phwen Privacy Policy

1. Introduction

phwen ("we", "our", or "us") is committed to protecting the privacy and personal information of all players, registered users, and visitors to the phwen Platform (available at phwen.co and associated mobile applications). This Privacy Policy explains what personal information phwen collects, the purposes for which we process it, how we protect it, and the rights you hold as a data subject under Philippine law.

This Privacy Policy is incorporated into and must be read together with phwen's Terms and Conditions. By registering a phwen account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2. Who We Are (Data Controller)

For the purposes of the Data Privacy Act of 2012, phwen is the Personal Information Controller in respect of the personal data collected through the Platform. phwen determines the purposes and means of processing your personal information.

phwen has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data privacy laws. Contact details for the DPO are provided in Section 15 of this Policy.

3. Personal Data We Collect

3.1 Registration and Identity Data

When you create a phwen account, we collect: your full legal name, date of birth, Philippine mobile number, email address (where provided), and username. For KYC verification purposes, phwen may additionally collect a copy of a government-issued identification document (e.g., Philippine National ID, passport, driver's licence, SSS ID, GSIS ID, Postal ID, or voter's ID) and a selfie photograph for identity matching.

3.2 Financial and Transaction Data

phwen collects data relating to deposits, withdrawals, and gaming transactions made through the Platform. This includes the amount, date, time, payment method used (e.g., GCash, Maya, BPI, BDO, Metrobank, InstaPay), and transaction reference numbers. phwen does not store full payment instrument credentials (such as complete GCash PINs or bank passwords) — payment authentication is handled directly by the relevant payment provider.

3.3 Gaming and Account Activity Data

phwen records data about your gaming activity on the Platform, including game sessions played, wagers placed, outcomes, bonus claims, and account balance history. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory compliance.

3.4 Technical and Device Data

When you access the phwen Platform, we automatically collect certain technical data, including: IP address, device type and model, operating system, browser type and version, session timestamps, and general geographic location (at city or regional level, derived from IP address). This data is used for security monitoring, fraud prevention, and Platform optimisation.

3.5 Communications Data

phwen retains records of communications between you and phwen's support team, including live chat transcripts and email correspondence. These records are used for quality assurance, dispute resolution, and staff training purposes.

4. How We Collect Your Data

phwen collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in phwen promotions.
• Automated collection: Technical data collected automatically when you access and use the Platform, including through cookies and similar tracking technologies (see Section 11).
• Third-party sources: phwen may receive identity verification data from third-party KYC service providers, fraud prevention databases, and payment processors in connection with account verification and transaction processing.

5. How We Use Your Personal Data

phwen processes your personal data for the following purposes:

• Creating and maintaining your phwen account, and verifying your identity and eligibility to use the Platform.
• Processing deposits, withdrawals, and gaming transactions, and maintaining accurate financial records.
• Providing customer support, resolving disputes, and responding to your inquiries.
• Complying with legal and regulatory obligations, including AML reporting requirements under the Anti-Money Laundering Act of 2001 (RA 9160) and PAGCOR regulatory requirements.
• Preventing fraud, money laundering, collusion, and other prohibited conduct on the Platform.
• Monitoring gaming activity for responsible gaming purposes and applying player protection measures where appropriate.
• Sending you account-related notifications, including transaction confirmations, security alerts, and promotional communications (where you have consented to receive marketing communications).
• Improving the phwen Platform, analysing usage patterns, and developing new features and services.
• Enforcing phwen's Terms and Conditions and other Platform policies.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, phwen processes personal data on the following lawful bases:

• Contractual necessity: Processing is necessary to perform the contract between phwen and the registered User (i.e., the phwen Terms and Conditions), including account creation, transaction processing, and game provision.
• Legal obligation: Processing is necessary for phwen to comply with applicable Philippine laws and regulations, including AML obligations, PAGCOR requirements, and NPC data privacy regulations.
• Legitimate interests: Processing is necessary for phwen's legitimate interests in preventing fraud, maintaining Platform security, and improving the Platform, where such interests are not overridden by the data subject's rights and freedoms.
• Consent: Where phwen processes personal data for purposes not covered by the above bases (such as sending marketing communications), phwen relies on your explicit, freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

phwen does not sell or rent your personal data to third parties. phwen may share your personal data with the following categories of recipients in the circumstances described:

• Payment processors and e-wallet providers (GCash, Maya, BPI, BDO, Metrobank, InstaPay, GrabPay, 7-Eleven CLiQQ): Necessary for processing your deposits and withdrawals.
• KYC and identity verification service providers: To verify your identity and age in compliance with phwen's regulatory obligations.
• Game software providers: Game providers may receive anonymised gameplay data necessary for the operation of their games on the Platform. No personally identifiable information is shared with game providers beyond what is technically necessary.
• Regulatory authorities: phwen may disclose personal data to PAGCOR, the AMLC, the NPC, and other Philippine government agencies where required by law or lawful order.
• Legal and professional advisers: phwen may share personal data with its legal counsel, auditors, and other professional advisers under obligations of confidentiality.
• Fraud prevention and security providers: phwen uses third-party services to assist with fraud detection, account security, and Platform integrity.

