pbwin Privacy Policy

1. Introduction & Scope

pbwin ("we," "us," "our") operates the online gaming platform accessible at pbwin.org and all associated services (the "Platform"). This Privacy Policy describes how pbwin collects, processes, uses, stores, shares, and protects personal information relating to individuals who access, register on, or use the Platform ("you," "your," "Player").

This Policy applies to all personal data collected through the pbwin Platform, including data collected via the website, account registration forms, payment processing, customer support interactions, and any marketing communications to which you have subscribed.

By registering an Account with pbwin or by continuing to use the Platform, you confirm that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any aspect of this Policy, you should cease using the Platform and contact us to request account closure.

2. Legal Basis & Data Controller

pbwin is the data controller responsible for the personal data collected through the Platform. As data controller, pbwin determines the purposes and means by which your personal data is processed, and is accountable for ensuring that processing complies with applicable data protection law.

pbwin operates under the regulatory oversight of PAGCOR (Philippine Amusement and Gaming Corporation) and is subject to the National Privacy Commission of the Philippines. pbwin has appointed a Data Protection Officer (DPO) responsible for overseeing data privacy compliance. Enquiries related to data privacy may be directed to the pbwin support team, who will route them to the DPO as required.

pbwin processes personal data on the following legal grounds:

• Contractual necessity — processing required to fulfil our obligations under your Account agreement and these Terms & Conditions;
• Legal obligation — processing required to comply with PAGCOR regulations, Anti-Money Laundering Act requirements, and other applicable Philippine law;
• Legitimate interests — processing for fraud prevention, security monitoring, and platform improvement where these interests are not overridden by your fundamental rights;
• Consent — processing for marketing communications and non-essential analytics, where you have provided explicit opt-in consent.

3. Personal Data We Collect

pbwin collects personal data through several channels. The categories of data collected and the circumstances in which they arise are described below.

pbwin does not knowingly collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where government-issued ID documents are submitted for KYC purposes — in which case only the information necessary for identity verification is processed and stored.

4. How pbwin Uses Your Personal Data

pbwin uses the personal data collected for the following purposes:

1. Account creation and management — to register your pbwin Account, maintain account security, process authentication including OTP verification, and provide access to the Platform;
2. Payment processing — to process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, 7-Eleven, USDT TRC20, and Coins.ph, and to reconcile transaction records;
3. KYC and identity verification — to verify your age (21+ requirement), identity, and payment source ownership as required by PAGCOR and anti-money laundering regulations;
4. Gaming service delivery — to provide access to game content, record game outcomes, calculate balances, and apply bonus terms;
5. Responsible gaming — to monitor gaming activity for signs of problem gambling patterns, enforce self-exclusion requests, apply deposit limits, and send session reminders;
6. Fraud prevention and security — to detect and investigate suspicious account activity, unauthorised access attempts, bonus abuse, and other potential violations;
7. Customer support — to respond to queries, resolve disputes, and maintain records of support interactions;
8. Regulatory compliance — to fulfil reporting obligations to PAGCOR, Anti-Money Laundering Council (AMLC), and other relevant Philippine regulatory authorities;
9. Marketing communications — to send promotional offers, bonus notifications, and platform updates to Players who have opted in, via SMS to their registered Philippine mobile number;
10. Platform improvement — to analyse aggregated and anonymised usage data to improve Platform performance, game selection, and user experience.

5. Legal Grounds for Processing

pbwin only processes your personal data where a valid legal ground under the Data Privacy Act of 2012 (RA 10173) applies. The primary legal grounds used for each processing purpose are as follows:

• Account creation and management: Performance of contract (your Account agreement with pbwin);
• Payment processing: Performance of contract; legal obligation (PAGCOR licensing conditions);
• KYC verification: Legal obligation (PAGCOR regulations; AMLA compliance);
• Gaming service delivery: Performance of contract;
• Responsible gaming monitoring: Legal obligation; legitimate interests (player welfare);
• Fraud prevention and security: Legitimate interests; legal obligation;
• Regulatory reporting: Legal obligation;
• Marketing communications: Consent (explicit opt-in required; withdrawable at any time);
• Platform analytics: Legitimate interests (anonymised and aggregated data); Consent for non-essential cookie-based analytics.

