96win Privacy Policy

1. Who We Are

This Privacy Policy applies to the 96win online gaming platform, accessible at 96win.one ("Platform", "we", "us", "our"). 96win operates as an online casino and sports betting service targeting Filipino players and operates in alignment with the guidelines of the Philippine Amusement and Gaming Corporation (PAGCOR).

For the purposes of applicable data protection legislation — including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations — 96win acts as the Personal Information Controller in respect of the personal data you provide when using the Platform.

By registering an account or using any 96win service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2. Data We Collect

96win collects the following categories of personal data:

We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required for responsible gaming assessments or regulatory compliance.

3. How We Collect Your Data

96win collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification (KYC), making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: When you access the Platform, we automatically collect Technical Data and Usage Data via cookies, server logs, and similar tracking technologies. See Section 7 for details.
• Third-party sources: We may receive data from payment processors (e.g., GCash, Maya, BPI, BDO) to confirm transaction status, and from identity verification service providers to validate your government-issued ID.
• Publicly available sources: In limited circumstances, we may verify information against publicly available records for fraud prevention or regulatory compliance purposes.

4. Why We Use Your Data

96win uses your personal data for the following purposes:

• Account management: To create, maintain, and secure your 96win account, including authentication and password recovery.
• Service delivery: To provide access to games, process bets, calculate and credit winnings, and deliver the core gaming experience.
• Payment processing: To process deposits and withdrawals via your chosen payment method, and to maintain accurate financial records.
• Identity verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR guidelines and anti-money laundering (AML) regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, and other prohibited conduct.
• Responsible gaming: To monitor gaming patterns, enforce self-imposed limits, and identify players who may be at risk of problem gambling.
• Customer support: To respond to your enquiries, resolve disputes, and improve our support services.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given explicit consent or where we have a legitimate interest. You may opt out at any time.
• Legal and regulatory compliance: To comply with applicable Philippine laws, PAGCOR requirements, and any lawful requests from competent authorities.
• Platform improvement: To analyse usage patterns, conduct A/B testing, and improve the performance, design, and features of the Platform.

5. Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, 96win processes your personal data on the following legal bases:

• Consent: Where you have given clear, informed consent — for example, when opting in to marketing communications or agreeing to this Privacy Policy at registration.
• Contractual necessity: Where processing is necessary to perform the contract between you and 96win — for example, processing your deposits, running games, and paying out winnings.
• Legal obligation: Where processing is required to comply with a legal or regulatory obligation — for example, KYC verification, AML reporting, and responding to lawful authority requests.
• Legitimate interests: Where processing is necessary for 96win's legitimate business interests, provided those interests are not overridden by your rights — for example, fraud detection, platform security, and service improvement.

6. Sharing Your Data

96win does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following limited circumstances:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, solely to process your transactions.
• Identity verification providers: Third-party KYC service providers who assist in verifying your identity and age in compliance with regulatory requirements.
• Game providers: Licensed game studios whose games are hosted on the Platform may receive anonymised or pseudonymised gameplay data for technical and audit purposes.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection vendors who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where required by law or court order.
• Professional advisers: Lawyers, auditors, and accountants, subject to professional confidentiality obligations.

All third-party service providers who process personal data on behalf of 96win are required to implement appropriate technical and organisational security measures and to process data only in accordance with our instructions.

7. Cookies and Tracking Technologies

96win uses cookies and similar technologies (such as web beacons and local storage) to operate the Platform, remember your preferences, and analyse usage. The main types of cookies we use are:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled. They include session authentication tokens and security cookies.
• Functional cookies: Remember your preferences such as language settings, preferred games, and display options.
• Analytics cookies: Collect anonymised data about how users interact with the Platform, helping us identify popular features and areas for improvement.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may impair Platform functionality, including your ability to log in.

8. Data Retention

96win retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods include:

• Account and identity data: Retained for the duration of your account plus a minimum of five (5) years after account closure, in compliance with AML and PAGCOR record-keeping requirements.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming history: Retained for a minimum of three (3) years for dispute resolution and audit purposes.
• Support communications: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter.

After the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with you.

9. Data Security

96win implements industry-standard technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including financial data and government ID information;
• Role-based access controls ensuring that only authorised 96win personnel can access personal data, and only to the extent necessary for their role;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for internal systems that handle personal data;
• Staff training on data privacy obligations and secure data handling practices.

While we take every reasonable precaution, no method of transmission over the internet or electronic storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 96win will notify the National Privacy Commission (NPC) and affected users in accordance with the requirements of the Data Privacy Act of 2012.

10. Your Rights Under Philippine Law

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 96win:

• Right to be informed: You have the right to know what personal data we collect, why we collect it, and how it is used — which is the purpose of this Privacy Policy.
• Right of access: You may request a copy of the personal data we hold about you at any time.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our overriding legal obligations.
• Right to data portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: If you believe your data privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Children's Privacy

The 96win Platform is strictly intended for adults aged 21 years and older, in accordance with PAGCOR regulations governing casino-style gambling in the Philippines. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately at the details in Section 14.

12. International Data Transfers

96win primarily stores and processes your personal data within the Philippines. In certain circumstances, data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or game studios based in other jurisdictions.

Where such transfers occur, 96win ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under Philippine law. By using the Platform, you consent to such transfers where they are necessary for the provision of our services.

13. Changes to This Policy

96win may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. When we make material changes, we will post the revised policy on the Platform with an updated "Last Updated" date and, where appropriate, notify you via email or an in-platform notification.

We encourage you to review this Privacy Policy periodically. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated policy. If you do not agree with any changes, you should cease using the Platform and may request account closure in accordance with our Terms & Conditions.

14. Contact and Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact the 96win Data Privacy Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the Platform

We aim to acknowledge all data privacy requests within three (3) business days and to resolve them within fifteen (15) business days. For complex requests, we may require additional time and will inform you accordingly.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent authority responsible for enforcing the Data Privacy Act of 2012.