8. International Data Transfers

Where phwen transfers personal data to recipients located outside the Philippines — for example, to international game software providers or cloud infrastructure providers — phwen ensures that such transfers are subject to appropriate safeguards in accordance with the Data Privacy Act and NPC regulations. This may include data processing agreements incorporating standard contractual clauses, or transfers to jurisdictions recognised by the NPC as providing an adequate level of data protection.

By using the phwen Platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where such transfers are necessary for the provision of the Platform's services.

9. Data Retention

phwen retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention guidelines apply:

• Account data: Retained for the duration of your phwen account and for a period of five (5) years following account closure, in accordance with Philippine AML record-keeping requirements.
• Transaction data: Retained for a minimum of five (5) years following the date of the transaction, as required under the Anti-Money Laundering Act.
• KYC documentation: Retained for five (5) years following account closure or the completion of the last transaction, whichever is later.
• Support communications: Retained for two (2) years following the date of the communication, unless retention for a longer period is required for dispute resolution or regulatory purposes.
• Marketing consent records: Retained for the duration of the consent, plus three (3) years following withdrawal of consent.

Following the expiry of the applicable retention period, phwen will securely delete or anonymise your personal data in accordance with its data disposal procedures.

10. Security Measures

phwen implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS 1.3 encryption for all data transmitted between your device and phwen's servers.
• Encryption of sensitive stored data, including password hashing using industry-standard algorithms.
• Two-factor authentication (2FA) for user accounts and for phwen's internal administrative systems.
• Role-based access controls ensuring that phwen staff access personal data only on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability management procedures.
• Incident response procedures for the prompt detection, containment, and reporting of personal data breaches in accordance with NPC notification requirements.

11. Cookies & Tracking Technologies

phwen uses cookies and similar tracking technologies (including session tokens and local storage) to operate the Platform, maintain your login session, personalise your experience, and analyse Platform usage. The following categories of cookies are used by phwen:

• Strictly necessary cookies: Required for the Platform to function and cannot be disabled. These include session authentication cookies and security cookies.
• Functional cookies: Enable personalisation features such as language preferences and saved game settings.
• Analytics cookies: Used to collect aggregated, anonymised data about how users interact with the Platform, helping phwen improve its services. Analytics data is not linked to individual user identities.

You may manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will affect the functionality of the phwen Platform. phwen does not use third-party advertising cookies or cross-site tracking technologies.

12. Children's Privacy

The phwen Platform is strictly intended for individuals who are 21 years of age or older. phwen does not knowingly collect personal data from individuals under the age of 21. If phwen becomes aware that personal data has been collected from a person under 21, phwen will immediately delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on phwen without your knowledge, please contact phwen support immediately at [email protected] so that appropriate action can be taken without delay.

13. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal data held by phwen:

• Right to be informed: The right to be informed of the existence of processing, the nature of the personal data being processed, and the purpose for which they are being processed.
• Right of access: The right to obtain from phwen confirmation of whether your personal data is being processed, and to access a copy of that data.
• Right to correction: The right to correct inaccurate or incomplete personal data held by phwen.
• Right to erasure or blocking: The right to request the deletion or blocking of personal data where phwen no longer has a lawful basis for retaining it, subject to legal retention obligations.
• Right to object: The right to object to the processing of your personal data, including for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to damages: The right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of personal data.
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that phwen has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact phwen's Data Protection Officer using the contact details in Section 15. phwen will respond to all data subject requests within a reasonable timeframe as required by applicable law.

14. Changes to This Privacy Policy

phwen reserves the right to update or amend this Privacy Policy at any time to reflect changes in its data processing practices, applicable law, or regulatory requirements. Where amendments are material, phwen will notify registered users via the Platform or by email to the registered account address prior to the changes taking effect.

The date of the most recent revision to this Privacy Policy is displayed at the top of this page. Your continued use of the phwen Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or phwen's processing of your personal data, please contact phwen's Data Protection Officer:

• Email: [email protected] (mark your subject line "Data Privacy Request")
• Live Chat: Available 24/7 on the phwen Platform — mention "data privacy" to be connected with the DPO team

phwen endeavours to acknowledge all data privacy requests within 72 hours of receipt and to respond substantively within the timeframes required by the Data Privacy Act.

If you are not satisfied with phwen's response to your data privacy request, you may lodge a complaint with the National Privacy Commission at privacy.gov.ph.