Privacy Policy

This Privacy Policy ("Policy") describes how win2max ("we," "us," "our") collects, uses, stores, and protects the personal information of users ("you," "Player") who access or use the win2max platform at win2max.app. It applies to all services offered by win2max, including account registration, gameplay, financial transactions, customer support, and any communications between you and win2max.

win2max acts as the data controller for all personal information collected through the platform. We are committed to handling your data responsibly, transparently, and in full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together form the complete agreement governing your use of win2max.

win2max collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (to verify you are at least 21 years of age);
• Nationality and country of residence;
• Username and account credentials (password stored in encrypted form only);
• Government-issued ID details (e.g., Philippine passport, SSS ID, UMID, driver's license, PhilSys national ID) submitted during KYC verification.

2.2 Contact Data

• Email address;
• Mobile phone number;
• Residential address (barangay, city/municipality, province, ZIP code).

2.3 Financial Data

• Payment method details (e.g., GCash mobile number, PayMaya account, BPI/BDO/Metrobank account details);
• Transaction history including deposits, withdrawals, and wager amounts;
• Account balance information.

2.4 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session timestamps, login history, and activity logs;
• Game history, betting patterns, and session duration;
• Referral source and marketing attribution data.

2.5 Communications Data

• Records of your correspondence with our customer support team;
• Feedback, complaints, and dispute submissions;
• Responses to surveys or promotional communications (where you have opted in).

win2max collects your personal data through the following means:

3.1 Directly From You

The majority of your personal data is collected directly from you when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions. You are always informed at the point of collection what data is being requested and why.

3.2 Automatically

When you access the win2max platform, certain technical data is collected automatically through cookies, web beacons, and server logs. This includes your IP address, browser type, device identifiers, and session activity. This data is used to maintain platform security, detect fraud, and improve your user experience.

3.3 From Third Parties

win2max may receive personal data about you from third parties in limited circumstances, including:

• Identity verification and KYC service providers;
• Payment processors (e.g., GCash, PayMaya, InstaPay, PESONet) for transaction confirmation;
• Fraud detection and anti-money laundering screening services;
• Regulatory authorities including PAGCOR and the Anti-Money Laundering Council (AMLC), where required by law.

win2max processes your personal data only for specific, legitimate purposes. We do not use your data for any purpose incompatible with those stated below:

• Account Management: To create, maintain, and administer your win2max player account;
• Identity Verification: To verify your age (21+), identity, and eligibility to use the platform in compliance with PAGCOR regulations and Philippine law;
• Payment Processing: To process deposits, withdrawals, and refunds through your chosen payment method;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, and unauthorized access;
• Regulatory Compliance: To meet our obligations under the Anti-Money Laundering Act (AMLA), Data Privacy Act, PAGCOR licensing requirements, and other applicable Philippine laws;
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance;
• Responsible Gaming: To monitor gaming behavior, enforce self-exclusion requests, and provide responsible gaming interventions where necessary;
• Platform Improvement: To analyze usage patterns and improve the functionality, performance, and content of the win2max platform;
• Marketing Communications: To send you promotional offers, bonuses, and updates – but only where you have given your explicit consent to receive such communications. You may withdraw consent at any time.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, win2max processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and win2max (i.e., to operate your account and provide gaming services);
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, PAGCOR licensing conditions, and NPC requirements;
• Legitimate Interests: Processing is necessary for win2max's legitimate interests in fraud prevention, platform security, and business operations, provided these interests are not overridden by your rights;
• Consent: For marketing communications and non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

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

6.1 Service Providers

We engage trusted third-party service providers who process data on our behalf under strict data processing agreements. These include payment processors, KYC and identity verification providers, IT infrastructure and hosting providers, fraud detection services, and customer support platforms. All such providers are contractually bound to process your data only as instructed by win2max and in compliance with applicable privacy laws.

6.2 Regulatory & Legal Authorities

win2max may disclose your personal data to government agencies, regulatory bodies, or law enforcement authorities where required by Philippine law or a valid legal order. This includes mandatory reporting to the Anti-Money Laundering Council (AMLC), disclosures to PAGCOR in connection with our licensing obligations, and responses to court orders or subpoenas.

6.3 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 as part of that transaction. You will be notified of any such transfer and the privacy practices of the new entity prior to your data being transferred.

win2max retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

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

win2max implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and win2max is protected by 256-bit SSL/TLS encryption. Passwords are stored using industry-standard one-way hashing algorithms and are never stored in plain text;
• Access Controls: Access to personal data is restricted to authorized win2max personnel on a strict need-to-know basis. All staff with access to personal data undergo regular privacy and security training;
• Infrastructure Security: Our servers are hosted in secure, certified data centers with physical access controls, redundant systems, and continuous monitoring;
• Fraud Detection: Automated systems monitor account activity in real time to detect and respond to suspicious behavior, unauthorized login attempts, and potential data breaches;
• Incident Response: win2max maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights, we will notify the National Privacy Commission (NPC) and affected players within the timeframes required by Philippine law.

While win2max takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

win2max uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage, and support our security systems. A cookie is a small text file placed on your device when you visit a website.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function. These enable core features such as account login, session management, and security. They cannot be disabled without affecting platform functionality;
• Functional Cookies: Remember your preferences such as language settings and display options to provide a more personalized experience;
• Analytics Cookies: Help us understand how players use the platform so we can improve performance and content. Data collected is aggregated and anonymized where possible;
• Marketing Cookies: Used to deliver relevant promotional content. These are only placed with your explicit consent.

9.2 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the win2max platform. For marketing cookies, you may withdraw your consent at any time by adjusting your account communication preferences or contacting our support team.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by win2max:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy;
• Right of Access: You may request a copy of the personal data win2max holds about you, along with information about how it is being processed;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format;
• 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 privacy rights have been violated.

If win2max becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data, and return any deposited funds to the originating payment method. If you believe a minor has registered on win2max, please contact us immediately at [email protected].

win2max primarily stores and processes your personal data within the Philippines. In limited circumstances, data may be transferred to or processed by service providers located outside the Philippines, for example in connection with cloud infrastructure or specialized technical services.

Where such transfers occur, win2max ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law. This may include contractual clauses approved by the National Privacy Commission, adequacy decisions, or other recognized transfer mechanisms.

By using the win2max platform, you acknowledge and consent to the transfer of your personal data as described in this section, subject always to the protections outlined in this Privacy Policy.

win2max reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email or through a prominent notice on the win2max platform prior to the changes taking effect.

The date at the top of this page indicates when this Privacy Policy was last revised. Your continued use of the win2max platform after the effective date of any update constitutes your acceptance of the revised Policy. If you do not agree with the updated Policy, you must stop using the platform and may request account closure by contacting our support team.

We encourage you to review this Privacy Policy periodically to stay informed about how win2max protects your personal information.

win2max has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012 and the National Privacy Commission. If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our DPO directly.

If you are not satisfied with our response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. The NPC is the independent regulatory body responsible for administering and implementing the Data Privacy Act of 2012.