win2max Privacy Policy

1 Introduction

win2max ("we," "us," or "our") operates the online gaming platform accessible at win2max.club (the "Platform"). As a data controller, win2max is responsible for the personal data of individuals ("you," "your," or "Data Subject") who register for and use our services.

This Privacy Policy describes the types of personal information we collect, the purposes for which we process it, the parties with whom we may share it, and the rights you have in relation to your personal data. It applies to all users of the win2max Platform, including registered members and visitors to our website.

By accessing or using the win2max Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, you should discontinue use of the Platform. This Privacy Policy should be read alongside our Terms & Conditions, which govern your overall use of the Platform.

2 Personal Data We Collect

win2max collects personal data that is necessary for the provision of our services, compliance with legal obligations, and the improvement of the Platform. The categories of personal data we collect include:

2.1 Identity & Contact Information

• Full legal name;
• Date of birth (for age verification purposes);
• Residential address, city, and province (e.g., Metro Manila, Cebu, Davao, Quezon City, Makati);
• Email address;
• Mobile number.

2.2 Account & Financial Information

• Username and encrypted password;
• Deposit and withdrawal transaction records;
• Payment method details (e.g., GCash account reference, bank account details for BPI, BDO, Metrobank, UnionBank, or debit card information — stored only to the extent required for transaction processing and verification);
• Account balance history and gaming activity records.

2.3 Identity Verification (KYC) Documents

• Government-issued identification (e.g., Philippine passport, driver's licence, SSS/GSIS ID, PhilSys National ID);
• Proof of address documents;
• Selfie or facial image submitted for identity verification purposes.

2.4 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Pages visited, session duration, and navigation patterns on the Platform;
• Game play history, wager amounts, and session logs.

2.5 Communications Data

• Records of correspondence with our customer support team;
• Feedback, survey responses, and promotional opt-in preferences.

3 How We Collect Your Data

win2max collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and usage data collected automatically through cookies, log files, and similar tracking technologies when you access the Platform;
• Third-party sources: Identity verification and fraud prevention data received from licensed KYC service providers and payment processors, where permitted by applicable law.

4 How We Use Your Personal Data

win2max processes your personal data only for the purposes described below. We do not use your data for any purpose that is incompatible with the original purpose for which it was collected.

• Account management: To create, maintain, and administer your win2max account, including authentication and account security;
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the features of the Platform;
• Identity verification & KYC compliance: To verify your identity, confirm your age (21+), and comply with anti-money laundering obligations under Philippine law;
• Fraud prevention & security: To detect, investigate, and prevent fraudulent transactions, cheating, and other prohibited conduct;
• Legal compliance: To comply with applicable laws, regulations, court orders, and the requirements of PAGCOR and other competent authorities;
• Customer support: To respond to your enquiries, resolve disputes, and improve our support services;
• Responsible gaming: To monitor gaming patterns and apply responsible gaming tools where appropriate, in line with our Responsible Gaming commitments;
• Marketing & promotions: To send you promotional communications about win2max offers and updates, where you have provided consent. You may withdraw consent at any time by contacting our support team;
• Platform improvement: To analyse usage patterns and improve the functionality, performance, and user experience of the Platform.

5 Legal Basis for Processing

win2max processes your personal data on the following legal bases under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you have agreed to, including account management and service delivery;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations and PAGCOR requirements;
• Legitimate interests: Processing necessary for fraud prevention, platform security, and the improvement of our services, where such interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

win2max does not sell, rent, or trade your personal data to third parties. We may share your personal data only in the following limited circumstances:

• Service providers: Trusted third-party vendors who assist us in operating the Platform, including KYC/identity verification providers, payment processors (e.g., GCash, Maya, Philippine banks), IT infrastructure providers, and customer support platforms. These parties are contractually bound to process your data only on our instructions and in accordance with applicable law;
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation;
• Law enforcement: Philippine law enforcement agencies, where we are legally required or permitted to disclose information in connection with the investigation or prosecution of criminal activity;
• Business transfers: In the event of a merger, acquisition, or sale of all or part of win2max's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations;
• With your consent: To any other third party where you have given explicit prior consent to such disclosure.

7 Cookies & Tracking Technologies

win2max uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how the Platform is used.

Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled as they are required for account authentication, session management, and security;
• Functional cookies: Remember your preferences and settings to provide a more personalised experience;
• Analytics cookies: Help us understand how users interact with the Platform so we can improve its performance and content. Data collected is aggregated and anonymised where possible;
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no consent is required as they are essential to service delivery.

8 Data Retention

win2max retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account and transaction records: Retained for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements under Philippine law;
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship;
• Customer support communications: Retained for two (2) years from the date of the last interaction;
• Technical and usage logs: Retained for up to twelve (12) months, unless required for longer periods for security or legal purposes;
• Marketing consent records: Retained until consent is withdrawn, plus a reasonable period thereafter for compliance documentation.

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

9 Data Security

win2max implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and financial information;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and vulnerability testing of the Platform;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

10 Your Data Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by win2max. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

win2max will respond to all verified data subject requests within thirty (30) days of receipt. We may request proof of identity before processing your request to protect against unauthorised access.

11 Children's Privacy

The win2max Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. 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, we will take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered on the win2max Platform, please contact us immediately using the details in Section 14.

12 Third-Party Links

The win2max Platform may contain links to third-party websites or services for informational purposes. win2max is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to data collected by win2max through the Platform.

13 Changes to This Privacy Policy

win2max reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered users via email or a prominent notice on the Platform. The "Last Updated" date at the top of this page will be revised accordingly.

Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acknowledgement of the changes. We encourage you to review this page periodically to stay informed about how we protect your personal data.

14 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by win2max, please contact our Data Protection Officer:

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.