winspire Privacy Policy

1. Overview & Scope

winspire ("we," "us," or "our") operates as a data controller in respect of the personal data collected through the winspire platform. We are committed to processing personal data in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission ("NPC").

This Privacy Policy must be read alongside the winspire Terms & Conditions and Responsible Gaming Policy. By creating a winspire account or using any part of the winspire platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

winspire may update this Privacy Policy from time to time. Significant changes will be communicated to registered players via email and/or a platform notification. The "Last Updated" date at the top of this document indicates when the most recent revision was made.

2. Personal Data We Collect

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

winspire does not collect sensitive personal information (as defined under the DPA) unless strictly necessary for KYC compliance or as required by applicable law. winspire does not collect credit or debit card numbers directly — all card-based transactions, where applicable, are processed by certified third-party payment processors.

3. How winspire Collects Personal Data

winspire collects personal data through the following means:

• Direct collection: Information you provide when creating a winspire account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the winspire platform, including IP address, device identifiers, session data, and cookies (see Section 9 for full details);
• Third-party sources: Identity and financial verification data received from our KYC and AML compliance service providers; fraud prevention data received from third-party risk management platforms; payment confirmation data received from GCash, Maya, BPI, BDO, Metrobank, and other payment processors;
• Publicly available sources: Where permitted by applicable law and necessary for fraud prevention or AML compliance, winspire may consult publicly available databases, including records published by Philippine government agencies.

4. Purpose of Processing Your Personal Data

winspire processes your personal data only for specified, legitimate purposes. The primary purposes for which we process player data are:

• Account management: To create, maintain, secure, and close your winspire account, and to authenticate your identity on login;
• Payment processing: To facilitate deposits and withdrawals in Philippine Peso through GCash, Maya, and other approved methods, and to maintain accurate financial records;
• KYC & AML compliance: To verify player identity before processing withdrawals and to monitor transactions for suspicious financial activity as required under Philippine law;
• Game delivery: To provide the games, services, and features available on the winspire platform and to maintain game history and balance records;
• Responsible gaming: To operate and enforce deposit limits, loss limits, session alerts, cooling-off periods, and self-exclusion tools elected by players or mandated by regulatory requirements;
• Customer support: To respond to inquiries, resolve complaints, and maintain support records for quality assurance;
• Security & fraud prevention: To detect, investigate, and prevent unauthorized account access, fraud, bonus abuse, and other prohibited conduct;
• Legal compliance: To comply with applicable Philippine laws, including reporting obligations to regulatory authorities;
• Marketing (with consent): To send promotional offers, bonus notifications, and platform updates to players who have opted in to marketing communications. Players may withdraw consent at any time.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, winspire processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations to you under the winspire Terms & Conditions — including account management, payment processing, and game delivery;
• Legal obligation: Processing required for compliance with Philippine law, including AML obligations, KYC requirements, and regulatory reporting;
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming enforcement, and the improvement of winspire services, where such interests are not overridden by your data rights;
• Consent: Processing for marketing communications and non-essential analytics, where you have provided clear, freely given, and informed consent. This consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Third-Party Disclosure

winspire does not sell, rent, or trade your personal data to any third party for commercial purposes. winspire may share your personal data with the following categories of recipients only where necessary and lawful:

• Payment processors: GCash, Maya, GrabPay, BPI, BDO, Metrobank, and InstaPay — solely to process your deposits and withdrawals;
• KYC & AML service providers: Identity verification and anti-money laundering compliance platforms engaged by winspire to verify player identities and monitor transactions;
• Game providers: Certified third-party game studios (e.g., Pragmatic Play, PG Soft, Hacksaw) may receive anonymized session and technical data necessary to deliver their games;
• Fraud prevention platforms: Third-party risk management services engaged to detect and prevent unauthorized access and financial fraud;
• Regulatory authorities: Philippine regulatory bodies, including PAGCOR and the NPC, where disclosure is required by law or court order;
• Professional advisers: Legal, accounting, and auditing firms engaged by winspire under obligations of professional confidentiality.

All third-party service providers engaged by winspire are contractually bound to process personal data only for the specified purposes outlined above and to maintain appropriate security standards consistent with applicable Philippine data protection law.

7. Data Retention Periods

winspire retains personal data only for as long as necessary to fulfil the purpose for which it was collected, and to comply with applicable legal retention obligations. The following retention periods apply:

• Account and identity data: Retained for the duration of your active winspire account, plus a minimum of five (5) years after account closure — as required by Philippine AML regulations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with applicable financial record-keeping obligations;
• Game history and betting records: Retained for three (3) years from the date of each session, unless required longer for dispute resolution or regulatory purposes;
• Customer support communications: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained for the duration of your consent plus three (3) years, to enable us to demonstrate compliance if challenged;
• Technical and security logs: Retained for twelve (12) months, unless a security incident requires extended retention for investigation purposes.

Upon expiry of the applicable retention period, winspire will securely delete or anonymize your personal data in a manner that prevents reconstruction or identification.

