rights with respect to your personal data held by winqh:

• Right to be Informed: The right to be informed about how your personal data is being collected and processed — which this Privacy Policy fulfills;
• Right of Access: The right to request a copy of the personal data winqh holds about you and information about how it is processed;
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal data where processing is no longer necessary or where the data was unlawfully processed — subject to winqh's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data where processing is based on legitimate interests or for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) at https://www.privacy.gov.ph if you believe winqh has violated your privacy rights.

To exercise any of these rights, please contact the winqh Data Protection Officer using the contact details in Section 14. winqh will respond to verified requests within fifteen (15) business days, consistent with NPC guidelines.

11. Minors and Age Restriction

The winqh platform is strictly intended for individuals who are at least 21 years of age in accordance with Philippine regulations applicable to casino-style online gaming. winqh does not knowingly collect personal data from persons under 21 years of age.

As part of the Account registration process, winqh collects and verifies date of birth information. Where winqh discovers or has reason to believe that personal data has been collected from a person under 21 years of age, winqh will immediately close the Account, delete the associated personal data (subject to any legal retention obligations), and report the incident to PAGCOR where required.

If you are a parent or guardian and believe that your child has registered with winqh, please contact us immediately at the details in Section 14 so we can take prompt action.

12. Third-Party Links and Integrations

The winqh platform may display links to third-party websites or resources in certain contexts. winqh does not control these third-party sites and is not responsible for their privacy practices or content. This Privacy Policy applies solely to data processed by winqh in connection with the winqh platform at https://winqh.net.

winqh integrates with third-party payment processors including GCash, Maya, BPI, BDO, UnionBank, Coins.ph, and 7-Eleven CLiQQ. When you initiate a payment through these services, your financial transaction data is processed by those providers under their own privacy policies and terms. winqh recommends you review the applicable privacy policies of any payment provider you use.

13. Changes to This Privacy Policy

winqh reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, Philippine law, NPC guidance, or PAGCOR requirements. The revised Privacy Policy will be published on the winqh platform with an updated Effective Date.

Where changes are material — for example, a significant new category of data collection or a new disclosure to a third party — winqh will notify registered Players via email or an in-platform notification with reasonable advance notice. Your continued use of the winqh platform after the revised Effective Date constitutes your acceptance of the updated Privacy Policy.

winqh encourages you to review this Privacy Policy periodically to stay informed about how we protect your data.

14. Contact Us — Data Protection Officer

For any privacy-related inquiries, requests to exercise your data subject rights, concerns about how winqh handles your personal data, or to reach our Data Protection Officer, please use the following contact channels. Note that the email address below is displayed as plain text only — it is not a clickable link. Please copy it manually into your email client:

Last Reviewed: 1 January 2026. This is the current governing version of the winqh Privacy Policy. Previous versions are available upon request.