Privacy Policy – How 43winph Protects Your Data in Philippines

43winph (referred to throughout this policy as "43winph," "we," "us," or "the platform") operates the online casino and sports betting platform accessible at 43winph.click. 43winph is the data controller for all personal data collected through this platform from Philippine-based players.

This Privacy Policy covers all personal data collected from:

• Registered players on the 43winph platform, whether active or inactive.
• Individuals who browse 43winph.click without registering, to the extent that device and session data is collected through cookies and analytics tools.
• Individuals who contact 43winph through customer support channels, including live chat and email.

This policy does not cover data practices of third-party game providers, payment gateways, or other external services — each of which maintains its own privacy policy. While 43winph selects service partners carefully, we encourage players to review the privacy policies of any third-party services they interact with directly.

The categories of personal data collected by 43winph, and the context in which each is collected, are set out in the table below:

43winph collects personal data through the following channels:

• Directly from you — when you register an account, complete identity verification, make a deposit or withdrawal request, contact customer support, or respond to a promotion.
• Automatically — through cookies, session tracking, and standard web analytics tools as you navigate the 43winph website and mobile platform. This includes your IP address, device identifiers, and behavioural data such as pages visited and time spent on the platform.
• From third-party verification services — when we use a KYC (Know Your Customer) provider to assist in verifying your identity documents. The verification provider processes your documents and returns a pass/fail result to 43winph; they do not retain your ID documents beyond the period required for the verification process.
• From payment processors — payment gateways such as GCash, Maya, and bank transfer services provide 43winph with transaction confirmations and reference numbers. 43winph does not receive or store your full GCash PIN, Maya password, or online banking credentials.

43winph uses personal data only for defined, legitimate purposes directly related to operating the platform and meeting our legal obligations. Those purposes are:

• Account creation and management — to open, maintain, and secure your 43winph player account.
• Identity and age verification — to confirm that you meet the 18+ age requirement and are who you say you are, as required by Philippine gaming regulations.
• Payment processing — to process deposits and withdrawals in Philippine Peso through your chosen payment method, and to maintain accurate transaction records.
• Regulatory compliance — to fulfil our obligations under RA 9160 (Anti-Money Laundering Act), PAGCOR regulations, and any other applicable Philippine laws, including filing required reports with the AMLC where mandated.
• Responsible gaming — to monitor gaming patterns that may indicate problematic gambling behaviour and to enforce player-requested limits, cool-down periods, and exclusions.
• Customer support — to respond to your queries, investigate complaints, and resolve disputes.
• Fraud prevention and security — to detect and prevent fraudulent account activity, money laundering, and platform abuse.
• Platform improvement — aggregated, anonymised analytics to understand how the 43winph platform is used so we can improve it for Filipino players.
• Marketing communications — with your explicit consent, to send you promotional offers and platform updates via email or SMS. You can withdraw this consent at any time through your account settings or by contacting support.

43winph does not use personal data for automated individual decision-making that produces significant legal effects without human review.

Under the Philippine Data Privacy Act of 2012, 43winph processes personal data on the following legal bases:

• Consent — You provide consent when you register and accept this Privacy Policy. Consent is also specifically obtained before we send marketing communications. Consent can be withdrawn at any time without affecting the lawfulness of prior processing.
• Contractual necessity — Processing your identity data, contact data, and financial data is necessary to fulfil the player account agreement between you and 43winph. Without this processing, the platform cannot function for your account.
• Legal obligation — Certain data processing is required by Philippine law — particularly identity verification and AML transaction monitoring under RA 9160 — regardless of your consent preferences.
• Legitimate interests — Security monitoring, fraud prevention, and platform analytics serve the legitimate interests of 43winph and its players, provided those interests do not override your fundamental privacy rights.

43winph does not sell your personal data. We share it only in the following circumstances and only to the minimum extent necessary:

• Payment processors — GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, Visa/Mastercard network processors — to execute deposits and withdrawals. Each payment partner operates under its own privacy and security framework.
• KYC and identity verification providers — Third-party KYC service providers who assist in verifying government IDs and age compliance. These providers are bound by data processing agreements with 43winph and may not use your verification data for any purpose beyond the verification service.
• Game software providers — Limited technical data (session tokens, RNG audit logs) is shared with game providers to operate and audit casino games on the 43winph platform. Game providers do not receive personally identifying information such as your name or payment details.
• Philippine government and regulatory authorities — 43winph will disclose personal data to the AMLC, PAGCOR, the National Privacy Commission, or law enforcement agencies when legally required to do so — for example, in response to a subpoena, regulatory audit, or suspicious transaction report filing.
• Professional advisors — Lawyers, auditors, and accountants who provide professional services to 43winph are bound by professional confidentiality obligations.
• Business successors — In the event of a merger, acquisition, or asset sale involving 43winph, player data may be transferred to the successor entity, with prior notice provided to affected players.

