ManilaWin Privacy Policy – How We Protect Your Data

1. Who We Are

ManilaWin is an online gaming and sports betting platform operated for players in the Philippines and accessible at manilawin.best. When we refer to "ManilaWin," "we," "us," or "our" in this Privacy Policy, we mean the entity responsible for collecting and processing your personal data in connection with the ManilaWin Platform.

ManilaWin acts as both the data controller and data processor for most personal data collected through the Platform. Where we engage third-party processors – such as payment providers or game software companies – we do so under written agreements that require those parties to handle your data securely and only for the purposes we specify.

This Privacy Policy covers all services available through the ManilaWin website and any mobile applications associated with the Platform. It applies to all registered players, visitors to the site, and anyone who contacts ManilaWin for support or enquiries.

2. Data We Collect

ManilaWin collects personal data that is necessary and proportionate to the services we provide. We do not collect more information than we need. The categories of data we may collect about you include:

Information You Provide Directly

• Registration data: full name, date of birth, email address, mobile number, and a valid government-issued ID number.
• Identity verification documents: scanned copies of a Philippine passport, UMID, SSS card, driver's licence, or PhilHealth card when required for KYC (Know Your Customer) verification.
• Payment information: GCash or Maya mobile number, bank account or e-wallet details, Visa or Mastercard details. We do not store full card numbers – these are processed through PCI-DSS compliant payment gateways.
• Communications: messages you send to our customer support team, responses to surveys, and any correspondence related to your account.

Data Collected Automatically

• Device and browser data: IP address, device type, operating system, browser version, and screen resolution.
• Usage data: pages visited, games played, betting history, session duration, login timestamps, and navigation patterns within the Platform.
• Location data: general geographic location derived from your IP address, used to comply with jurisdictional restrictions.
• Cookies and similar technologies: as detailed in Section 6 of this policy.

3. How We Use Your Data

ManilaWin uses your personal data for specific, legitimate purposes. We do not use your data in ways that you would not reasonably expect given the nature of an online gaming platform. Here is how we use the data we collect:

• Account management: to create, verify, and maintain your ManilaWin account, including processing login credentials and account preferences.
• Identity and age verification: to confirm that you meet the eligibility requirements to use the Platform, including the minimum age of 21.
• Payment processing: to handle deposits and withdrawals securely and ensure funds are sent to and received from the correct payment method.
• Customer support: to respond to your enquiries, resolve disputes, and keep records of your interactions with our support team.
• Fraud prevention and security: to detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other security threats.
• Regulatory compliance: to meet our obligations under Philippine gaming regulations and data privacy law, including maintaining records as required by our licence.
• Responsible gaming: to monitor gaming behaviour and identify signs of problem gambling, and to respond to self-exclusion requests.
• Platform improvement: to understand how players use ManilaWin and to improve the performance, design, and features of the Platform.
• Marketing communications: to send you promotional offers and updates about ManilaWin, where you have opted in to receive them. You can opt out at any time.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173), ManilaWin relies on the following legal bases for processing your personal data:

• Contractual necessity: Processing your registration data, payment details, and account transactions is necessary to fulfil our contract with you as a ManilaWin player.
• Compliance with legal obligations: We are required by our gaming licence and anti-money laundering regulations to collect and retain certain data, including identity verification documents and transaction records.
• Legitimate interests: We process usage and technical data to keep the Platform secure, prevent fraud, and improve our services. These interests do not override your fundamental privacy rights.
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you can withdraw at any time.

5. Sharing Your Data

ManilaWin does not sell, rent, or trade your personal information to any third party. We share your data only in the following limited circumstances:

• Payment processors: We share payment-related data with our partner payment gateways (such as GCash, Maya, and card processors) to process your transactions. These providers are contractually bound to handle your data securely.
• Game software providers: Some game data is processed by the third-party providers whose games appear on the ManilaWin Platform. This is limited to what is necessary to deliver the game experience and record outcomes.
• Identity verification services: We may use third-party KYC providers to verify government-issued IDs. These providers operate under data processing agreements and are not permitted to use your data for any other purpose.
• Regulatory authorities: We may be required to disclose certain information to the relevant Philippine gaming regulatory body, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or law enforcement agencies, where we are legally obligated to do so.
• Fraud prevention partners: We may share limited data with fraud prevention and cybersecurity services to protect the Platform and our players.
• Business transfers: In the unlikely event of a merger or acquisition, your data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

We require all third parties who receive your personal data to respect its security and to process it only in accordance with our instructions and applicable law.

