manilawin Casino – Privacy Policy

This Privacy Policy ("Policy") describes how manilawin Casino ("manilawin", "we", "us", "our") collects, uses, stores, shares, and otherwise processes personal data relating to individuals who access or use the manilawin online casino platform available at manilawin.vip and any associated mobile-optimised interfaces ("the Platform").

This Policy applies to all registered players, prospective registrants, and any other individuals whose personal data manilawin processes in connection with the Platform, including players from Manila, Cebu, Davao, Quezon City, Makati, and all other areas of the Philippines.

This Policy is to be read alongside and in conjunction with manilawin's Terms and Conditions and Responsible Gaming Policy, both of which are available on this Platform. By registering a manilawin account or using the Platform in any way, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA") and its Implementing Rules and Regulations, manilawin Casino is the Personal Information Controller (PIC) responsible for the personal data collected and processed through the Platform.

manilawin operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). All data processing activities undertaken by manilawin are conducted in compliance with the DPA, PAGCOR's data governance requirements, and the directives of the National Privacy Commission (NPC) of the Philippines.

manilawin collects the following categories of personal data in the course of operating the Platform and fulfilling its regulatory obligations:

3.1 Identity and Registration Data

• Full legal name as it appears on a valid Philippine government-issued identification document.
• Date of birth (collected to verify the mandatory 21-year age requirement).
• Username chosen at registration.
• Password (stored in hashed, non-reversible form — manilawin staff cannot read your password).

3.2 Contact Data

• Philippine mobile number (Globe, Smart, or DITO).
• Email address.
• Residential address (may be required as part of enhanced KYC for high-value accounts).

3.3 Identity Verification (KYC) Data

• Photographs or scanned copies of government-issued Philippine identification documents (e.g., Passport, LTO Driver's License, UMID, PhilSys National ID, SSS Card, GSIS Card, PRC ID, Voter's ID).
• Selfie photograph holding the submitted ID document.
• Proof of address documentation (where required).
• Source of funds documentation (for enhanced due diligence on high-value accounts, per PAGCOR AML requirements).

3.4 Financial and Transaction Data

• Deposit and withdrawal amounts, dates, and payment method references (GCash account number, BPI/BDO/Metrobank account details, PayMaya reference numbers).
• Account balance and transaction history.
• Bonus and promotional offer eligibility and usage records.

3.5 Gaming Activity Data

• Game session logs including games played, bet amounts, win/loss outcomes, session duration, and timestamps.
• Sports betting market selections and outcomes.
• Responsible gaming tool settings, including deposit limits, session limits, and self-exclusion status.

3.6 Technical and Device Data

• IP address and approximate geolocation at time of login and transaction.
• Device type, operating system, browser type and version.
• Session identifiers and authentication tokens.
• Platform access logs including login timestamps and session durations.

3.7 Communication Data

• Records of communications between you and the manilawin support team via live chat, email, or any other channel.
• Records of marketing communication preferences and opt-in or opt-out actions.

manilawin collects personal data through the following means:

• Directly from you — when you complete the manilawin account registration form, submit KYC documents, contact our support team, or make changes to your account settings.
• Automatically through Platform use — when you log in, play games, make deposits or withdrawals, or otherwise interact with the manilawin Platform, certain technical and activity data is automatically collected through our systems and, where applicable, cookies and similar tracking technologies.
• From third-party payment processors — when you complete a deposit or withdrawal, your payment provider (GCash, PayMaya, BPI, BDO, Metrobank, 7-Eleven) shares transaction confirmation data with manilawin sufficient to credit or debit your account.
• From identity verification service providers — manilawin may use third-party KYC and identity verification service providers to cross-reference submitted documents and assist in fraud detection.
• From PAGCOR and regulatory authorities — manilawin may receive information from PAGCOR or other Philippine regulatory bodies as part of our compliance and reporting obligations.

manilawin processes personal data on one or more of the following lawful bases as established under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations:

manilawin uses the personal data it collects for the following purposes:

• To create, maintain, and administer your manilawin account.
• To verify your identity and confirm compliance with the 21-year minimum age requirement mandated by PAGCOR.
• To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported Philippine payment channels.
• To maintain accurate game session records and account transaction histories.
• To detect, investigate, and prevent fraud, account abuse, money laundering, and other prohibited activities.
• To provide customer support and resolve player complaints or disputes.
• To administer bonuses, promotional offers, and loyalty rewards.
• To provide and administer responsible gaming tools, including deposit limits, session reminders, and self-exclusion, as required under PAGCOR's responsible gaming mandate.
• To monitor compliance with our Terms and Conditions and applicable Philippine laws.
• To fulfil reporting obligations to PAGCOR, the National Privacy Commission, and other Philippine regulatory or law enforcement bodies where required by law.
• To send marketing communications about manilawin promotions, new games, and platform updates, where you have provided consent to receive such communications.
• To improve the manilawin platform through analysis of aggregated, anonymised usage data.

manilawin will not use your personal data for any purpose incompatible with those listed above without first obtaining your explicit consent or where required to do so by applicable Philippine law.

manilawin does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your personal data only in the following circumstances and only to the extent strictly necessary:

7.1 Regulatory and Law Enforcement Authorities

manilawin is required to share certain player data with PAGCOR as part of our ongoing compliance and regulatory reporting obligations. We may also disclose personal data to the National Privacy Commission, Philippine law enforcement agencies, or courts of competent jurisdiction where required by a lawful order or directive.

7.2 Payment Service Providers

manilawin shares the transaction data necessary to process deposits and withdrawals with our payment service providers, including GCash, PayMaya, BPI, BDO, Metrobank, and 7-Eleven. These providers are contractually bound to use your data only for the purpose of processing the relevant transaction.

7.3 Identity Verification and KYC Providers

manilawin may share identity documents and associated data with third-party KYC verification providers engaged to assist with our compliance obligations. All such providers are required to process your data solely for KYC verification purposes and are contractually bound to appropriate data protection standards.

7.4 Technology and Infrastructure Providers

manilawin engages technology service providers for hosting, security, fraud detection, and platform operations. These providers process personal data as Personal Information Processors (PIPs) on behalf of manilawin and are bound by data processing agreements requiring compliance with the DPA and manilawin's security standards.

7.5 Game Content Providers

Certain game session data (such as player session tokens and bet amounts) may be transmitted to the third-party game content providers — such as JILI Games and other licensed game studios — that supply the game software powering the manilawin lobby. This data is used solely for the purpose of operating and recording the game session.

manilawin retains personal data only for as long as is necessary to fulfil the purposes for which it was collected or as required by applicable Philippine law and PAGCOR regulations.

Upon expiry of the applicable retention period, manilawin will securely destroy, anonymise, or de-identify the relevant personal data in accordance with NPC-approved data disposal standards.

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

• SSL/TLS Encryption: All data transmitted between your device and the manilawin Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols. This protects your login credentials, payment data, and personal information in transit.
• Password Hashing: Account passwords are stored in one-way hashed form using modern cryptographic hashing algorithms. manilawin staff cannot retrieve or read your password.
• Two-Factor Authentication (OTP): manilawin offers OTP-based two-factor authentication via your registered Philippine mobile number, providing an additional layer of access protection.
• Access Controls: Access to personal data within manilawin's systems is strictly limited to personnel who require it to perform their designated functions. All staff with data access are subject to confidentiality obligations.
• Intrusion Detection and Monitoring: manilawin's systems are subject to continuous monitoring and intrusion detection to identify and respond to suspicious access patterns.
• Segregated Database Architecture: Player data is stored in access-controlled database environments segregated from other manilawin operational systems.

Despite these measures, no data security system is entirely infallible. In the event of a personal data breach that poses a risk to your rights and freedoms, manilawin will notify the National Privacy Commission and affected data subjects within the timeframes prescribed by the DPA and NPC Circular No. 16-03.

manilawin uses cookies and similar browser-based tracking technologies to operate the Platform, maintain your session, and improve Platform performance. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for Platform operation. They maintain your login session, remember your authenticated state, and ensure security features such as CSRF protection function correctly. These cookies cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymised information about how players use the manilawin Platform — such as pages visited, game categories accessed, and session duration — to help us improve the Platform. No personally identifiable information is collected by these cookies.
• Functional Cookies: These cookies remember your Platform preferences, such as your selected display language and responsible gaming limit settings, to provide a more personalised experience.