43winph retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by Philippine law. The general retention schedule is as follows:

• Active account data — retained for the duration of your active account relationship with 43winph.
• Transaction and gaming records — retained for a minimum of 5 years after the relevant transaction, as required by RA 9160 for AML compliance and PAGCOR regulations.
• Identity verification documents — retained for 5 years from the date of verification, or longer if required by a specific regulatory or legal hold.
• Customer support communications — retained for 3 years from the date of last interaction for dispute resolution and service improvement purposes.
• Marketing consent records — retained for the period of the marketing relationship plus 1 year after consent is withdrawn, for compliance evidence purposes.
• Technical/session data (cookies, logs) — typically retained for 90 days to 12 months depending on the data type and operational purpose.

When data is no longer required, 43winph securely destroys or anonymises it in a manner that prevents reconstruction of any personal identifier.

43winph takes the security of your personal data seriously and applies multiple layers of protection:

• TLS/SSL encryption on all data transmissions between your device and 43winph servers — all traffic is encrypted in transit.
• Encryption at rest for all sensitive personal data and financial records stored on 43winph systems.
• Access controls — only authorised 43winph staff who require access to your data to perform their job function can access it, under a principle of least privilege.
• Two-factor authentication (2FA) available to all players for account login, and required for staff accessing internal systems containing personal data.
• Regular security testing — 43winph conducts periodic security assessments of its platform infrastructure.
• Incident response procedures — 43winph maintains documented procedures for identifying, containing, and reporting personal data breaches in line with NPC requirements, including the 72-hour notification obligation.

Whilst 43winph takes all reasonable precautions, no online system can guarantee absolute security. You are also responsible for securing your own device and 43winph account credentials — do not share your password with anyone, and contact support immediately if you suspect unauthorised access to your account.

43winph uses cookies and similar tracking technologies to operate the platform, remember your session, and understand how Filipino players use the site so we can improve it. The types of cookies used on 43winph are:

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies will prevent you from logging into your 43winph account, as they are required for the session authentication system to function. Disabling analytics and functional cookies will not affect your ability to play — it simply means we have less data available to improve your experience.

43winph does not use cookies to serve third-party advertising on the platform or to track your browsing activity on other websites.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 43winph. All rights can be exercised by contacting us at support@43winph.click with the subject line "Data Subject Request."

43winph is strictly an 18+ platform. We do not knowingly collect personal data from individuals under the age of 18. If you are under 18, you must not register or attempt to use the 43winph platform under any circumstances.

If 43winph discovers or is informed that a player account belongs to an individual under the age of 18, we will immediately suspend the account, conduct age verification, and — where underage use is confirmed — permanently close the account and delete the associated personal data to the extent permitted by our legal obligations. Any funds associated with a confirmed underage account will be returned to the payment source used.

If you are a parent or guardian and you believe that a minor has registered on 43winph using your payment details, please contact our support team immediately. We will investigate and act promptly.

In the course of operating the 43winph platform, some personal data may be processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international game software studios whose servers are hosted in other jurisdictions.

Wherever cross-border transfers occur, 43winph ensures that:

• The receiving party is bound by data processing agreements that impose data protection standards equivalent to or exceeding those required by RA 10173.
• Transfers occur only to countries or organisations that provide adequate data protection, as recognised by the National Privacy Commission.
• You are informed of any such transfers through this Privacy Policy, which constitutes prior notification under applicable Philippine regulations.

43winph does not transfer your data to jurisdictions with materially weaker data protection frameworks without the appropriate contractual safeguards in place.

43winph reviews this Privacy Policy periodically and updates it when our data practices change, when applicable Philippine law is amended, or when new guidance is issued by the National Privacy Commission. The "Last Updated" date at the top of this page reflects the most recent revision.

Where changes are material — for example, a new category of data we intend to collect, or a new category of third party we intend to share data with — 43winph will notify registered players via email or in-platform notification at least 14 days before the changes take effect.

For non-material updates (corrections of typographical errors, clarifications that do not change the substance of our practices), changes may be published without prior notice. Your continued use of the 43winph platform after any policy update constitutes your acceptance of the revised Privacy Policy.

43winph has appointed a Data Protection Officer (DPO) responsible for overseeing our compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any question, concern, or request related to your personal data and its handling by 43winph, please reach out through any of the following:

• Email: support@43winph.click (subject line: "Privacy / Data Request")
• Live Chat: Available 24/7 through the 43winph platform. Ask to speak with the DPO team for privacy-specific matters.

We commit to acknowledging all data subject requests within 48 hours and providing a substantive response within 15 business days of receiving a valid request. Complex requests may require additional time, but we will communicate any extension to you with an explanation.