Privacy Policy — 43winph

1 About This Privacy Policy

This Privacy Policy ("Policy") applies to all personal data collected by 43winph ("we," "us," "our") through the website at 43winph.co (the "Website") and any related services, features, or communications offered by the 43winph platform.

By registering an account on 43winph, making a deposit, or otherwise using the Website, you acknowledge that you have read and understood this Policy. If you do not agree with how 43winph handles your personal data, you should not use our services and should contact us to request account closure.

This Policy is effective as of June 2026 and supersedes all previous privacy notices issued by 43winph. It should be read in conjunction with our Terms & Conditions.

2 Data Controller

For purposes of the Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, 43winph acts as the Personal Information Controller (PIC) in respect of the personal data of its registered players and website visitors.

Our designated Data Protection Officer (DPO) can be reached at the contact details provided in Section 13 of this Policy. The DPO is responsible for ensuring 43winph's compliance with applicable data protection laws and for handling all data subject rights requests.

3 Personal Data We Collect

43winph collects personal data through various channels — registration forms, KYC submissions, customer support interactions, and automated platform activity. The categories of data we collect include:

We do not collect sensitive personal information (as defined under the Data Privacy Act) unless specifically required for regulatory compliance, in which case we will request your explicit consent.

4 How We Use Your Personal Data

43winph uses the personal data we collect for the following purposes:

• Account management: Creating, maintaining, and administering your 43winph player account, including identity verification and password recovery.
• Service delivery: Processing deposits, withdrawals, and game play; calculating and crediting bonuses; providing customer support.
• Legal and regulatory compliance: Fulfilling KYC requirements, complying with PAGCOR AML obligations, responding to lawful requests from Philippine government authorities, and maintaining audit records.
• Fraud prevention and security: Detecting and preventing fraudulent activity, money laundering, multiple accounts, and platform abuse.
• Responsible gaming: Monitoring play patterns to identify potential problem gambling behaviour and administering self-exclusion and limit requests.
• Communications: Sending transactional notifications (deposit confirmations, withdrawal alerts, security alerts) and, where you have opted in, promotional communications about 43winph offers.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the 43winph website, game offerings, and user experience.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, 43winph processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to fulfil our obligations under the 43winph Terms & Conditions (e.g., account creation, payment processing, game delivery).
• Legal obligation: Processing mandated by PAGCOR regulations, Philippine AML laws, tax obligations, and other applicable legal requirements.
• Legitimate interests: Processing necessary for fraud prevention, security, and platform integrity, where such interests are not overridden by your rights.
• Consent: Processing for optional purposes — such as marketing communications or enhanced analytics — where you have provided explicit, informed, and freely given consent. You may withdraw this consent at any time.

6 Data Sharing & Third-Party Disclosure

43winph does not sell or rent your personal data to third parties. We may share your data in the following limited circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers receive only the data necessary to process your transactions.
• Game software providers: Licensed game providers (e.g., PG Soft, Pragmatic Play) may receive session tokens and anonymised player identifiers to deliver game content. These providers are contractually prohibited from using such data for any purpose other than game delivery.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is legally required.
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and IT service providers who process data on our behalf under strict data processing agreements.

All third-party processors engaged by 43winph are contractually bound to process your personal data solely on our instructions and in compliance with the Data Privacy Act of 2012.

7 Data Security

43winph implements a comprehensive set of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 43winph servers.
• Passwords stored using one-way cryptographic hashing — 43winph cannot view your raw password and will never ask for it.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Regular penetration testing, vulnerability scanning, and independent security audits.
• Optional two-factor authentication (2FA) for all 43winph player accounts.
• Incident response procedures compliant with the 72-hour breach notification requirement under NPC Circular 16-03.

8 Data Retention

43winph retains your personal data for as long as necessary to fulfil the purposes described in this Policy and to comply with legal and regulatory obligations:

• Active accounts: Data is retained for the duration of your account's active status.
• Closed accounts: Account records, transaction history, and KYC documentation are retained for a minimum of five (5) years following account closure, in compliance with PAGCOR AML regulations and the Anti-Money Laundering Act (Republic Act No. 9160, as amended).
• Marketing data: Where consent has been given for marketing communications, data is retained until you withdraw your consent or request erasure, subject to overriding legal retention requirements.
• Technical / log data: Server and session logs are retained for up to 12 months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, 43winph will securely delete or anonymise your personal data.

9 Cookies & Tracking Technologies

43winph uses cookies and similar tracking technologies on the Website for the following purposes:

• Essential cookies: Required for the Website to function correctly, including maintaining your login session and remembering your language preference. These cannot be disabled without breaking core functionality.
• Analytics cookies: Used to collect anonymised data on how players navigate the Website (pages visited, time spent, error rates). This helps 43winph improve platform performance. No personally identifiable information is included in analytics data.
• Functional cookies: Remember your preferences (e.g., game display settings, responsible gaming limit reminders) to personalise your experience.

43winph does not use advertising cookies or allow third-party advertisers to track you across external websites. You may manage cookie preferences through your browser settings; however, disabling essential cookies may impair your ability to use the 43winph platform.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 43winph:

• Right to be Informed: You have the right to know what personal data we collect, why, and how it is processed — which this Policy provides.
• Right to Access: You may request a copy of the personal data we hold about you. We will respond to verified requests within 15 business days.
• Right to Rectification: You have the right to correct inaccurate or incomplete personal data. You may update most information directly in your 43winph account settings.
• Right to Erasure: Subject to legal retention obligations, you may request deletion of your personal data upon closing your account.
• Right to Object: You may object to the processing of your personal data on grounds of legitimate interest, including processing for direct marketing purposes.
• Right to Data Portability: You may request a machine-readable copy of the personal data you have provided to 43winph.
• Right to Lodge a Complaint: If you believe your data rights have been violated, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, contact our Data Protection Officer (see Section 13). We may require identity verification before processing rights requests.

11 Children's Privacy

The 43winph platform is strictly for adults aged 21 years and above. We do not knowingly collect personal data from anyone under the age of 21. If 43winph becomes aware that a minor has registered an account or submitted personal data through the Website, that account will be immediately closed, all funds forfeited, and the personal data securely deleted.

If you are a parent or guardian and believe that a minor has accessed 43winph, please contact our support team immediately at the details provided in Section 13.

12 Changes to This Privacy Policy

43winph reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. When material changes are made, we will notify registered players via email and post a notice on the Website at least 7 days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Continued use of 43winph following the effective date of any updated Policy constitutes your acceptance of the revised terms.

13 Contact & Data Protection Officer

For all data privacy-related enquiries, rights requests, complaints, or to reach our Data Protection Officer, please use the following contact:

• Email: [email protected]
• Subject line: "Data Privacy Request — [Your Registered Email]"
• Response time: We aim to acknowledge all data privacy requests within 3 business days and resolve them within 15 business days.