wintime Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how wintime ("wintime," "we," "us," "our") collects, processes, stores, and discloses personal data relating to individuals ("you," "Player," "User") who access or use the wintime platform available at wintime.lat, including all associated games, payment services, promotional features, and customer support functions (collectively, the "Service").

wintime is committed to protecting the privacy and personal data of all users, particularly Filipino players whose data is governed by the Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations. By registering for and using a wintime account, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with the wintime Terms & Conditions, which govern your overall use of the Service. In the event of any conflict between this Policy and the Terms & Conditions on a privacy-related matter, this Policy shall prevail.

02 Data Controller

For the purposes of the Data Privacy Act of 2012 and other applicable privacy legislation, wintime is the Data Controller responsible for the personal data collected through the wintime platform. As Data Controller, wintime determines the purposes and means of processing your personal data and is accountable for ensuring that processing is carried out in compliance with applicable law.

wintime has designated a Data Protection Officer (DPO) responsible for overseeing compliance with data privacy obligations. Players may contact the wintime DPO with privacy-related inquiries or complaints at the contact address set out in Section 14 of this Policy. wintime takes its obligations as Data Controller seriously and has implemented appropriate technical and organisational measures to safeguard the personal data of all players.

03 Personal Data We Collect

wintime collects the following categories of personal data in connection with the operation of the Service:

3.1 Registration and Identity Data

When you create a wintime account, we collect: your full legal name (as it appears on your Philippine government-issued identification), date of birth, Philippine mobile number, email address (if provided), and the username and password you create. This data is required to establish and manage your account.

3.2 Know Your Customer (KYC) and Verification Data

As required under PAGCOR regulations and anti-money laundering (AML) laws applicable in the Philippines, wintime collects copies of government-issued identity documents for KYC verification purposes. Accepted documents include the PhilSys National ID, Philippine Passport, Driver's License, and UMID. wintime may also collect a facial photograph or selfie-with-ID for liveness verification purposes where required.

3.3 Financial and Transaction Data

wintime collects data relating to your financial transactions on the platform, including: deposit amounts and dates, payment method identifiers (e.g., GCash registered mobile number, bank account number last four digits), withdrawal requests and processing records, and account balance history. wintime does not store full credit or debit card numbers and does not process card-based payments directly.

3.4 Gaming Activity Data

wintime records your gaming activity on the platform, including: games played, wager amounts, game outcomes, session durations, and bonus usage history. This data is used for account management, responsible gaming monitoring, dispute resolution, and fraud prevention purposes.

3.5 Technical and Device Data

When you access the wintime platform, our systems automatically collect certain technical data, including: IP address, device type and operating system, browser type and version, referring URL, session timestamps, and general geographic location derived from IP address. This data is used for security monitoring, fraud prevention, and platform optimisation.

3.6 Communications Data

wintime retains records of communications between you and the wintime customer support team, including live chat transcripts, email correspondence, and records of any formal complaints or disputes. This data is retained for quality assurance, regulatory compliance, and dispute resolution purposes.

04 How wintime Uses Your Personal Data

wintime processes personal data for the following purposes:

• Account Creation and Management: To register your wintime account, verify your identity, maintain your account records, and manage your login credentials.
• Payment Processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, GrabPay, 7-Eleven, and USDT payment channels available to Philippine players.
• PAGCOR Regulatory Compliance: To fulfil wintime's obligations under PAGCOR's online gaming licensing framework, including player identification, KYC maintenance, and reporting of suspicious transactions as required by the Anti-Money Laundering Act (AMLA).
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, duplicate account creation, collusion, bonus abuse, and other prohibited activities on the platform.
• Responsible Gaming: To monitor gaming patterns and identify potential signs of problem gambling, to administer self-exclusion requests, and to apply deposit limits and session controls as set by the player or required by wintime's responsible gaming policy.
• Customer Support: To respond to your inquiries, process complaints, and resolve disputes in connection with your wintime account or gaming activity.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the wintime user experience, optimise game loading performance for Philippine mobile connections, and develop new features based on player behaviour patterns.
• Marketing Communications: To send promotional offers, bonus notifications, and game announcements to players who have not opted out of such communications. You may unsubscribe at any time via your account settings.
• Legal Compliance: To comply with applicable Philippine laws, respond to lawful requests from regulatory authorities including PAGCOR and the National Privacy Commission (NPC), and to establish, exercise, or defend legal claims.