6. Data Sharing & Disclosure

pbwin shares personal data only with parties where such sharing is necessary for the operation of the Platform, fulfilment of legal obligations, or explicit Player consent. The categories of recipients are described below.

• Payment processors: GCash (Globe Fintech Innovations), Maya (Paymaya Philippines Inc.), BPI, BDO, Metrobank, Bayad Center (7-Eleven), and blockchain network facilitators for USDT TRC20. Sharing is limited to transaction data required to process deposits and withdrawals.
• KYC and identity verification providers: Third-party identity verification services that process government-issued ID documents on behalf of pbwin for age and identity verification. These providers operate under data processing agreements with pbwin and are prohibited from using your data for any purpose other than verification.
• Game content providers: pbwin's game providers (including Jili, PG Soft, Pragmatic Play, and others) receive session tokens and Player IDs necessary to deliver game content. They do not receive your full identity data.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government agencies where pbwin is legally required to disclose data.
• Law enforcement: Philippine law enforcement agencies where pbwin receives a valid court order, subpoena, or lawful request, or where disclosure is necessary to prevent or report a crime.
• Professional advisers: Lawyers, auditors, and compliance consultants engaged by pbwin, subject to professional confidentiality obligations.

7. Data Retention

pbwin retains your personal data for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law and regulation. The primary retention periods that apply are:

Where pbwin is required by law to retain data beyond the periods listed above, the data will be retained for the legally mandated period and then securely deleted or anonymised. Data retained beyond an Account's active period is stored with restricted access controls limiting processing to the minimum necessary for the retention purpose.

8. Security Measures

pbwin implements technical and organisational security measures proportionate to the risk associated with processing your personal data. These measures include:

• TLS 1.3 encryption for all data in transit between your browser and pbwin servers;
• Encryption at rest for sensitive data fields including payment method references and identity document hashes;
• Password hashing — your pbwin account password is stored as a salted hash and is never recoverable in plain text form by any pbwin employee;
• OTP-based two-factor authentication for all account logins from unrecognised devices, delivered to your registered Philippine mobile number;
• Role-based access controls limiting staff access to personal data to those with a defined operational need;
• Brute-force login protection — accounts are temporarily locked after five consecutive failed authentication attempts;
• Continuous security monitoring of Platform infrastructure for anomalous access patterns and known attack signatures;
• Regular security assessments conducted by qualified personnel to identify and remediate vulnerabilities.

While pbwin implements industry-standard security measures, no online platform can guarantee absolute security against all possible threats. In the event of a security incident affecting your personal data, pbwin will follow the breach notification procedures described in Section 13 of this Policy.

9. Cookies & Tracking Technologies

pbwin uses cookies and similar technologies (including local storage and session tokens) on the Platform. Cookies are small text files placed on your device that help pbwin deliver and improve the gaming experience.

The categories of cookies used by pbwin are:

• Strictly Necessary Cookies: Required for core Platform functions including session authentication, maintaining your logged-in status, and processing deposits. These cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: Store your preferences such as language settings, display preferences, and recently played games. These enhance your experience but are not required for basic Platform access.
• Analytics Cookies: Collect anonymised and aggregated data on how Players use the Platform — including page visit frequency, session duration, and navigation paths — to help pbwin improve Platform design and performance. No individual Player is identified in analytics reports.

You can manage functional and analytics cookies through your browser settings. Most modern browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies will prevent you from logging in to your pbwin account and using most Platform features.

pbwin does not use third-party advertising cookies or allow external advertising networks to place tracking cookies on the Platform.

10. Your Data Rights Under RA 10173

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

1. Right to be informed — you have the right to know that pbwin is processing your personal data and to receive clear information about how it is used, as provided by this Privacy Policy;
2. Right to access — you may request a copy of the personal data pbwin holds about you, along with information about how it is processed;
3. Right to correction — you may request correction of inaccurate or incomplete personal data in your Account;
4. Right to erasure — you may request deletion of your personal data where processing is no longer necessary, your consent has been withdrawn, or processing is unlawful — subject to pbwin's legal retention obligations;
5. Right to object — you may object to processing based on legitimate interests, including profiling for marketing purposes;
6. Right to data portability — you may request a copy of your personal data in a structured, machine-readable format where technically feasible;
7. Right to lodge a complaint — you may file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe pbwin has violated your data privacy rights.