6. Cookies & Tracking Technologies

ManilaWin uses cookies and similar tracking technologies to make the Platform work properly and to understand how players use our services. Here's a breakdown of what we use and why:

• Essential cookies: These are necessary for the Platform to function. They enable you to log in, navigate between pages, and maintain your session. You cannot disable these without affecting the Platform's core functionality.
• Analytics cookies: We use analytics tools to understand how players interact with ManilaWin – which games are most popular, how long sessions last, and where players encounter issues. This data is aggregated and does not identify you personally.
• Preference cookies: These remember your settings and preferences, such as your preferred language and display options, so you don't have to reconfigure them every visit.
• Marketing cookies: If you consent, these cookies allow us to deliver relevant promotional content and measure the effectiveness of our marketing campaigns.

You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling certain cookies may affect your experience on the ManilaWin Platform.

7. Data Retention

ManilaWin retains your personal data for as long as is necessary to fulfil the purposes outlined in this Privacy Policy and to comply with our legal and regulatory obligations. Here are our general retention guidelines:

• Active account data: Retained for the duration of your account plus a minimum of five years after account closure, as required by anti-money laundering regulations.
• Transaction records: Retained for a minimum of five years from the date of the transaction in line with our gaming licence requirements.
• Identity verification documents: Retained for five years after account closure or the completion of the business relationship.
• Customer support records: Retained for three years from the date of the interaction.
• Marketing data: Retained until you withdraw your consent or for a maximum of three years from the last interaction, whichever comes first.

When data is no longer needed, we securely delete or anonymise it in accordance with our data retention procedures. Anonymised or aggregated data that cannot be linked back to an individual may be retained indefinitely for analytical purposes.

8. Security Measures

Protecting your personal data is one of ManilaWin's most important responsibilities. We implement technical and organisational measures designed to prevent unauthorised access, disclosure, alteration, or destruction of your information. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encrypted storage of sensitive data including passwords (hashed using bcrypt) and financial details.
• Role-based access controls ensuring that only authorised staff can access personal data, limited to what is needed for their role.
• Regular security audits and penetration testing by independent cybersecurity professionals.
• Two-factor authentication (2FA) available for all player accounts – we strongly recommend enabling it.
• Continuous monitoring for suspicious activity, attempted breaches, and unusual account behaviour.
• Staff training on data privacy and security awareness conducted on a regular basis.

9. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have specific rights regarding your personal data held by ManilaWin. We take these rights seriously and will respond to all valid requests within 15 business days.

10. Children's Privacy

The ManilaWin Platform is strictly for adults aged 21 and over. We do not knowingly collect personal data from anyone under the age of 21. If we discover that we have inadvertently collected data from a minor, we will delete that information immediately and close the associated account.

If you are a parent or guardian and believe a minor has registered on ManilaWin, please contact us immediately at support@manilawin.best. We will investigate and take prompt action.

11. Changes to This Privacy Policy

ManilaWin may update this Privacy Policy from time to time to reflect changes in law, regulation, technology, or our business practices. When we make material changes, we will notify registered users by email and display a notice prominently on the Platform at least 7 days before the changes take effect.

We encourage you to review this Privacy Policy periodically. The date at the top of this page indicates when the policy was last updated. Your continued use of the ManilaWin Platform after any changes take effect constitutes your acknowledgment of the updated policy.

12. Contact Us & Your Data Protection Officer

If you have any questions, concerns, or requests related to this Privacy Policy or how ManilaWin handles your personal data, please contact our Data Protection Officer (DPO):

• Email: support@manilawin.best
• Subject line: "Privacy Request – [your full name]" for faster routing
• Response time: We aim to respond within 15 business days, and often much sooner.
• Live chat: Available 24/7 through the ManilaWin Platform for general privacy questions.