8. Data Security Measures

winspire implements a layered approach to data security, including the following organizational and technical measures:

• End-to-end 256-bit SSL/TLS encryption for all data transmitted to and from the platform;
• Encrypted storage of all personally identifiable information at rest;
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need;
• Multi-factor authentication for all winspire administrative systems;
• Regular security assessments and penetration testing conducted by independent third parties;
• Automated monitoring for unusual access patterns and potential data breach indicators;
• Staff data protection training and binding confidentiality obligations for all employees with access to personal data;
• Incident response procedures to contain and report any personal data breach in accordance with NPC notification requirements.

Despite winspire's implementation of robust security measures, no data transmission over the internet or electronic storage system is unconditionally secure. winspire cannot guarantee absolute security of your data. Players are responsible for maintaining the security of their winspire login credentials and should contact support immediately upon suspecting unauthorized access.

9. Cookies & Tracking Technologies

winspire uses cookies and similar tracking technologies to operate the platform, personalize your experience, and analyze platform performance. The following types of cookies are used:

• Strictly necessary cookies: Required for the platform to function — including session authentication tokens, login state management, and security cookies. These cannot be disabled without disrupting platform functionality;
• Functional cookies: Remember your platform preferences — such as language settings, preferred game categories, and responsible gaming tool configurations;
• Analytics cookies: Collect anonymized data on how players interact with winspire — including pages visited, game categories browsed, and session duration — to help winspire improve the platform experience;
• Marketing cookies: Used only where you have explicitly opted in, to personalize promotional content displayed to you within the platform.

You may manage your cookie preferences through your browser settings. Blocking strictly necessary cookies will affect platform functionality. winspire does not use third-party advertising networks to serve ads to players outside the winspire platform.

10. Your Data Rights Under Philippine Law

Under the Data Privacy Act of 2012, you hold the following rights in respect of your personal data processed by winspire:

• Right to be Informed: To know what personal data winspire collects about you, the purpose of processing, and the identity of any third parties to whom your data is disclosed;
• Right to Access: To obtain a copy of your personal data held by winspire and information about how it is being processed;
• Right to Rectification: To have inaccurate or incomplete personal data corrected without undue delay;
• Right to Erasure / Right to be Forgotten: To request deletion of your personal data where processing is no longer necessary, consent has been withdrawn, or processing is unlawful — subject to winspire's legal retention obligations;
• Right to Object: To object to processing of your personal data for direct marketing at any time, and to object to processing based on legitimate interests on grounds relating to your particular situation;
• Right to Data Portability: To receive your personal data in a structured, commonly used, machine-readable format and, where technically feasible, to request transfer to another data controller;
• Right to Lodge a Complaint: To lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact the winspire Data Protection Officer at the email address listed in Section 14 below. winspire will respond to all verified data rights requests within fifteen (15) business days, or within the timeframe prescribed by the NPC where a longer period is permitted.

11. Minors & Age Restriction

winspire maintains strict age verification procedures as part of KYC compliance. All players must be at least 21 years old to create a winspire account. This requirement exists in accordance with PAGCOR-regulated online gaming market standards applicable to the Philippines.

If you are a parent or guardian and believe that a minor under your supervision has provided personal data to winspire, please contact support immediately at the details in Section 14. winspire will verify the report and, where confirmed, will delete the data and close the account without undue delay.

12. International Data Transfers

Where winspire engages third-party service providers (including game studios, security platforms, and KYC verification services) that operate infrastructure outside the Philippines, personal data may be transferred to servers located in other jurisdictions. Such transfers are carried out only where:

• The receiving jurisdiction provides an adequate level of data protection as assessed by the NPC or under applicable Philippine law;
• Appropriate contractual safeguards — including standard contractual clauses or equivalent data processing agreements — are in place between winspire and the receiving third party;
• The transfer is strictly necessary for the performance of services described in this Privacy Policy.

winspire does not transfer personal data internationally for purposes beyond those stated in this Privacy Policy. Players may request information about the safeguards applicable to any specific international transfer by contacting the winspire Data Protection Officer.

13. Changes to This Privacy Policy

winspire reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory guidance issued by the NPC. When material changes are made, winspire will notify registered players via email and/or a prominent notice displayed on the platform for at least 14 days before the changes take effect.

The version of this Privacy Policy displaying the most recent "Last Updated" date at the top of this page is the version currently in force. Continued use of the winspire platform after the effective date of any update constitutes your acknowledgment of the revised Privacy Policy.

Previous versions of this Privacy Policy are available upon request to the winspire Data Protection Officer. winspire maintains a record of all historical versions for accountability purposes.

14. Contact & Data Protection Officer

winspire has appointed a Data Protection Officer ("DPO") in accordance with the requirements of the Data Privacy Act of 2012. The DPO is responsible for overseeing winspire's compliance with the DPA and its Implementing Rules and Regulations, and is the primary point of contact for all data privacy concerns.

If you believe that winspire has not adequately addressed your data privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines. Information about the NPC complaints process is available on the official NPC website.