pbwin Privacy Policy

pbwin ("we," "us," "our") operates the online gaming and sports betting platform accessible at pbwin.vip (the "Platform"). This Privacy Policy applies to all personal data collected from individuals who visit, register with, or use the Platform ("you," "your," "Player").

This Policy covers:

• Information you provide directly during registration, KYC verification, customer support interactions, and any other communications with pbwin;
• Information collected automatically through your use of the Platform, including device data, session logs, and behavioral data;
• Information received from third-party partners, payment providers, and service providers in connection with your use of the Platform.

By registering with pbwin, logging in to your Account, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

This Policy is to be read alongside pbwin's Terms & Conditions, available at pbwin.vip/terms-conditions, which govern your overall use of the Platform. In the event of a conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy prevails.

For the purposes of the Philippine Data Privacy Act of 2012, pbwin is the Personal Information Controller responsible for the personal data collected and processed through the Platform.

pbwin's operations are based in Metro Manila, Philippines. As Personal Information Controller, pbwin determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Data Privacy Act and its Implementing Rules and Regulations.

Where pbwin engages third-party service providers (such as payment processors, KYC verification providers, and cloud hosting services) to process personal data on pbwin's behalf, those parties act as Personal Information Processors bound by Data Processing Agreements that require them to process data only on pbwin's documented instructions and in compliance with applicable Philippine law.

pbwin collects the following categories of personal data, depending on how you interact with the Platform:

pbwin does not collect sensitive personal information as defined under the Data Privacy Act (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) unless required for specific compliance purposes and with appropriate safeguards in place.

pbwin collects your personal data through the following methods:

• Direct Collection: Information you provide when creating your pbwin Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or interacting with promotional campaigns.
• Automated Collection: Technical and behavioral data collected automatically when you access the Platform, including through cookies, web beacons, log files, and session tracking technologies. See Section 8 for more detail on cookies.
• Third-Party Sources: Identity and payment verification data received from KYC service providers, payment processors (such as GCash, Maya, BPI, and BDO), and fraud prevention services in connection with transactions you initiate on the Platform.
• Regulatory Sources: In limited circumstances, pbwin may receive information from regulatory bodies such as PAGCOR or the Anti-Money Laundering Council (AMLC) in connection with its compliance obligations.

pbwin processes your personal data for the following purposes:

• Account Registration and Management: To create, verify, maintain, and administer your pbwin Player Account, including processing login credentials and account preferences.
• Identity and Age Verification (KYC): To verify that you are who you say you are and that you meet the minimum age requirement of 21 years, as required by PAGCOR and Philippine law.
• Transaction Processing: To process deposits, withdrawals, and internal fund transfers in PHP, including interfacing with GCash, Maya, BPI, BDO, Metrobank, and other Philippine payment providers.
• Platform Provision and Improvement: To operate, maintain, and improve the pbwin Platform, including game delivery, live dealer streaming, sports betting services, and bingo hall management.
• Customer Support: To respond to your inquiries, resolve disputes, and handle complaints through pbwin's 24/7 live chat and email support channels.
• Legal and Regulatory Compliance: To comply with pbwin's obligations under PAGCOR regulations, the Philippine Data Privacy Act, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws, including mandatory reporting of suspicious transactions to the AMLC.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, identity theft, unauthorized account access, and other prohibited conduct in accordance with Section 9 of the Terms & Conditions.
• Responsible Gaming: To monitor gaming activity for patterns consistent with problem gambling and to enforce Responsible Gaming Tools including deposit limits, session limits, and self-exclusion.
• Marketing and Promotions: To send you promotional offers, bonus notifications, and updates about pbwin services where you have provided consent to receive such communications. You may withdraw consent at any time by contacting support.
• Analytics: To analyze aggregated, anonymized Platform usage data to understand player behavior, improve game selection, optimize the user interface, and measure the effectiveness of promotions.

pbwin processes your personal data on one or more of the following legal bases under the Philippine Data Privacy Act of 2012:

