66winph Privacy Policy — How We Protect Your Personal Data

1. Introduction

This Privacy Policy describes how 66winph ("we," "us," "our," or "the Platform") collects, uses, stores, and protects personal information provided by players and visitors ("you," "your") in connection with the 66winph website and mobile application located at 66winph.app.

66winph is committed to protecting your privacy and to processing your personal data responsibly, transparently, and in full compliance with the Republic of the Philippines Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and applicable issuances from the National Privacy Commission (NPC). If any part of this policy is unclear, we encourage you to reach out to our Data Protection Officer before submitting personal information.

By creating a 66winph account, using any feature of the platform, or voluntarily submitting personal data through our contact or registration forms, you acknowledge that you have read this Privacy Policy and consent to its terms. If you do not agree with any part of this policy, please do not create an account or continue using 66winph.

2. Data Controller Identity

For the purposes of the Data Privacy Act of 2012, the data controller responsible for the personal information processed through the 66winph platform is the 66winph operating entity. The platform is operated under the domain 66winph.app and all data-related enquiries, access requests, or complaints should be directed to our Data Protection Officer at the contact details provided in Section 15 of this policy.

66winph maintains a registered Data Protection Officer (DPO) in accordance with NPC requirements. The DPO is responsible for overseeing compliance with the Data Privacy Act, responding to player data requests, and coordinating with the National Privacy Commission where necessary.

3. Personal Data We Collect

66winph collects personal data in different categories depending on your relationship with the platform. The following table summarises the types of personal data we may collect and hold:

4. How We Collect Personal Data

66winph collects personal data through the following channels:

4.1 Directly From You

You provide data directly when you register a 66winph account, complete the KYC verification process, make a deposit or withdrawal, contact customer support, respond to promotions, or fill in any other form on the platform. This is the primary source of your identity, contact, and financial data.

4.2 Automatically Through Platform Use

When you access 66winph — whether through a browser or the mobile application — our servers automatically collect technical data including your IP address, device identifiers, browser type, and session activity. This data is collected to ensure platform security, detect fraud, comply with regulatory requirements, and improve the user experience.

4.3 From Third-Party Payment Providers

When you initiate a deposit or withdrawal through GCash, Maya, or another payment channel, the relevant payment provider may pass confirmation data — such as transaction reference numbers and the last few digits of the registered account — to 66winph to reconcile the transaction. We do not receive or store full financial account credentials from these providers.

4.4 From Identity Verification Services

Where required under our compliance obligations, 66winph may use a certified third-party KYC (Know Your Customer) service provider to verify the authenticity of identity documents you submit. The result of the verification check is shared with 66winph, but the raw document images are subject to the data handling terms of the verification service provider, which are governed by their own privacy policy.

5. How 66winph Uses Your Personal Data

66winph uses personal data only for specific, legitimate purposes. The table below sets out each purpose alongside the data used and the lawful basis:

• Account creation and management — To register your account, maintain your profile, and provide access to 66winph features. Without this, no account can exist.
• Payment processing — To process deposits and withdrawals via your chosen Philippine payment channel (GCash, Maya, BDO, BPI, etc.) and to reconcile transactions.
• Identity and age verification — To confirm that you meet the 21+ age requirement and that your identity matches the payment method on file, as required under our gaming licence conditions.
• Fraud prevention and security — To detect and prevent fraudulent activity, money laundering, multiple account creation, and misuse of the bonus system.
• Regulatory compliance — To fulfil obligations under Philippine gaming regulations, anti-money laundering (AMLA) requirements, and NPC data privacy obligations.
• Responsible gaming — To monitor gaming patterns and apply responsible gaming tools where appropriate, in accordance with our Responsible Gaming policy.
• Customer support — To respond to enquiries, complaints, and requests, and to maintain records for dispute resolution.
• Platform improvement — To analyse aggregated usage data and improve features, performance, and the overall player experience.
• Marketing communications — To send promotional offers, bonus notifications, and platform updates to players who have consented to receive them. You may unsubscribe at any time.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, 66winph must have a lawful basis for processing your personal data. The primary bases 66winph relies on are:

• Performance of a contract: Processing necessary to fulfil the 66winph account agreement with you — including account management, payment processing, and bet settlement.
• Compliance with a legal obligation: Processing required to comply with gaming regulations, AMLA obligations, tax reporting, and NPC directives.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and improvement of services, where these interests are not overridden by your rights and freedoms.
• Consent: For optional marketing communications and non-essential cookies. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

7. Data Sharing and Disclosure

66winph shares personal data with third parties only where strictly necessary and under appropriate data protection safeguards. We do not sell personal data. Circumstances where data may be shared include:

7.1 Payment Service Providers

To process your deposit or withdrawal, 66winph shares the minimum necessary transaction data with your selected Philippine payment provider (GCash, Maya, BDO, BPI, UnionBank, etc.). Each payment provider processes data under their own privacy policy and applicable regulations.

7.2 Identity Verification Partners

During KYC, identity document data is shared with our certified verification partner to authenticate your identity. This partner is bound by contractual data protection obligations consistent with RA 10173 requirements.

7.3 Game Software Suppliers

To operate casino and live dealer games, certain session-level technical data (device type, session ID) is shared with the relevant game software supplier (e.g., JILI). Personal identity data is not shared with game suppliers.

