dowinn Privacy Policy

1. Introduction

dowinn ("dowinn," "we," "us," "our") is committed to protecting the privacy and personal data of every player who uses our platform. We understand that trust is the foundation of any relationship between a player and their online casino, and that trust begins with being transparent about how we handle your information.

This Privacy Policy describes the types of personal data we collect from you when you use the dowinn platform, the purposes for which we process that data, the parties with whom we may share it, and the rights you have in relation to your personal data under Philippine law – specifically the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

dowinn operates under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR). Certain data processing activities are required by PAGCOR's licensing conditions and applicable Philippine law, including anti-money laundering (AML) obligations under Republic Act No. 9160, as amended.

2. Personal Data We Collect

dowinn collects the following categories of personal data from players and platform users:

2.1 Identity and Contact Data

• Full legal name as it appears on a government-issued ID
• Date of birth (for age verification – players must be 21 years or older)
• Nationality and country of residence
• Email address and mobile phone number
• Residential address (barangay, city/municipality, province)

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., PhilSys ID, passport, driver's license, SSS/GSIS ID, Voter's ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Proof of payment method ownership (e.g., GCash account screenshot, bank account details)
• Selfie or facial image for identity verification purposes

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash mobile number, bank account number – stored in masked form)
• Account balance history and bonus transaction records
• Source of funds declarations where required by AML regulations

2.4 Gaming Activity Data

• Game session history, including games played, stakes, and outcomes
• Betting patterns and wagering history
• Bonus and promotion usage records
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

2.5 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Platform access logs and session timestamps
• Cookies and similar tracking technology data (see Section 8)

2.6 Communications Data

• Records of communications with dowinn's customer support team
• Feedback, survey responses, and complaint records
• Marketing preference settings and communication opt-in/opt-out records

3. How We Collect Your Data

dowinn collects personal data through the following means:

• Direct registration: Information you provide when creating your dowinn account.
• KYC verification: Documents and images you submit during identity verification.
• Platform use: Data generated automatically as you navigate and play on dowinn.
• Payment processing: Transaction data received from payment providers such as GCash, PayMaya, BPI, BDO, and Metrobank.
• Customer support interactions: Information you share when contacting our support team via email or live chat.
• Cookies and tracking technologies: Data collected automatically via cookies when you visit the dowinn platform (see Section 8).

4. How We Use Your Personal Data

dowinn uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Identity, contact, and KYC data
Age verification (21+ requirement)	Date of birth, KYC documents
Processing deposits and withdrawals	Financial and transaction data
Anti-money laundering (AML) compliance	Identity, financial, and transaction data
Fraud detection and prevention	Technical, financial, and gaming activity data
Responsible gaming monitoring	Gaming activity and responsible gaming settings
Customer support	Identity, contact, and communications data
Marketing communications (with consent)	Contact data and marketing preferences
Platform improvement and analytics	Technical and usage data (anonymized where possible)
Legal and regulatory compliance	All categories as required by applicable law

5. Legal Basis for Processing

dowinn processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management and payment processing.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AML obligations under RA 9160, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection 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 and Disclosure

dowinn does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• PAGCOR and Philippine regulatory authorities: As required by our operating license and applicable law, including mandatory reporting of suspicious transactions.
• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, Visa, and Mastercard, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Third-party services engaged to assist with document verification and fraud screening, bound by strict data processing agreements.
• Game content providers: Licensed game studios whose content is available on dowinn may receive anonymized session data for game performance purposes.
• IT and cloud infrastructure providers: Service providers who host and maintain the dowinn platform, operating under data processing agreements that require them to protect your data.
• Law enforcement and courts: Where required by a valid court order, subpoena, or other legal process under Philippine law.

All third parties with whom dowinn shares personal data are required to handle that data in accordance with applicable Philippine data protection law and dowinn's data processing standards.

7. Data Retention

dowinn retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and KYC records are retained for a minimum of five (5) years following account closure, as required by PAGCOR's licensing conditions and AML regulations.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Marketing preference records are retained until you withdraw consent or close your account, whichever is earlier.
• Technical and usage logs are retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymized in accordance with dowinn's data disposal procedures.

8. Cookies & Tracking Technologies

dowinn uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the platform. The types of cookies we use are:

• Strictly necessary cookies: Essential for the platform to function, including session management and security. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, display settings) to improve your experience on dowinn.
• Analytics cookies: Collect anonymized data about how players use the platform, helping us identify areas for improvement. Used only with your consent.
• Marketing cookies: Used to deliver relevant promotional content within the dowinn platform. Used only 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 dowinn platform.

9. Your Data Subject Rights

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

• Right to be informed: The right to know what personal data we collect and how we use it – which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data dowinn holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to object: The right to object to certain types of processing, including direct marketing.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at: [email protected]. We will respond to all verified requests within thirty (30) days.

10. Data Security

dowinn implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the dowinn platform.
• Encryption of sensitive data at rest, including financial and KYC records.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing of the dowinn platform.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, dowinn will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

11. Children's Privacy and Age Restriction

The dowinn platform is strictly for players aged 21 years and above, in accordance with Philippine law and PAGCOR's licensing conditions. dowinn does 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 immediately suspend the associated account and delete the data in question.

If you believe that a minor has registered on the dowinn platform, please contact us immediately at [email protected].

12. Third-Party Links

The dowinn platform may contain links to third-party websites or services (for example, payment provider portals). This Privacy Policy applies only to the dowinn platform. dowinn is not responsible for the privacy practices of any third-party websites. We encourage you to review the privacy policies of any third-party services you access through or in connection with dowinn.

13. Changes to This Privacy Policy

dowinn reserves the right to update or amend this Privacy Policy at any time. Where changes are material, we will provide reasonable notice via email or a prominent notice on the platform prior to the changes taking effect. The "Last updated" date at the top of this page will always reflect the most recent revision. Your continued use of the dowinn platform following any update constitutes your acceptance of the revised Privacy Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or dowinn's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Response time: We aim to respond to all privacy-related inquiries within 30 days.
• Regulator: You also have the right to lodge a complaint with the National Privacy Commission of the Philippines.

This Privacy Policy was last reviewed and updated in May 2026. dowinn is committed to keeping this document current and accurate.