phwn Privacy Policy

phwn operates phwn.asia and is the data controller responsible for the personal data of its registered players and website visitors. As data controller, phwn determines the purposes and means by which your personal information is processed in connection with the phwn gaming platform.

phwn has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations. The DPO may be contacted at [email protected].

phwn processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to register your account, verify your identity, process deposits and withdrawals, and provide gaming services pursuant to your agreement with phwn.
• Legal Obligation: Processing required to comply with anti-money laundering (AMLA) obligations, tax reporting requirements, and any regulatory directives from PAGCOR or the NPC.
• Legitimate Interests: Processing for fraud prevention, platform security monitoring, responsible gaming analysis, and service improvement, where such interests do not override your fundamental rights.
• Consent: Processing for marketing communications and non-essential analytics, where you have provided specific, informed consent. You may withdraw consent at any time.

phwn uses the personal data it collects for the following specific purposes:

• Account Registration & KYC Verification: To create your phwn account, verify your identity and age (21+ requirement), and comply with Know Your Customer obligations.
• Payment Processing: To facilitate deposits via GCash, PayMaya, BPI, BDO, and Metrobank, and to process withdrawal requests to verified payment methods in your name.
• Gaming Services: To provide access to phwn's game library, record gaming history, calculate and award winnings, and administer bonuses and promotions.
• Responsible Gaming: To monitor gaming patterns, identify signs of problematic gambling behavior, and administer deposit limits, session controls, and self-exclusion measures.
• Security & Fraud Prevention: To detect and prevent unauthorized account access, fraudulent transactions, collusion, bonus abuse, and money laundering activity.
• Regulatory Compliance: To fulfill reporting obligations to relevant Philippine regulatory bodies and to maintain records as required by law.
• Customer Support: To respond to queries, resolve complaints, and maintain records of support interactions for quality and accountability purposes.
• Marketing (with consent): To send promotional communications about new games, bonuses, and phwn platform updates, where you have opted in to receive such communications.

phwn does not sell your personal data. phwn may share your personal data with third parties only in the following circumstances:

• Payment Processors: GCash (GXI), PayMaya (Maya Bank), BPI, BDO, and Metrobank receive only the minimum transaction data necessary to process payments and withdrawals.
• KYC Verification Providers: phwn uses third-party identity verification services to validate government-issued IDs. These providers are contractually bound to process data only for the stated verification purpose.
• Game Content Providers: phwn's game software providers may receive anonymous gaming session data for RNG certification and gameplay analytics. No personally identifiable information is shared with game providers beyond what is technically necessary.
• Regulatory Authorities: phwn will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the NPC, or other Philippine government agencies when required by law or pursuant to a valid legal order.
• Law Enforcement: phwn will cooperate with legitimate law enforcement requests and disclose information when required to do so by applicable Philippine law.

All third-party data processors engaged by phwn are subject to data processing agreements that prohibit any use of your data beyond the specific purpose for which it was shared.

phwn uses cookies and similar tracking technologies to operate the platform, maintain your login session, remember your preferences, and analyze platform usage. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the phwn platform to function. These cannot be disabled. They include session authentication tokens, CSRF protection tokens, and load balancing cookies.
• Functional Cookies: Remember your language preference, display settings, and phwn login "remember me" selection. These can be disabled but may affect platform functionality.
• Analytics Cookies: Collect anonymous data about how players navigate phwn — page views, session duration, feature usage. Used to improve the platform experience. These are enabled only with your consent.
• Security Cookies: Used to detect fraudulent login attempts, bot activity, and other security threats. These are strictly necessary and cannot be disabled.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent phwn from functioning correctly.

phwn retains personal data for as long as necessary to fulfill the purpose for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account & KYC Data: Retained for a minimum of 5 years from the date of account closure, in compliance with Anti-Money Laundering Act (AMLA) requirements.
• Financial Transaction Records: Retained for a minimum of 5 years from the transaction date, as required by AMLA and BIR recordkeeping regulations.
• Gaming History: Retained for 2 years from the date of each gaming session. Extended retention may apply where records are relevant to a pending dispute or investigation.
• Customer Support Records: Retained for 3 years from the date of the last interaction.
• Marketing Consent Records: Retained until consent is withdrawn, plus 1 year for compliance documentation.

Upon expiry of the applicable retention period, phwn will securely delete or anonymize your personal data.

phwn implements the following technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

• AES-256 encryption for data at rest; TLS 1.3 for all data in transit
• Multi-factor authentication for all phwn administrative access
• Regular penetration testing and vulnerability assessments by independent security firms
• Access controls ensuring personal data is accessible only to phwn staff with a documented legitimate need
• Audit logging of all access to personal data records
• Regular staff training on data privacy obligations and security procedures
• Incident response procedures aligned with NPC breach notification requirements

phwn's services are strictly intended for individuals who are 21 years of age or older. phwn does not knowingly collect personal data from persons under the age of 21. All account registrations are subject to age verification through KYC processes.

If phwn becomes aware that personal data has been collected from a minor — whether through fraudulent registration or error — the account will be immediately suspended, any deposits will be refunded, and all associated personal data will be deleted from phwn's systems without undue delay.

If you believe a minor has created a phwn account, please contact phwn support immediately at [email protected].

phwn's primary data processing infrastructure is located within the Philippines. Where data processing activities involve service providers or technology infrastructure located outside the Philippines — such as cloud services or game content delivery networks — phwn ensures that such transfers comply with the Data Privacy Act of 2012 and that recipient parties provide an adequate level of data protection.

International transfers of personal data are conducted only under appropriate safeguards, including data processing agreements incorporating the standard contractual clauses recognized by the NPC, or equivalent protective measures.

phwn may update this Privacy Policy from time to time to reflect changes in data processing practices, Philippine legal requirements, or platform operations. Material changes will be communicated to registered players via their registered mobile number or email address at least 7 days before the updated policy takes effect.

The "Effective Date" at the top of this Privacy Policy indicates when the current version entered into force. Continued use of phwn following notification of an updated Privacy Policy constitutes your acceptance of the revised terms.

For all privacy-related inquiries, data subject rights requests, complaints, or questions about phwn's data practices, please contact phwn's Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 from within the phwn platform after login
• Response Time: phwn's DPO will acknowledge all privacy requests within 5 business days and resolve them within 15 business days of receipt.

If you are not satisfied with phwn's response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.