To exercise any of these rights, contact pbwin support via the 24/7 live chat function or by writing to [email protected] with the subject line "DATA PRIVACY REQUEST." pbwin will acknowledge all data rights requests within five (5) business days and complete processing within fifteen (15) business days, unless an extension is required due to complexity — in which case you will be notified.

Note that pbwin may be required by law to retain certain data even following a deletion request — particularly KYC records and transaction data subject to PAGCOR and AMLA retention requirements. Where full deletion is not possible, pbwin will delete all data that is not subject to a legal retention obligation.

11. Children, Minors & the 21+ Requirement

pbwin does not knowingly collect personal data from individuals under 21 years of age. Where pbwin discovers or is notified that a user under 21 has registered an Account or provided personal data, pbwin will:

• Immediately suspend the Account pending investigation;
• Return any deposits to the source payment method;
• Delete all personal data associated with the underage Account to the extent permitted by applicable law;
• Report the incident to relevant regulatory authorities where required.

If you are a parent or guardian and believe that a minor in your care has registered or used a pbwin Account, please contact pbwin support immediately via the 24/7 live chat.

12. International Data Transfers

pbwin's primary data infrastructure is located in Asia-Pacific. Some personal data may be processed by service providers operating outside the Philippines — specifically in connection with game content delivery, KYC verification, and payment processing services where providers may operate regional data centres.

Where personal data is transferred outside the Philippines, pbwin takes appropriate steps to ensure that the transfer is protected by:

• Data processing agreements incorporating standard contractual clauses consistent with NPC requirements;
• Transfers to countries, territories, or organisations assessed by pbwin as providing an adequate level of data protection;
• Binding corporate rules or equivalent protection mechanisms where applicable.

pbwin does not transfer personal data to jurisdictions that do not offer adequate data protection safeguards without first implementing appropriate contractual or technical protections.

13. Data Breach Notification Procedures

In the event of a personal data breach that poses a real risk of serious harm to affected individuals, pbwin will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03 and subsequent issuances.

Where a breach is likely to result in a high risk to your rights and interests, pbwin will also notify you directly via your registered Philippine mobile number and, where available, by email, providing the following information:

• A description of the nature of the breach in plain language;
• The categories and approximate number of individuals affected;
• The categories and approximate number of personal data records affected;
• The likely consequences of the breach;
• The measures pbwin has taken or is taking to address the breach;
• Steps you may take to protect yourself, such as changing your password.

Breach notifications will be provided as quickly as technically feasible. Where pbwin is unable to notify all affected individuals individually, a prominent notice will be posted on the pbwin Platform.

14. Third-Party Links & Services

The pbwin Platform may contain links to or integrate with third-party services — including game providers, payment gateways, and customer support tools. These third parties operate under their own privacy policies and terms, which govern their collection and use of your personal data.

pbwin is not responsible for the privacy practices of third-party services. We recommend that you review the privacy policies of any third-party provider with whom you share personal data in connection with your use of the Platform. pbwin selects third-party providers carefully and requires all service providers handling personal data on pbwin's behalf to operate under data processing agreements consistent with this Privacy Policy and RA 10173.

15. Changes to This Privacy Policy

pbwin reserves the right to update or amend this Privacy Policy at any time. Where changes are material — particularly changes that affect how we use your personal data or the rights available to you — pbwin will notify registered Players via SMS to their registered Philippine mobile number at least seven (7) days before the changes take effect.

The current version of this Privacy Policy is always accessible at pbwin.org/privacy-policy. The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of the Platform after the effective date of any amendment constitutes acceptance of the updated Policy.

If you have concerns about any proposed changes to this Privacy Policy, please contact pbwin support before the effective date. If you do not accept the updated Policy, you may request Account closure in accordance with the Account closure provisions in pbwin's Terms & Conditions.

16. Contact & Complaints

For all data privacy enquiries, access requests, correction requests, deletion requests, or complaints, please contact pbwin using the following channels:

• 24/7 Live Chat: Available directly on the pbwin Platform after logging in to your Account;
• Email: [email protected] — use the subject line "DATA PRIVACY REQUEST" for priority routing to the Data Protection Officer.

If you are not satisfied with pbwin's response to your data privacy enquiry or complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC is the independent government body responsible for overseeing data privacy compliance in the Philippines.