dowinn Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") is issued by dowinn ("we," "us," "our"), the operator of the online gaming platform accessible at dowinn.cam. It describes how dowinn collects, uses, stores, shares, and protects the personal information of registered players and visitors in the Philippines ("you," "your," "data subject").

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission. By creating a dowinn account or using any part of our platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein.

This Policy applies to all personal data collected through the dowinn website, mobile web interface, customer support channels, and any other digital or physical touchpoint through which dowinn interacts with players. It should be read alongside the dowinn Terms & Conditions, which govern your use of the platform more broadly.

2. Personal Data We Collect

dowinn collects personal data through several channels: directly from you during registration and account use, automatically through your interaction with the platform, and from third-party service providers involved in payment processing and identity verification. The categories of personal data we collect are set out below.

2.1 Registration and Identity Data

When you create a dowinn account, we collect:

• Full legal name as it appears on your government-issued identification document
• Date of birth (used to verify that you meet the 21+ age requirement)
• Email address
• Mobile phone number
• Residential address in the Philippines
• Username and hashed password

2.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and Philippine anti-money laundering law, we may collect:

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's license, Unified Multi-Purpose ID)
• Proof of residential address (e.g., utility bill or bank statement dated within the last three months)
• Source of funds documentation where applicable to high-value transactions
• Selfie photographs for liveness verification matched against submitted ID documents

2.3 Financial Transaction Data

When you make deposits or withdrawal requests through dowinn, we collect:

• GCash and PayMaya account numbers or linked mobile numbers
• Bank account details (account name, account number, bank name) for BPI, BDO, Metrobank, and Unionbank transfers
• Transaction amounts, dates, and reference numbers
• Deposit and withdrawal history associated with your account

2.4 Gaming Activity Data

As part of operating the gaming platform, dowinn records:

• Game sessions played, including game title, duration, wager amounts, and outcomes
• Bonus claims, wagering requirement progress, and promotion history
• Account balance history and transaction logs

2.5 Technical and Device Data

When you access the dowinn platform, we automatically collect:

• IP address and approximate geolocation derived from IP
• Browser type and version, operating system, and device type
• Session duration, pages visited, and in-platform navigation paths
• Referring URL (if you arrived at dowinn via a link on another site)

2.6 Communications Data

When you contact dowinn customer support via live chat, email, or any other channel, we retain records of those communications including their content, timestamps, and any personal information you voluntarily provide during the interaction. These records are used to resolve disputes, improve support quality, and maintain service history.

3. How We Use Your Personal Data

dowinn uses the personal data we collect for the following purposes:

• Account Management: To create and maintain your dowinn account, verify your identity and age, and process your login and account security settings.
• Payment Processing: To process deposits and withdrawals through GCash, PayMaya, and Philippine bank transfer channels, and to maintain accurate financial records.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, Philippine anti-money laundering regulations (Republic Act No. 9160 as amended), and the reporting obligations imposed on licensed gaming operators.
• Fraud Prevention and Security: To detect and prevent fraudulent activity, unauthorized account access, money laundering, bonus abuse, and other forms of platform misuse.
• Platform Operation: To operate, maintain, and improve the dowinn gaming platform, including game delivery, bonus crediting, and jackpot administration.
• Customer Support: To respond to inquiries, resolve complaints, and provide assistance with account and payment matters.
• Responsible Gaming: To monitor gaming patterns that may indicate problem gambling behavior, administer self-exclusion and deposit limit requests, and fulfill responsible gaming obligations.
• Marketing Communications: To send promotional offers, bonus notifications, and news relevant to your dowinn account, where you have consented to receive such communications. You may opt out at any time through your account settings.
• Analytics and Improvement: To analyze aggregated, anonymized usage data to understand how the platform is used and to identify areas for improvement. This analysis does not involve individually identifiable data.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, dowinn relies on the following legal bases for processing your personal data:

• Contractual Necessity: Processing required to enter into and perform our agreement with you, including account registration, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act, and tax reporting requirements.
• Consent: Processing for optional purposes where we have obtained your explicit consent, including marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.
• Legitimate Interests: Processing necessary for the legitimate interests of dowinn, including platform security, fraud prevention, analytics, and responsible gaming monitoring, where those interests are not overridden by your privacy rights.