You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of specific Platform features. manilawin does not use third-party advertising or behavioural tracking cookies.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to the personal data manilawin holds about you:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, stored, and shared. This Privacy Policy fulfils manilawin's obligation to inform you.
• Right to Access: You may request a copy of the personal data manilawin holds about your account, including your KYC data, transaction history, and game session records. Requests will be processed within a reasonable timeframe.
• Right to Correction: If any personal data manilawin holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure / Right to be Forgotten: You may request deletion of your personal data where (a) it is no longer necessary for the purposes for which it was collected, (b) you withdraw consent and there is no other lawful basis for processing, or (c) the data has been unlawfully processed. This right is subject to manilawin's legal data retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interest, subject to applicable DPA provisions.
• Right to Data Portability: You may request a copy of your personal data in a commonly used, machine-readable format for transfer to another Personal Information Controller.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 16 of this Policy. manilawin will respond to all data rights requests within thirty (30) days of receipt.

manilawin sends promotional emails, SMS messages, and in-platform notifications about bonuses, new game launches, and promotional offers only to players who have actively opted in to receive such communications.

You may withdraw your consent to receive marketing communications at any time by: (a) updating your notification preferences in your manilawin account settings; (b) clicking the unsubscribe link included in any marketing email; or (c) contacting the manilawin support team at [email protected].

Withdrawal of marketing consent does not affect the lawfulness of communications sent prior to withdrawal. Note that operational communications — such as account security alerts, deposit confirmations, withdrawal notifications, and KYC status updates — are not marketing communications and will continue to be sent regardless of your marketing preference settings.

The manilawin Platform is strictly intended for adults aged twenty-one (21) years and above, in compliance with PAGCOR's age requirement for online gambling in the Philippines. manilawin does not knowingly collect personal data from persons under the age of 21.

Age verification is enforced through mandatory KYC identity verification using a government-issued Philippine ID that displays the account holder's date of birth. Any account found to belong to a person under the age of 21 will be immediately and permanently closed, with any associated personal data securely deleted or retained only as required by applicable law for compliance and audit purposes.

If you believe that a minor has accessed or registered on the manilawin Platform, please notify us immediately at [email protected].

In the course of operating the manilawin Platform, it may be necessary to transfer your personal data to service providers or technology partners whose systems or personnel are located outside the Philippines — for example, cloud hosting infrastructure, internationally-operating game content providers, or security monitoring services.

Any cross-border transfer of personal data by manilawin is conducted in compliance with Section 21 of the Philippine Data Privacy Act and the National Privacy Commission's guidelines on cross-border data transfers. manilawin ensures that an adequate level of data protection is maintained through contractual clauses, data processing agreements, or other approved transfer mechanisms consistent with NPC standards.

manilawin will not transfer your sensitive personal information — including KYC identity documents — outside the Philippines except where strictly required to fulfil our KYC obligations and only to processors bound by equivalent data protection standards.

manilawin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, amendments to applicable Philippine law or PAGCOR regulations, or operational changes to the Platform.

When material changes are made to this Policy, manilawin will notify you through one or more of the following channels: an in-platform notification upon your next login, an email to your registered address, or a prominent notice on the manilawin homepage. The "Last Updated" date at the top of this Policy will be revised to reflect the date of any amendment.

Your continued use of the manilawin Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you must discontinue use of the Platform and may request account closure by contacting the manilawin support team.

For any questions, concerns, or requests relating to this Privacy Policy or your personal data rights, including the exercise of your rights under the Philippine Data Privacy Act of 2012, please contact the manilawin Data Protection Officer (DPO) through the following channels:

• Email (DPO): [email protected] — please use the subject line "Data Privacy Request" to ensure prompt routing.
• Live Chat: Available on the manilawin Platform, 8:00 AM to 12:00 MN Philippine Time (PHT), seven days a week.

manilawin commits to acknowledging all data privacy requests within five (5) business days and to resolving them within thirty (30) calendar days of receipt, or within such other timeframe as prescribed by the NPC.

If you are not satisfied with manilawin's response to your data privacy complaint or request, you have the right to escalate your concern to the National Privacy Commission (NPC) of the Philippines, which serves as the independent regulatory authority overseeing compliance with the Data Privacy Act.