winforlife Privacy Policy

1. Data Controller

winforlife ("we," "us," or "our") is the data controller responsible for the personal information collected through the winforlife platform at winforlife.one. As data controller, winforlife determines the purposes and means of processing personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR) as enforced by the National Privacy Commission (NPC) of the Philippines.

By registering an account or otherwise using the winforlife platform, you acknowledge that your personal data will be processed as described in this Privacy Policy. If you do not agree to the terms of this Policy, you should discontinue use of the platform.

2. Information We Collect

winforlife collects personal data that is necessary for the operation of a licensed online gaming platform. The categories of personal data we may collect include:

winforlife does not collect sensitive personal information beyond what is strictly required for identity verification and AML compliance. We do not collect religious beliefs, political affiliations, or health information unless voluntarily disclosed in the context of responsible gaming self-exclusion.

3. How We Collect Your Data

winforlife collects personal data through the following channels:

• Direct interactions: Information you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting support, or participating in promotions;
• Automated technologies: Technical and usage data collected automatically when you access the platform, via server logs, session analytics, and first-party cookies;
• Third-party service providers: Identity verification and KYC data from accredited verification partners; payment confirmation data from GCash, PayMaya, and banking partners; game and transaction data from licensed game providers;
• Regulatory sources: Information shared by PAGCOR or law enforcement agencies pursuant to lawful requests or our compliance obligations.

4. Purposes of Processing

winforlife processes your personal data for the following purposes:

• Creating and maintaining your player account and verifying your identity;
• Processing deposits, withdrawals, and all financial transactions;
• Complying with Anti-Money Laundering (AML) and Know Your Customer (KYC) obligations under Philippine law;
• Providing customer support and resolving disputes;
• Delivering personalised promotions, bonuses, and communications where you have consented;
• Monitoring platform activity to detect and prevent fraud, cheating, and unauthorised access;
• Implementing responsible gaming measures, including deposit limits and self-exclusion;
• Improving the platform through aggregate analytics and performance monitoring;
• Fulfilling regulatory reporting obligations to PAGCOR and other competent authorities;
• Enforcing the winforlife Terms & Conditions and pursuing legal claims where necessary.

5. Legal Basis for Processing

winforlife processes personal data on the following legal bases as provided under the Data Privacy Act of 2012:

• Consent: For marketing communications and optional platform features — you may withdraw consent at any time via account settings or by contacting support;
• Contractual necessity: Processing required to perform the Player Agreement and operate your account (e.g., payment processing, game access, KYC);
• Legal obligation: Processing required to comply with AML regulations, PAGCOR directives, NPC requirements, and other applicable Philippine laws;
• Legitimate interests: Processing for fraud prevention, platform security, and business analytics — always balanced against your rights and interests.

6. Sharing Your Personal Data

winforlife does not sell your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary:

• Payment processors: GCash (GXI), PayMaya (Voyager), BPI, BDO, and Metrobank — solely for transaction processing;
• KYC / identity verification partners: Accredited third-party verification services that assist in confirming player identity;
• Game providers: Licensed studios such as Pragmatic Play, Evolution Gaming, JILI, and PG Soft receive anonymised or pseudonymised session data necessary for game delivery and dispute resolution;
• IT infrastructure providers: Cloud hosting, CDN, and cybersecurity vendors operating under data processing agreements with equivalent data protection standards;
• Regulatory and law enforcement bodies: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent authorities, where required by law or court order;
• Professional advisers: Legal, audit, and compliance firms bound by professional confidentiality obligations.

Any third-party data processor engaged by winforlife is bound by a Data Processing Agreement requiring them to implement appropriate technical and organisational security measures and to process data only on documented instructions from winforlife.

7. Data Retention

winforlife retains personal data only for as long as necessary to fulfil the purposes described in this Policy, and in any event for no shorter than the minimum periods required by applicable law:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, in line with AML retention requirements under the AMLA and PAGCOR directives;
• Financial transaction records: Minimum five (5) years from the date of the transaction;
• Customer support communications: Up to three (3) years from the date of the interaction;
• Marketing preferences and consent records: Until withdrawal of consent plus one (1) year for audit purposes;
• Technical / server log data: Up to twelve (12) months for security and fraud monitoring purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised such that it can no longer be attributed to any individual.

8. Data Security

winforlife implements technical and organisational measures proportionate to the sensitivity of the personal data we process and the risks involved. These measures include:

• SSL/TLS encryption for all data in transit between your device and the winforlife platform;
• At-rest encryption for sensitive data stored on winforlife servers;
• Industry-standard password hashing — winforlife staff cannot view your password in plain text;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of the platform infrastructure;
• Incident response procedures aligned with the NPC's mandatory breach notification requirements.

Notwithstanding these measures, no internet transmission or electronic storage system is completely secure. winforlife cannot guarantee absolute security, and players are encouraged to protect their login credentials and report any suspected unauthorised account activity immediately via the live chat support channel.

9. Your Data Privacy Rights

Under the Data Privacy Act of 2012, players have the following rights in respect of their personal data held by winforlife:

• Right to be Informed: The right to know that your data is being collected and how it is used — as fulfilled by this Privacy Policy;
• Right to Access: The right to request a copy of the personal data winforlife holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data, subject to our legal retention obligations;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Object: The right to object to processing based on legitimate interests, including direct marketing;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, contact the winforlife support team via live chat or email at [email protected]. winforlife will respond to all legitimate requests within thirty (30) calendar days.

10. Cookies & Tracking Technologies

winforlife uses first-party cookies and similar technologies to operate the platform and improve the player experience. The categories of cookies we use are:

• Strictly necessary cookies: Required for platform functionality such as session management, authentication, and security — these cannot be disabled;
• Functional cookies: Remember your preferences (e.g., language, game lobby layout) to personalise your experience;
• Analytics cookies: Collect aggregated, anonymised data about how players use the platform, enabling us to identify areas for improvement.

winforlife does not use third-party advertising cookies or share cookie data with ad networks. You may manage cookie preferences through your browser settings, though disabling strictly necessary cookies may impair platform functionality.

11. Minors

The winforlife platform is strictly prohibited to persons under twenty-one (21) years of age in accordance with PAGCOR regulations. winforlife does not knowingly collect personal data from individuals under 21. If winforlife discovers or is notified that a registered player is under the age of 21, the account will be immediately suspended, any funds returned to the source payment method, and all personal data associated with the underage account deleted promptly in accordance with this Policy and applicable law.

If you believe a minor has registered on the winforlife platform, please notify us immediately via the live chat support channel.

12. Changes to This Privacy Policy

winforlife reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance from the NPC or PAGCOR. When material changes are made, winforlife will notify registered players via email or in-platform notification and will update the "Last updated" date at the top of this document. Your continued use of the platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Policy periodically to stay informed about how winforlife handles your personal data.

13. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by winforlife, please contact us through the following channels:

• Live Chat: Available 24/7 via the winforlife platform — the fastest way to reach our support team;
• Email: [email protected] (plain text — not a clickable link);
• Data Protection Officer: winforlife has designated a Data Protection Officer (DPO) in accordance with the Data Privacy Act of 2012. You may direct formal data privacy requests to the DPO via the email address above, marking your message "Attention: DPO / Data Privacy Request."

If you are not satisfied with our response, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines. Further information about filing an NPC complaint is available on the NPC's official website.