pbawin Privacy Policy

pbawin is the operator of the online gaming platform accessible at pbawin.one. For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, pbawin acts as the Personal Information Controller in respect of the personal data it collects from users of the platform.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer (DPO) through the following channel:

• Email: [email protected] (please include "Privacy / DPO" in your subject line)

Please note that the email address above is provided as plain text for informational purposes. It is not a clickable link. We aim to respond to all privacy-related inquiries within fifteen (15) business days of receipt.

pbawin collects personal data from you in several ways — directly when you provide it to us, automatically when you use our platform, and from third parties where permitted by law. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Registration data: Full name, date of birth, email address, mobile number, and residential address (including city and province within the Philippines).
• Identity verification (KYC) data: Government-issued identification documents (such as a Philippine passport, SSS ID, PhilSys National ID, driver's licence, or UMID), selfie photographs, and proof of address documents.
• Payment data: GCash account details, PayMaya account details, bank account information (BDO, BPI, Metrobank, UnionBank, or other Philippine banks), and transaction history. Note: pbawin does not store full card numbers or CVV codes.
• Communications data: Messages, emails, and chat transcripts exchanged with our customer support team.
• Responsible gaming data: Self-exclusion requests, deposit limit settings, and cooling-off period preferences.

2.2 Data Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage data: Pages visited, games played, session duration, click patterns, search queries within the platform, and feature interactions.
• Location data: General geographic location derived from your IP address (country and region level). pbawin does not collect precise GPS location data.
• Cookie and tracking data: Information collected through cookies, web beacons, and similar technologies as described in Section 8 of this Privacy Policy.

2.3 Data Received from Third Parties

• Payment processors: Transaction confirmation data, payment status, and fraud screening results from GCash, PayMaya, and partner banks.
• Identity verification providers: Results of automated identity and age verification checks conducted by our KYC service partners.
• Regulatory authorities: Information shared by PAGCOR or other competent Philippine authorities in connection with our compliance obligations.

pbawin processes your personal data only for specific, legitimate purposes. The table below summarises the primary purposes for which we use your data and the legal basis for each:

Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal. To withdraw consent for marketing communications, you may use the unsubscribe link in any marketing email or contact our support team.

pbawin does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: GCash, PayMaya, BDO, BPI, Metrobank, UnionBank, and other Philippine payment processors, solely to facilitate deposits and withdrawals on your behalf.
• KYC and identity verification partners: Third-party service providers that assist us in verifying your identity, age, and the authenticity of documents submitted during the KYC process.
• Game content providers: Software providers whose games are available on the pbawin platform may receive anonymised or pseudonymised gameplay data for technical and licensing purposes.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where we are legally required to disclose information.
• Professional advisers: Lawyers, auditors, and accountants who are bound by professional confidentiality obligations, where necessary for the operation of our business.

Any third party that processes personal data on behalf of pbawin is required to do so only in accordance with our instructions and in compliance with the Data Privacy Act of 2012 and its implementing rules. We do not permit our service providers to use your personal data for their own purposes.

pbawin retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account and registration data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering regulations.
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine financial regulations.
• Customer support communications: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing preferences and consent records: Retained for the duration of your account and for one (1) year following account closure or withdrawal of consent.
• Technical and usage logs: Retained for up to twelve (12) months, unless required for longer periods for security investigations or legal proceedings.

When personal data is no longer required, pbawin will securely delete or anonymise it in accordance with our data disposal procedures. Anonymised data that can no longer be linked to an identifiable individual may be retained indefinitely for statistical and analytical purposes.

Under the Data Privacy Act of 2012 and its implementing rules, Filipino players have the following rights in relation to their personal data held by pbawin:

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Subject Request." We will respond within fifteen (15) business days. We may need to verify your identity before processing your request.

pbawin implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS): All data transmitted between your device and pbawin servers is encrypted using TLS 1.2 or higher.
• Encryption at rest: Sensitive personal data stored on our servers, including KYC documents and payment information, is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorised pbawin personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Regular security audits: pbawin conducts periodic security assessments, penetration testing, and vulnerability scans to identify and remediate potential weaknesses in our systems.
• Intrusion detection: Our infrastructure is monitored around the clock by automated intrusion detection and prevention systems.
• Incident response: pbawin maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the NPC and affected users in accordance with the requirements of the Data Privacy Act of 2012.

While pbawin takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials. If you suspect that your pbawin account has been compromised, please contact us immediately at [email protected].

pbawin uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file placed on your device when you visit our website. We use the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Functional cookies: These cookies remember your preferences (such as language settings and game display options) to provide a more personalised experience.
• Analytics cookies: These cookies collect anonymised information about how users interact with the pbawin platform, helping us understand which features are most used and where improvements can be made.
• Security cookies: These cookies help us detect and prevent fraudulent activity, bot traffic, and other security threats.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the pbawin platform. Strictly necessary and security cookies cannot be disabled without impacting your ability to use the platform.

pbawin does not use third-party advertising cookies or allow external advertisers to place tracking cookies on our platform.

The pbawin platform is strictly intended for persons aged 21 years and above. pbawin does not knowingly collect personal data from individuals under the age of 21. Our registration process includes age verification steps designed to prevent minors from accessing the platform.

If pbawin becomes aware that personal data has been collected from a person under the age of 21, we will immediately close the relevant account, delete the associated personal data to the extent permitted by law, and return any deposited funds to the payment source.

If you believe that a minor has registered on the pbawin platform, please notify us immediately at [email protected] so that we can take prompt action.

In the course of operating the pbawin platform, your personal data may be transferred to and processed in countries other than the Philippines — for example, where our cloud infrastructure providers or game content partners are located. Where such transfers occur, pbawin ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012.

These safeguards may include:

• Contractual clauses that require the recipient to protect your personal data to the same standard as required under Philippine law.
• Transfers only to countries or organisations that have been assessed as providing an adequate level of data protection.
• Binding corporate rules where data is transferred within a group of companies.

By using the pbawin platform, you acknowledge and consent to the transfer of your personal data as described in this section, subject to the safeguards outlined above.

pbawin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered users via email or a prominent notice on the platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how pbawin protects your personal data.

Your continued use of the pbawin platform after the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy. If you do not agree with any changes, you should cease using the platform and may close your account in accordance with our Terms and Conditions.