• Consent: Where you have freely given, specific, informed, and unambiguous consent to the processing of your personal data for a stated purpose (e.g., receiving marketing communications).
• Performance of a Contract: Where processing is necessary to fulfil our contractual obligations to you as a Player, including account operation, game delivery, and transaction processing.
• Legal Obligation: Where processing is required to comply with a legal obligation to which pbwin is subject under Philippine law, including KYC requirements, AMLC reporting, and PAGCOR compliance.
• Legitimate Interests: Where processing is necessary for pbwin's legitimate interests — such as fraud prevention, platform security, and responsible gaming monitoring — provided that such interests are not overridden by your fundamental rights and interests.

pbwin does not sell your personal data to any third party. We share your data only in the following circumstances and only to the extent necessary for each stated purpose:

• Payment Processors: Transaction data (including partial account identifiers) is shared with GCash, Maya, BPI, BDO, Metrobank, InstaPay, and other Philippine payment providers solely to process your deposits and withdrawals.
• KYC Verification Providers: Identity data and document scans are shared with accredited KYC service providers engaged by pbwin to verify your identity and age in compliance with PAGCOR requirements.
• Fraud Prevention and Security Services: Technical and behavioral data may be shared with fraud detection service providers to identify and prevent prohibited conduct on the Platform.
• Game Technology Providers: Limited data (such as Player ID and session identifiers, but not full personal details) may be shared with game software providers to facilitate game delivery and resolve technical disputes.
• Regulatory and Law Enforcement Authorities: pbwin is required by Philippine law to disclose personal data to PAGCOR, the AMLC, the National Privacy Commission (NPC), and other competent Philippine authorities where required by regulation or valid legal process.
• Cloud Infrastructure Providers: Data is stored on secure cloud infrastructure operated by third-party providers engaged under Data Processing Agreements. These providers process data only on pbwin's instructions.
• Business Transfers: In the event of a merger, acquisition, or sale of pbwin's business or assets, Player data may be transferred as part of that transaction, subject to the receiving party's agreement to maintain equivalent data protection standards.

All third-party data processors engaged by pbwin are required to process personal data only in accordance with pbwin's documented instructions and applicable Philippine data protection law.

pbwin uses cookies and similar tracking technologies to operate the Platform, improve your experience, and comply with security and regulatory requirements. The following types of cookies are used:

• Essential Cookies: Strictly necessary for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, last-visited game category, and remembered login state (where you have opted into "Remember Me"). These improve convenience but are not essential.
• Analytical Cookies: Used in aggregated, anonymized form to understand how Players interact with the Platform — which features are used most, how navigation flows work, and where technical issues arise. This data helps pbwin improve the product for all Filipino players.
• Security Cookies: Used to detect and prevent fraudulent access, bot activity, and other security threats. These include device fingerprinting and session integrity tokens.

pbwin does not use third-party advertising cookies or serve targeted advertising to Players through the Platform. You can manage cookie preferences through your browser settings. Note that disabling essential cookies will prevent the Platform from functioning correctly.

pbwin retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, as set out in this Privacy Policy, and as required by applicable Philippine law. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your active Account and for a minimum of 5 years after Account closure, in compliance with PAGCOR regulations and the Anti-Money Laundering Act's record-keeping requirements.
• KYC and Identity Document Data: Retained for a minimum of 5 years after the verification was completed or the Account was closed, whichever is later, as required by the AMLC.
• Financial Transaction Records: Retained for a minimum of 5 years from the date of each transaction, in compliance with AMLA and PAGCOR record-keeping requirements.
• Customer Support Communications: Retained for 3 years after the relevant support interaction, to facilitate dispute resolution and quality management.
• Technical and Log Data: Retained for up to 12 months for security and fraud detection purposes, after which it is anonymized or deleted.
• Marketing Consent Records: Retained for the period during which marketing communications are sent, plus 3 years after consent withdrawal, as evidence of lawful processing.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents reconstruction of the original data. Where deletion is not immediately practicable due to technical constraints, data will be securely isolated pending destruction.

pbwin implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or alteration. These measures include:

