manilawin Privacy Policy

1.1 This Privacy Policy applies to all personal data collected, processed, stored, or transmitted by manilawin in connection with the operation of the manilawin online gaming platform accessible at manilawin.club and any related services, communications, or promotional activities directed at registered players and prospective users.

1.2 manilawin acts as the Personal Information Controller with respect to personal data processed in connection with player account registration, financial transactions, gameplay activity, responsible gaming tools, and customer support interactions.

1.3 Where manilawin engages third-party service providers – including payment processors, game technology providers, and fraud prevention services – to process personal data on its behalf, those third parties act as Personal Information Processors and are contractually bound to process data only in accordance with manilawin's instructions and applicable Philippine data protection law.

1.4 This Privacy Policy should be read in conjunction with the manilawin Terms & Conditions and Responsible Gaming Policy, both of which are incorporated herein by reference.

2.1 manilawin collects the following categories of personal data from players:

• Full legal name as appearing on a valid government-issued identification document;
• Date of birth (used for age verification – players must be 21 years or older);
• Registered Philippine mobile number;
• Username chosen at registration;
• Copies of government-issued ID (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's licence, UMID) submitted for KYC verification.

• GCash registered mobile number and account reference;
• Maya / PayMaya account details as applicable;
• Philippine bank account details (BPI, BDO, Metrobank, or other Philippine bank) where used for deposits or withdrawals;
• Transaction history including deposit amounts, withdrawal requests, and game wagering records.

• IP address and approximate geolocation at time of login;
• Device type, operating system, and browser information;
• Session timestamps, login history, and session duration;
• Game history, bet amounts, game outcomes, and gaming session data;
• Responsible gaming settings applied to the account.

• Records of live chat, email, and other support interactions with manilawin;
• Complaints and dispute records;
• Marketing preference settings and communication opt-in/opt-out records.

3.1 manilawin collects personal data through the following means:

Information you provide directly when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or responding to surveys and promotional communications.

Technical and usage data collected automatically when you access and use the manilawin platform, including through cookies, log files, session recording tools, and device fingerprinting technologies. See Section 9 for details on cookies and tracking.

Identity and fraud-risk information received from payment processors (GCash, Maya, Philippine banks) and identity verification service providers engaged by manilawin to facilitate KYC compliance. manilawin may also receive information from PAGCOR or other regulatory bodies as required by applicable law.

4.1 manilawin processes your personal data for the following specific purposes:

5.1 Under the Philippine Data Privacy Act of 2012, manilawin relies on the following legal bases for processing personal data:

• Contractual necessity: Processing required to perform the contract between manilawin and the player, including operating the player's account and processing financial transactions;
• Legal obligation: Processing necessary for manilawin to comply with applicable Philippine laws and PAGCOR regulations, including KYC, AML obligations, and mandatory responsible gaming requirements;
• Legitimate interests: Processing necessary for manilawin's legitimate business interests, including fraud prevention, security monitoring, and platform improvement, where these interests are not overridden by the player's rights and interests;
• Consent: For processing activities not covered by the above bases, particularly direct marketing communications, manilawin relies on the player's explicit consent, which may be withdrawn at any time without affecting the lawfulness of prior processing.

5.2 Where manilawin relies on consent, you may withdraw it at any time by adjusting your communication preferences within your account settings or by contacting manilawin support. Withdrawal of consent does not affect the validity of any processing conducted before the withdrawal.

6.1 manilawin does not sell, rent, or exchange your personal data for commercial consideration. Data is shared only in the following circumstances:

manilawin shares data with trusted third-party processors who provide services necessary to operate the platform, including payment processors (GCash, Maya, Philippine banks), KYC and identity verification providers, game technology providers, fraud detection services, and cloud infrastructure operators. All processors are bound by data processing agreements requiring them to maintain the confidentiality and security of your data.

manilawin is required by Philippine law to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and relevant law enforcement agencies upon lawful request or as mandated by applicable reporting obligations.

manilawin may share data with affiliated entities within the manilawin group for purposes consistent with this Privacy Policy, subject to the same data protection standards.

In the event of a merger, acquisition, or sale of all or substantially all of manilawin's assets, personal data held by manilawin may be transferred to the acquiring entity. Players will be notified of any such transfer in advance where practicable.

7.1 Some of manilawin's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to a country outside the Philippines, manilawin ensures that appropriate safeguards are in place consistent with the requirements of the Philippine Data Privacy Act and NPC regulations.