5. Cookies and Tracking Technologies

5.1 What We Use

dowinn uses cookies and similar tracking technologies on the platform to operate essential functions, analyze usage patterns, and deliver a personalized gaming experience. A cookie is a small text file placed on your device by a website you visit. dowinn uses the following categories of cookies:

• Essential Cookies: Required for the platform to function. These include session authentication cookies, security tokens, and preference settings. These cannot be disabled without breaking core platform functionality.
• Analytics Cookies: Used to collect anonymized data on how players interact with the dowinn platform, including page visits, session duration, and navigation paths. This information helps us improve the platform.
• Functional Cookies: Used to remember your preferences, such as language settings and previously played games, to enhance your experience on return visits.

5.2 Managing Cookies

You may configure your browser to refuse all cookies or to alert you when cookies are being set. Note that disabling essential cookies will impair the operation of the dowinn platform and may prevent you from logging into your account. Disabling analytics or functional cookies will not prevent you from using core platform features.

6. Sharing Your Personal Data

dowinn does not sell, rent, or trade your personal data. We share personal data only in the following circumstances and only to the extent strictly necessary:

6.1 Payment Service Providers

To process GCash, PayMaya, and bank transfer transactions, dowinn shares relevant payment data with the applicable payment service providers. These providers are subject to their own privacy policies and are bound by Philippine banking secrecy and data protection regulations.

6.2 Identity Verification Providers

dowinn engages accredited third-party KYC verification providers to process identity document verification and liveness checks. These providers process identity data on our behalf under data processing agreements that require compliance with the Philippine Data Privacy Act.

6.3 Regulatory and Law Enforcement Authorities

dowinn is required by Philippine law to share certain player data with PAGCOR as the licensing authority, with the Anti-Money Laundering Council (AMLC) where suspicious transaction reports are filed, and with law enforcement authorities where we receive a valid legal order. Such disclosures are made only to the extent required by law and documented in our compliance records.

6.4 Platform Technology Providers

dowinn works with technology providers who support platform infrastructure, cloud hosting, customer support software, and analytics. These providers access only the data necessary to perform their contracted services and are prohibited from using dowinn player data for their own purposes.

6.5 Game Providers

Individual game providers such as Pragmatic Play, Evolution Gaming, and PG Soft receive limited technical session data (such as session tokens and game round identifiers) required to operate their games within the dowinn environment. They do not receive your full identity, financial, or contact data.

7. Data Retention

dowinn retains personal data for the period necessary to fulfill the purposes described in this Policy, and in any event for the minimum periods required by Philippine law:

• Account and identity data: Retained for the duration of your active account plus five (5) years following account closure, in compliance with PAGCOR record-keeping requirements.
• Financial transaction records: Retained for five (5) years from the date of the transaction in compliance with the Anti-Money Laundering Act requirements.
• KYC documentation: Retained for five (5) years from account closure or from the date of the last transaction, whichever is later.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless the communication relates to a dispute that has not been fully resolved.
• Gaming activity logs: Retained for three (3) years from the date of the recorded activity, unless retention is required for longer by ongoing investigation or regulatory review.
• Analytics data: Retained in anonymized, aggregated form with no individual retention limit. Identifying information is removed before analytics data is archived for longer-term trend analysis.

When the applicable retention period expires, personal data is securely deleted or irreversibly anonymized in accordance with our data disposal procedures. You may request early deletion of your data as described in Section 9, subject to overriding legal retention obligations.