• Encryption in Transit: All data transmitted between your browser or device and the pbwin Platform is encrypted using TLS 1.3 (256-bit SSL). The padlock icon in your browser confirms this encryption is active.
• Encryption at Rest: Personal data stored in pbwin's databases is encrypted at rest using industry-standard AES-256 encryption.
• Access Controls: Access to personal data within pbwin's internal systems is restricted to authorized personnel on a strict need-to-know basis. All internal access is logged and audited.
• Two-Factor Authentication: All pbwin staff with access to systems containing personal data are required to use two-factor authentication. Players are offered OTP-based two-factor authentication for their Accounts.
• Security Monitoring: pbwin's systems are subject to continuous security monitoring for intrusion attempts, anomalous access patterns, and data exfiltration attempts.
• Incident Response: pbwin maintains a documented data breach response procedure. In the event of a data breach that is likely to result in a risk to Player rights and freedoms, pbwin will notify the National Privacy Commission within 72 hours of becoming aware of the breach, as required by the Data Privacy Act, and will notify affected Players without undue delay.

The pbwin Platform is strictly restricted to individuals who are 21 years of age or older in compliance with PAGCOR's minimum age requirement for online real-money gaming in the Philippines. pbwin does not knowingly collect personal data from individuals under the age of 21.

If pbwin discovers or reasonably suspects that personal data has been collected from an individual under 21 years of age, pbwin will:

• Immediately suspend the associated Account;
• Delete the personal data of the minor from its records, subject to any mandatory retention obligations arising from the circumstances of the Account;
• Take appropriate steps in accordance with PAGCOR's requirements regarding underage gambling incidents.

If you believe that a person under 21 has accessed or registered with pbwin, please notify pbwin's support team immediately via live chat or the email address in Section 15.

To exercise any of your rights under the Philippine Data Privacy Act as summarized in the Feature Cards above, you may submit a request to pbwin's Data Protection Officer using the contact details in Section 15.

When making a rights request, please provide:

• Your full registered name and pbwin Account email address or mobile number;
• A clear description of the right you are seeking to exercise and the specific data it relates to;
• Sufficient information to verify your identity — pbwin may require you to provide proof of identity before acting on any rights request.

pbwin will respond to your request within 15 calendar days of receipt. In complex cases, or where pbwin requires additional information, the response period may be extended by up to a further 15 days, and you will be informed of the extension and the reason for it.

pbwin will not charge a fee for processing rights requests unless a request is manifestly unfounded or excessive, in which case pbwin may charge a reasonable fee or decline to act.

If you are not satisfied with pbwin's response to a rights request or believe that pbwin is not processing your personal data in compliance with the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

Some of pbwin's service providers — including cloud infrastructure providers and game technology partners — may process personal data in servers or facilities located outside the Philippines. Where such cross-border transfers occur, pbwin ensures that:

• The transfer is made to a country or jurisdiction that provides an adequate level of data protection, as recognized by the National Privacy Commission; or
• Appropriate safeguards are in place, including Data Processing Agreements that incorporate standard contractual clauses equivalent to those required under Philippine law; or
• The transfer is otherwise permitted under the Data Privacy Act and its Implementing Rules and Regulations.

In all cases, pbwin maintains contractual oversight of how transferred data is processed and requires third-party processors to implement security standards equivalent to those applied by pbwin within the Philippines.

pbwin may update this Privacy Policy from time to time to reflect changes in the Platform's operations, applicable Philippine law, or regulatory guidance from the National Privacy Commission or PAGCOR.

When material changes are made to this Policy, pbwin will notify registered Players by sending a notification to their registered email address and/or by displaying a prominent notice on the Platform. The effective date at the top of this Policy will be updated to reflect the date of the most recent revision.

Your continued use of the Platform after the effective date of an updated Privacy Policy constitutes your acceptance of the changes. If you do not accept the updated Policy, you must cease using the Platform and may request Account closure by contacting support.

For all data privacy inquiries, rights requests, or complaints, please contact pbwin's Data Protection Officer (DPO) through the following channels:

• Live Chat: 24/7 via the pbwin Platform at pbwin.vip. State that your inquiry is a "Data Privacy Matter" at the start of the conversation to be directed to the appropriate team.
• Email: [email protected] — mark the subject line as "Data Privacy Request" or "DPO Inquiry" for routing to the Data Protection Officer.
• Postal / Registered Address: Operations: Metro Manila, Philippines.

pbwin's DPO is responsible for overseeing compliance with the Data Privacy Act, managing the company's data protection program, and serving as the primary point of contact between pbwin and the National Privacy Commission.