05 Legal Basis for Processing

wintime processes your personal data under the following legal bases as recognised under the Data Privacy Act of 2012:

• Contractual Necessity: Processing of identity, financial, and gaming data is necessary for the performance of the contract between you and wintime — specifically, to operate your account and deliver the gaming services you have registered for.
• Legal Obligation: wintime is required by law to collect and retain certain player data under PAGCOR licensing requirements and the Anti-Money Laundering Act. This processing is mandatory and cannot be refused without affecting your ability to use the Service.
• Legitimate Interests: wintime processes technical and device data for fraud prevention and platform security based on wintime's legitimate interests in protecting the integrity of the platform and the security of all players' accounts and funds.
• Consent: Where wintime sends marketing communications, this is based on your consent as given during registration or through subsequent opt-in. You may withdraw this consent at any time without affecting the lawfulness of processing already carried out.

06 Data Sharing and Disclosure

wintime does not sell, rent, or trade your personal data to third parties for commercial purposes. wintime may share your personal data with the following categories of recipients only as necessary to operate the Service or to comply with legal obligations:

• Payment Service Providers: GCash, Maya, BPI, BDO, Metrobank, GrabPay, and other payment processors receive transaction-specific data necessary to process your deposits and withdrawals. Each provider operates under its own privacy policy and regulatory obligations.
• Identity Verification Providers: Third-party KYC and identity verification service providers may process your identification documents and photograph for verification purposes on behalf of wintime. These providers are contractually bound to process data solely for KYC purposes and maintain equivalent data security standards.
• Game Content Providers: Slot and live casino providers such as JILI, Pragmatic Play, PG Soft, and Evolution receive minimal session data (player identifier, bet amounts, game results) necessary to operate games technically. These providers do not receive your identity or payment data.
• Regulatory Authorities: wintime will disclose player data to PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), or other Philippine government authorities when required to do so by law, court order, or lawful regulatory directive.
• Professional Advisers: wintime's legal counsel, auditors, and compliance consultants may have access to player data to the extent necessary to provide their professional services, subject to binding confidentiality obligations.

07 Cookies and Tracking Technologies

wintime uses cookies and similar tracking technologies on the wintime platform to provide and improve the Service. A cookie is a small text file stored on your device by your browser at the instruction of a website. wintime uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the wintime platform to function. They maintain your login session, store your language and currency preferences, and enable the core functionality of account management and gaming. These cookies cannot be disabled without impairing your ability to use the Service.
• Functional Cookies: These cookies remember your preferences and personalisation settings across sessions — for example, your preferred game lobby view or recently played games. They improve the convenience of your wintime experience but are not strictly required for basic functionality.
• Analytics Cookies: wintime uses aggregated, anonymised analytics data to understand how players use the platform — which pages are visited most, where players encounter difficulties, and how load times perform on Philippine mobile connections. This data informs product improvements. Analytics data is not linked to individual identifiable users.
• Security Cookies: Short-lived cookies used to support wintime's fraud detection and account security systems, including device recognition for two-factor authentication and unusual login location detection.

You may control cookie preferences through your browser settings. However, disabling strictly necessary cookies will significantly impair or prevent use of the wintime platform. wintime does not use third-party advertising cookies or cross-site tracking cookies.

08 Data Retention

wintime retains personal data only for as long as necessary for the purposes for which it was collected, subject to mandatory minimum retention periods imposed by applicable Philippine law:

• Active Account Data: Personal data associated with an active wintime account is retained for the lifetime of the account and for a minimum period of five (5) years following account closure, as required by PAGCOR and AMLC record-keeping requirements.
• KYC and Identity Documents: Identity verification documents are retained for a minimum of five (5) years from the date of account closure or from the date of the last transaction, whichever is later, in accordance with AMLA record-keeping obligations.
• Financial Transaction Records: Records of all deposits, withdrawals, and wagers are retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLC and PAGCOR requirements.
• Customer Support Communications: Support correspondence is retained for three (3) years from the date of each interaction for dispute resolution and quality assurance purposes.
• Marketing Data: Data used solely for marketing communications (e.g., promotional email lists) is retained until you withdraw consent or unsubscribe. Upon unsubscription, your details are removed from active marketing lists within 10 business days.