8. Data Security

dowinn implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, and disclosure. Our security program includes the following controls:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the dowinn platform
• AES-256 encryption for sensitive data stored at rest, including identity documents and payment details
• Bcrypt hashing with salt for all account passwords — dowinn staff cannot view your password in plain text
• Role-based access controls ensuring that dowinn staff access player data only to the extent required by their specific job function
• Two-factor authentication requirements for staff systems that access player data
• Regular independent penetration testing and vulnerability assessments by accredited third-party security firms
• 24/7 automated monitoring of platform infrastructure for anomalous activity and intrusion attempts
• Segregated player fund accounts to separate gaming balances from operational funds

In the event of a personal data breach that is likely to result in risk to the rights and freedoms of affected players, dowinn will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Philippine Data Privacy Act and NPC Circular 16-03.

9. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by dowinn:

To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 14. dowinn will respond to verified data subject requests within fifteen (15) calendar days of receipt of a complete request. Requests that are complex or numerous may require up to thirty (30) days, in which case we will notify you of the extended timeline.

We may need to verify your identity before processing any data subject request to ensure that personal data is not disclosed to or modified by unauthorized individuals. For account holders, identity verification may involve confirming your registered mobile number or email address, or providing a copy of your government-issued ID.

10. Children and Minors

The dowinn platform is strictly intended for adults aged 21 years or older. dowinn does not knowingly collect personal data from individuals below the age of 21. The 21-year minimum age requirement reflects Philippine gaming regulations applicable to casino-style online gambling.

If dowinn becomes aware that personal data of a person below the age of 21 has been collected — whether through underage registration or misrepresentation of age — the relevant account will be immediately suspended, all real-money balances will be held pending investigation, and the personal data collected will be handled in accordance with applicable child data protection guidelines. Parents or guardians who believe a minor has registered a dowinn account are encouraged to contact support immediately.

11. Cross-Border Data Transfers

Some of the third-party service providers dowinn works with — including cloud infrastructure providers, game providers, and KYC verification services — may process or store data on servers located outside the Philippines. Where such cross-border data transfers occur, dowinn ensures that:

• The receiving country or organization provides an adequate level of data protection consistent with Philippine Data Privacy Act standards
• Appropriate contractual safeguards are in place, including standard data processing agreements that require the recipient to maintain equivalent data protection obligations
• Transfers occur only to the extent necessary for the specific service being provided and are not broader in scope than required

Where required by the National Privacy Commission, cross-border transfer arrangements are registered with or approved by the NPC in accordance with applicable regulations.

12. Third-Party Links

The dowinn platform may contain links to third-party websites or services — for example, links to payment provider portals. Once you leave the dowinn website by following such a link, this Privacy Policy no longer applies. dowinn is not responsible for the privacy practices of third-party websites and encourages you to review the privacy policies of any external sites you visit.

dowinn does not endorse or make representations about the privacy or security practices of any third-party website, even if that website is linked from or to the dowinn platform.

13. Amendments to This Policy

dowinn may update this Privacy Policy from time to time to reflect changes in our data practices, new regulatory requirements, or developments in platform features. When material changes are made, we will update the "Last Updated" date at the top of this page and, where the changes are significant, notify registered players by email or in-platform notification before the revised Policy takes effect.

We encourage you to review this Policy periodically. Your continued use of the dowinn platform after the publication of an updated Policy constitutes your acknowledgment of the changes and, where consent is required by law, your consent to the revised processing activities.

14. Contact Us and Data Protection Officer

If you have questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by dowinn, please contact our Data Protection Officer (DPO) through the following channel:

Data Protection Officer — dowinn
Email: [email protected]

Please include "Privacy Request" or "DPO Inquiry" in the subject line of your email. Our DPO and customer support team will acknowledge receipt within two business days and provide a full response within the timeframes specified in Section 9.

If you believe that dowinn has not adequately addressed your privacy concern, you have the right to escalate your complaint directly to the National Privacy Commission of the Philippines through the official NPC channels.