7.4 Regulatory and Legal Authorities

66winph may disclose personal data to the Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement bodies, or a court order, where required or permitted by applicable law. We will notify you of such disclosures where legally permitted to do so.

7.5 Business Continuity

In the event of a merger, acquisition, or transfer of substantially all of 66winph's assets, player data may be transferred to the acquiring entity under equivalent privacy protections. Affected players will be notified in advance where practicable.

8. Data Retention

66winph retains personal data only for as long as necessary to fulfil the purpose for which it was collected, subject to minimum retention requirements under applicable Philippine regulations. In general:

• Account and gaming records are retained for a minimum of 5 years after account closure, as required under gaming regulatory obligations and AMLA retention rules.
• KYC documents are retained for 5 years following the end of the customer relationship, per AMLA requirements.
• Financial transaction records (deposit/withdrawal history) are retained for 5 years to comply with AMLA and tax reporting obligations.
• Support communications are retained for 3 years from the date of the last interaction, to facilitate dispute resolution and service improvement.
• Marketing consent records are retained until you withdraw consent or close your account, whichever is earlier.
• Technical/log data is retained for a maximum of 12 months, after which it is aggregated and anonymised.

When personal data is no longer required and no legal obligation to retain it exists, 66winph securely deletes or anonymises the data in accordance with our internal data destruction procedures.

9. Data Security Measures

66winph implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

• TLS/SSL encryption for all data transmitted between your device and 66winph servers.
• AES-256 encryption for sensitive data stored in our databases, including identity and payment records.
• Role-based access controls so that only authorised 66winph personnel with a legitimate operational need can access personal data.
• Multi-factor authentication for all internal systems handling player personal data.
• Regular security audits and penetration testing by independent cybersecurity professionals.
• Data breach response procedures in line with NPC notification requirements — we will notify affected players and the NPC within 72 hours of discovering a breach that poses a real risk to rights and freedoms.

While 66winph takes all reasonable measures to protect your data, no internet-based system can be guaranteed 100% secure. You are responsible for protecting your own account credentials. If you suspect unauthorised access to your 66winph account, contact support immediately.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to the personal data 66winph holds about you. These rights are free to exercise and will be responded to within 30 days of a verified request:

To exercise any of the above rights, contact the 66winph Data Protection Officer at the details in Section 15. We may need to verify your identity before processing a request. No fee is charged for rights requests unless they are manifestly unfounded, excessive, or repetitive.

11. Cookies and Tracking Technologies

66winph uses cookies and similar technologies to operate the platform, maintain your login session, remember preferences, detect fraud, and analyse aggregate usage patterns. Cookies are small text files stored on your device when you visit 66winph.app.

11.1 Types of Cookies Used

• Strictly necessary cookies: Required for the platform to function, including session management, login authentication, and security checks. These cannot be disabled.
• Functional cookies: Remember your preferences (language, display settings) between visits. Can be disabled, but doing so may affect platform behaviour.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate the platform, used to improve features and performance. No personal identity data is included in analytics reports.

11.2 Managing Cookies

You can manage cookie preferences through your browser settings. Most browsers allow you to refuse non-essential cookies or delete stored cookies at any time. Note that disabling cookies may affect your ability to use certain features of the 66winph platform, including maintaining a login session.

66winph does not use advertising cookies, tracking pixels for third-party advertising networks, or social media tracking technologies.

12. Protection of Minors

The 66winph platform is strictly intended for adults aged 21 and over. We do not knowingly collect personal data from individuals under the age of 21. If during the KYC verification process we determine that a player is under 21, the account will be immediately suspended and all funds returned to the registered payment method. Any bonus winnings generated by an underage account are forfeited.

If you believe that a person under the age of 21 has created a 66winph account, please contact our support team or Data Protection Officer immediately. We take age restriction compliance seriously and will act on all such reports promptly.

13. Cross-Border Data Transfers

Some of the third-party service providers used by 66winph — including certain game software suppliers and infrastructure providers — may be located outside the Philippines. Where personal data is transferred outside the Philippines, 66winph ensures that appropriate safeguards are in place to protect the data in a manner consistent with RA 10173. These safeguards may include contractual data protection clauses, certification of the receiving party's compliance with equivalent privacy standards, or explicit confirmation that the destination country has been assessed as providing adequate data protection.

66winph will not transfer personal data to a third country or international organisation unless the relevant safeguards are in place and the transfer is authorised under applicable Philippine data privacy law.

14. Changes to This Privacy Policy

66winph may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or guidance from the National Privacy Commission. When significant changes are made — for example, to the types of data collected or the parties with whom data is shared — we will notify registered players via email at least 7 days before the updated policy takes effect.

The effective date at the top of this document will be updated with each revision. The current version of the Privacy Policy is always accessible at 66winph.app/privacy-policy. Continued use of the 66winph platform after the effective date of an updated policy constitutes acceptance of the revised terms. If you do not agree with changes, you may request account closure before the effective date.

15. Contact Us and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data rights under RA 10173, please contact the 66winph Data Protection Officer using the details below. All privacy-related enquiries are treated as confidential and will be handled with priority.

If your concern is not resolved to your satisfaction after contacting 66winph, you have the right to file a complaint with the National Privacy Commission of the Philippines. For more information on how to file a complaint, visit the NPC's official website.