At the end of the applicable retention period, personal data is securely deleted or anonymised in accordance with wintime's data destruction procedures.

09 Data Security

wintime implements comprehensive technical and organisational security measures to protect the personal data of all players against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and the wintime platform is encrypted using 256-bit SSL/TLS encryption. This applies to login sessions, game play sessions, and all payment processing flows.
• Password Security: Player passwords are stored using industry-standard one-way cryptographic hashing. wintime does not store passwords in readable form and cannot retrieve your password — only reset it.
• Access Controls: Access to player personal data within wintime's internal systems is restricted on a need-to-know basis. Staff members with access to player data are subject to contractual confidentiality obligations and undergo regular security training.
• Intrusion Detection: wintime's infrastructure is monitored 24/7 for suspicious access patterns, unauthorised data access attempts, and other security anomalies.
• Data Breach Response: wintime maintains an incident response plan in accordance with the National Privacy Commission's breach notification requirements under RA 10173. In the event of a data breach that poses a real risk to affected players, wintime will notify the NPC and affected players within the timeframes required by law.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012, Philippine players have the following rights in relation to their personal data held by wintime:

To exercise any of the above rights, please contact the wintime Data Protection Officer using the contact details in Section 14. wintime will respond to data subject requests within thirty (30) calendar days of receipt, as required by the DPA's Implementing Rules and Regulations. Identity verification will be required before any request can be processed.

11 Children's Privacy

The wintime platform is strictly restricted to individuals who are 21 years of age or older, in accordance with PAGCOR requirements governing real-money online gaming in the Philippines. wintime does not knowingly collect personal data from individuals under 21 years of age.

If wintime discovers or is notified that personal data has been collected from a user who is under 21 years of age, wintime will: (a) immediately suspend the relevant account; (b) delete all personal data associated with the account to the extent not required to be retained for regulatory compliance purposes; and (c) report the matter to PAGCOR in accordance with wintime's regulatory obligations.

If you are a parent or guardian and believe that your child under 21 years has created a wintime account, please contact wintime support immediately using the contact details in Section 14 of this Policy.

12 Cross-Border Data Transfers

In the course of operating the wintime Service, personal data may be transferred to and processed in jurisdictions outside the Republic of the Philippines — for example, where game content providers, payment processors, or technical infrastructure providers operate their servers in other countries.

Where such transfers occur, wintime ensures that appropriate safeguards are in place in accordance with the requirements of the Data Privacy Act of 2012, including contractual provisions that require recipient organisations to maintain data protection standards equivalent to those applicable in the Philippines. wintime will not transfer personal data to jurisdictions that do not provide an adequate level of data protection unless appropriate contractual protections are in place.

13 Changes to This Privacy Policy

wintime reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or the scope of the wintime Service. The most current version of this Policy is always available at wintime.lat/privacy-policy, with the effective date indicated at the top of the document.

When material changes are made to this Policy, wintime will notify registered players via their registered contact details and/or through a prominent notice on the wintime platform. Changes will take effect fourteen (14) calendar days after notification unless the change is required immediately by law or regulatory directive, in which case it takes effect upon publication.

Your continued use of the wintime platform after the effective date of any updated Policy constitutes your acknowledgment and acceptance of the revised terms. If you do not accept any material change to this Policy, you may request account closure and the return of any remaining balance in your account.

14 Contact the wintime Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by wintime, please contact the wintime Data Protection Officer through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, inside your wintime account dashboard. This is the fastest channel for privacy-related questions — typical first response under 5 minutes during Philippine daytime hours.
• Email: [email protected] — include "Privacy Request" in the subject line for routing to the Data Protection Officer. Responses are provided within 24 hours for standard inquiries and within 30 calendar days for formal data subject requests.

For complaints that cannot be resolved directly with wintime, you may escalate your complaint to the National Privacy Commission (NPC) of the Philippines through the NPC's official channels. wintime cooperates fully with NPC investigations and will provide all information requested by the NPC in connection with any lawful inquiry.