7.2 Such safeguards may include contractual clauses approved by the NPC, adequacy determinations, or other legally recognised transfer mechanisms. Players who wish to obtain further information about the safeguards applied to any specific international transfer may contact manilawin at the details provided in Section 15.

8.1 manilawin retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law, whichever is longer.

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with manilawin's internal data disposal procedures.

9.1 manilawin uses cookies and similar tracking technologies to operate the platform, enhance the user experience, and gather analytical information about platform usage.

These cookies are strictly necessary for the platform to function. They enable login session management, security features, and basic platform navigation. Essential cookies cannot be disabled without preventing you from using the platform.

These cookies collect anonymised or pseudonymised data about how players use the manilawin platform, including pages visited, time spent, and interaction patterns. This data is used to improve platform performance and user experience.

These cookies assist in identifying unusual access patterns, detecting fraudulent activity, and verifying that login requests originate from legitimate users rather than automated systems.

9.2 You may adjust cookie preferences through your browser settings. Please note that disabling certain cookies may limit functionality of the manilawin platform. Detailed cookie management instructions are available in your specific browser's help documentation.

10.1 manilawin implements technical and organisational security measures appropriate to the sensitivity of the personal data it holds. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and manilawin's servers;
• Encryption at rest for sensitive personal data and financial records stored in manilawin's systems;
• Role-based access controls restricting employee access to personal data to those with a documented operational need;
• Multi-factor authentication requirements for internal system access;
• Regular security assessments and penetration testing of the platform infrastructure;
• Intrusion detection systems monitoring for unauthorised access attempts;
• Incident response procedures for detecting, containing, and notifying affected individuals and regulators in the event of a personal data breach.

10.2 In the event of a personal data breach that is likely to result in risk to your rights and interests, manilawin will notify affected players and the National Privacy Commission within the timeframes required by the Data Privacy Act and its implementing rules.

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

• Right to be informed: the right to know what personal data manilawin holds about you, the purposes of processing, and your other rights under this Policy;
• Right to access: the right to obtain a copy of your personal data held by manilawin and information about how it is processed;
• Right to rectification: the right to have inaccurate or incomplete personal data corrected or completed;
• Right to erasure / blocking: the right to request deletion or blocking of personal data where it is no longer necessary for the purposes collected, or where processing was unlawful, subject to manilawin's legal retention obligations;
• Right to object: the right to object to processing based on legitimate interests or for direct marketing purposes;
• Right to data portability: the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible;
• Right to lodge a complaint: the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe manilawin has violated your data privacy rights.

11.2 To exercise any of the above rights, please submit a written request to manilawin's Data Protection Officer at [email protected] with the subject line "Data Privacy Request". manilawin will respond within thirty (30) calendar days of receiving a complete and verifiable request.

11.3 manilawin may require identity verification before processing any data subject rights request to ensure that personal data is not disclosed to or modified by an unauthorised person.

12.1 manilawin applies mandatory age verification during account registration consistent with PAGCOR requirements for online gaming in the Philippines. Any account where the registered player is found to be under 21 years of age will be immediately suspended and all associated personal data subject to deletion, except where retention is required by law.

12.2 If a parent or guardian believes that a person under 21 years of age has registered on the manilawin platform, they should contact manilawin immediately at [email protected]. manilawin will investigate and take appropriate action, including account closure and deletion of personal data, within five (5) business days.

13.1 The manilawin platform may contain links to third-party websites or services, including payment gateway interfaces. manilawin is not responsible for the privacy practices of third-party sites and encourages players to review the privacy policies of any third-party services they access from the manilawin platform.

13.2 This Privacy Policy applies solely to personal data processed by manilawin in connection with the manilawin platform. Once you leave the manilawin platform and interact with a third-party service, your data is governed by that third party's privacy policy.

14.1 manilawin may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Material changes will be communicated to registered players via their registered Philippine mobile number or email address no less than seven (7) calendar days before the change takes effect.

14.2 The date of the most recent revision is indicated at the top of this Policy. Continued use of the manilawin platform after the effective date of any amendment constitutes acceptance of the revised Privacy Policy.

14.3 Where a proposed amendment materially reduces your privacy rights, manilawin will seek fresh consent before applying the change to your data where consent is the applicable legal basis for the affected processing activity.

15.1 manilawin has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Philippine Data Privacy Act.

15.2 For any privacy-related enquiry, data subject rights request, or concern about manilawin's handling of your personal data, please contact:

15.3 If you are not satisfied with manilawin's response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which oversees compliance with the Data Privacy Act of 2012.