manilawin Privacy Policy

1. Scope and Application

This Privacy Policy ("Policy") describes how manilawin ("manilawin," "we," "us," or "our") collects, uses, stores, discloses, and otherwise processes personal data relating to users ("you," "Player") of the manilawin online gaming platform accessible at manilawin.app and any associated mobile web application (the "Platform").

This Policy applies to all personal data processed in connection with your manilawin account, your use of games and betting services, your interactions with manilawin customer support, and your visits to the Platform. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy.

This Policy should be read alongside our Terms & Conditions, which govern the overall relationship between you and manilawin. In the event of any inconsistency between this Policy and the Terms & Conditions specifically relating to data privacy, this Policy shall prevail.

2. Personal Data We Collect

manilawin collects the following categories of personal data:

2.1 Registration and Identity Data. Full legal name, date of birth, nationality, email address, mobile number, and residential address as provided during account registration.

2.2 Identity Verification (KYC) Data. Government-issued identification document type and number (PhilSys ID, passport, driver's license, SSS ID, UMID, or PRC ID), and where required, a selfie or facial photograph for identity verification purposes.

2.3 Financial Data. Payment method details including GCash mobile number, PayMaya account reference, bank account name and number (for BPI, BDO, Metrobank transfers). manilawin does not store full payment card numbers.

2.4 Transaction Data. Records of all deposits, withdrawals, bonuses credited and redeemed, and individual game bets placed on your manilawin account.

2.5 Technical and Usage Data. IP address, device type, browser type and version, operating system, session timestamps, pages visited, and game activity logs.

2.6 Communications Data. Records of your communications with manilawin customer support, including live chat transcripts and emails.

2.7 Responsible Gaming Data. Information you provide when using responsible gaming tools, such as deposit limit settings, self-exclusion requests, and responsible gaming questionnaire responses.

3. How We Collect Your Data

manilawin collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or use responsible gaming tools on the manilawin Platform.
• Automatically — through cookies, server logs, and similar tracking technologies when you access or use the Platform, as described in Section 6.
• From payment service providers — transaction confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank when you initiate payment transactions linked to your manilawin account.
• From identity verification services — where manilawin uses third-party KYC service providers to verify the authenticity of identity documents submitted during account verification.
• From fraud prevention services — risk signals and flagged patterns from third-party fraud detection systems used to protect the manilawin platform and its players.

4. Purposes and Legal Bases for Processing

manilawin processes your personal data for the following purposes and on the following legal bases under the Data Privacy Act of the Philippines:

• Account creation and management — necessary for the performance of the contract between you and manilawin.
• Identity verification (KYC) — necessary for compliance with Philippine anti-money laundering regulations and responsible gaming obligations.
• Payment processing — necessary for the performance of the contract; enables deposits and withdrawals via your registered manilawin payment methods.
• Fraud detection and prevention — based on manilawin's legitimate interest in protecting the Platform and its players from fraudulent activity.
• Responsible gaming management — necessary for compliance with applicable gaming regulations and manilawin's duty of care to players.
• Customer support — based on legitimate interest and, where applicable, performance of contract.
• Legal and regulatory compliance — necessary for compliance with applicable Philippine laws, including anti-money laundering, tax, and gaming regulations.
• Service improvement and analytics — based on manilawin's legitimate interest in improving platform performance and player experience, using aggregated or anonymised data where possible.
• Marketing communications — based on your consent, which you may withdraw at any time by updating your communication preferences in account settings.

5. Disclosure of Personal Data

manilawin does not sell your personal data. We may share your personal data with the following categories of recipients:

• Payment service providers — GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, to the extent necessary to process your transactions.
• Identity and KYC verification providers — third-party services that assist in verifying the identity documents you submit during account verification.
• Fraud prevention and security services — providers that help identify and prevent fraudulent activity on the manilawin Platform.
• IT and infrastructure providers — cloud hosting, database, and content delivery network providers that process data on manilawin's behalf under appropriate data processing agreements.
• Regulatory and law enforcement authorities — where required by applicable Philippine law, court order, or regulatory direction, including AMLC and other competent bodies.
• Professional advisors — lawyers, accountants, and auditors, subject to professional confidentiality obligations.

All third parties with whom manilawin shares personal data are required to process it only for the purposes specified, in accordance with manilawin's instructions, and subject to appropriate security measures.

6. Cookies and Tracking Technologies

The manilawin Platform uses cookies and similar tracking technologies to operate core platform functionality, analyse usage patterns, and detect fraud. The following types of cookies are used:

• Strictly necessary cookies — required for the Platform to function, including maintaining your login session and remembering in-game state. These cannot be disabled without impairing Platform functionality.
• Analytics cookies — used to understand how players interact with the manilawin Platform in aggregate, enabling us to improve performance and navigation. Data is anonymised where feasible.
• Security cookies — used to detect suspicious login activity and protect against cross-site request forgery and other security threats on the manilawin Platform.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to play games or access your manilawin account, though some analytical features may be limited.

7. Data Security

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

• TLS/SSL encryption for all data transmitted between your device and the manilawin Platform;
• Encryption at rest for stored personal and financial data;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Two-factor authentication available for all manilawin player accounts;
• Automated monitoring for suspicious account activity with real-time alerts.

Notwithstanding these measures, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in high risk to your rights and freedoms, manilawin will notify affected players and the National Privacy Commission as required by applicable law.

8. Data Retention

manilawin retains personal data for the following periods:

• Account and KYC data — retained for the duration of your manilawin account plus a minimum of five (5) years after account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction records — retained for a minimum of five (5) years from the date of each transaction.
• Support communications — retained for three (3) years from the date of the communication.
• Technical and usage logs — retained for up to twelve (12) months, unless extended for security investigation purposes.
• Marketing consent records — retained for as long as you remain a registered manilawin player or until you withdraw consent, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised.

9. International Data Transfers

Some of manilawin's third-party service providers operate servers outside the Philippines. Where personal data is transferred internationally, manilawin ensures that appropriate safeguards are in place, including contractual clauses consistent with the requirements of the National Privacy Commission, to ensure that your data receives a standard of protection equivalent to that provided under Philippine law.

10. Your Rights Under Philippine Law

Under the Data Privacy Act of the Philippines (Republic Act No. 10173), you have the following rights with respect to your personal data held by manilawin:

To exercise any of the above rights, contact the manilawin Data Protection Officer at the details provided in Section 13. manilawin will respond to verified requests within thirty (30) days. Some rights may be subject to limitations where retention of data is required by law or for the establishment, exercise, or defence of legal claims.

11. Children's Privacy

The manilawin Platform is strictly restricted to individuals who are 21 years of age or older. manilawin does not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately close the associated account, delete the data, and take steps to prevent further data collection from that individual.

If you believe that a person under 21 has registered an account or provided personal data to manilawin, please contact our support team immediately so that we can take appropriate action.

12. Changes to This Policy

manilawin reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform functionality. Material changes will be communicated to registered manilawin players via email or a prominent notice on the Platform at least seven (7) days before the updated Policy takes effect. Your continued use of the Platform after the effective date constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically.

13. Contact and Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by manilawin, please contact our Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the manilawin Platform

When submitting a data rights request, please include your registered manilawin account email address and clearly state the right you wish to exercise. We may request additional information to verify your identity before processing the request.

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