phlwen Privacy Policy — Your Data, Our Responsibility

01Introduction

phlwen takes your privacy seriously. This Privacy Policy explains how phlwen collects, uses, stores, and protects the personal information of its players — primarily Filipino users accessing the platform through phlwen.net. It is written to be as straightforward as possible, because you deserve to understand exactly what happens with your data when you use phlwen.

This policy applies to all personal data processed by phlwen in connection with your registration, use of the platform, deposits and withdrawals, participation in promotions, customer support interactions, and any other activity associated with your phlwen account.

This Privacy Policy should be read alongside the phlwen Terms and Conditions, which together form the full agreement governing your relationship with phlwen. In cases where this policy and the Terms overlap on data-related matters, this Privacy Policy governs.

phlwen complies with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, along with its Implementing Rules and Regulations. We take our obligations under Philippine data protection law seriously — not merely as a compliance requirement, but as a genuine commitment to the players who trust phlwen with their information.

02Data Controller

For the purposes of applicable data protection laws, phlwen is the data controller responsible for the personal data you provide when using phlwen.net. As data controller, phlwen determines the purposes for which your personal data is processed and the means by which that processing takes place.

If you have questions about how phlwen processes your personal data, or wish to exercise any of your data rights, you can reach our Data Privacy team at:

03What Personal Data We Collect

phlwen collects personal data in two main ways — information you provide directly, and information generated automatically by your use of the platform. Here is a detailed breakdown:

04How We Collect Your Data

phlwen collects personal data through several channels depending on how you interact with the platform:

• Direct interactions: When you register your phlwen account, complete your KYC verification, make a deposit or withdrawal, contact customer support, respond to a survey, or participate in a promotion.
• Automated collection: When you browse phlwen.net, our platform automatically collects technical data including your IP address, device identifiers, browser type, and session activity through server logs and analytics tools.
• Cookies and similar technologies: phlwen uses cookies and related tracking technologies on phlwen.net to maintain session state, remember your preferences, analyse traffic, and where you have consented, to serve relevant promotional content. See Section10 of this policy for full details on cookies.
• Third-party payment providers: When you deposit or withdraw via GCash, Maya, or other Philippine payment providers, those providers may share transaction reference information with phlwen necessary to confirm and process your payment. phlwen does not receive your full payment account credentials.
• Identity verification services: During KYC, phlwen may use third-party identity verification services to confirm the authenticity of documents you submit. These services process identity data on phlwen's behalf and are contractually bound to use it only for that purpose.
• Referal programme: If another phlwen player refers you using the Refer a Friend programme, phlwen receives basic referral tracking information when you register using their link. No detailed personal data about you is shared with the referring player.

05Why We Use Your Personal Data

phlwen uses your personal data only for clearly defined and legitimate purposes. We do not use your data in ways that are incompatible with the purposes for which it was collected. The main purposes for which phlwen processes personal data are:

• Account creation and management: To open your phlwen account, verify your identity, maintain your account records, and manage your relationship with phlwen over time.
• Processing transactions: To facilitate your deposits and withdrawals in Philippine Peso via GCash, Maya, and other supported payment methods, and to maintain accurate financial records for your account.
• Platform operation and personalisation: To provide you with a functioning, responsive, and personalised experience on phlwen — including displaying relevant sports markets, remembering your preferences, and keeping your bet history accessible.
• Legal and regulatory compliance: To meet phlwen's obligations under applicable Philippine law, including Know Your Customer (KYC) requirements, anti-money laundering (AML) obligations, and responsible gaming requirements under our operating licence.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorised access, and other security incidents affecting your phlwen account or the platform as a whole.
• Responsible gaming: To monitor your account activity for indicators of problem gambling behaviour and to apply responsible gaming tools where necessary — including deposit limits, cooling-off periods, and self-exclusion.
• Customer support: To respond to your enquiries, resolve disputes, and improve the support experience for all phlwen players.
• Marketing communications (with consent): To send you information about phlwen promotions, bonuses, and new features where you have opted in to receive such communications. You can withdraw your marketing consent at any time.
• Analytics and platform improvement: To analyse how players use phlwen — which features are most popular, where technical issues occur, and how the user experience can be improved — using aggregated, anonymised data where possible.

06Legal Basis for Processing

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

• Performance of a contract: Most processing related to operating your phlwen account — including registration, transaction processing, and bet management — is necessary for the performance of the contract between you and phlwen.
• Compliance with a legal obligation: Processing required by Philippine law, including KYC verification, AML reporting, and responsible gaming monitoring.
• Legitimate interests: Processing for fraud prevention, platform security, and the improvement of phlwen's services, where those interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given clear, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

07Who We Share Your Data With

phlwen does not sell your personal data to any third party. We share data only where necessary and with appropriate safeguards in place. The categories of third parties with whom phlwen may share your personal data include:

• Payment processors: GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, and other Philippine payment providers — to process your deposits and withdrawals. These providers process your transaction data as independent data controllers and have their own privacy policies.
• Identity verification providers: Third-party KYC services used to verify your identity documents. These providers act as data processors on phlwen's behalf, under data processing agreements that restrict use of your data to verification purposes only.
• Gaming software providers: Wherehlwen's slot and casino products are powered by licensed third-party providers, limited technical data (not your personal identity details) may be shared with those providers to deliver the game experience.
• Analytics and IT service providers: Companies that help phlwen operate, maintain, and improve the platform on a contracted, data-processor basis.
• Regulatory and law enforcement authorities: Where phlwen is required by law, court order, or regulatory direction to disclose your personal data — including to the relevant Philippine gaming authority or the Anti-Money Laundering Council (AMLC).
• Fraud prevention services: Shared data used to detect and prevent fraudulent activity, unauthorised access, or other security threats affecting phlwen or its players.

08How Long We Keep Your Data

phlwen retains your personal data only for as long as is necessary for the purposes described in this policy, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active phlwen account plus a minimum of five years following account closure, in line with AML and regulatory requirements.
• Transaction and financial data: Retained for a minimum of five years from the date of the transaction, as required by Philippine financial and anti-money laundering regulations.
• Betting and gaming history: Retained for a minimum of three years to support dispute resolution and regulatory compliance.
• Customer support communications: Retained for two years from the date of the last communication, to support ongoing service improvement and dispute resolution.
• Technical and usage data: Typically retained for 13 months in identifiable form before being anonymised or deleted.
• Marketing preferences: Retained until you withdraw your consent or for two years of account inactivity, whichever comes first.

After the applicable retention period, personal data is either securely deleted or irreversibly anonymised so that it can no longer be associated with you as an individual.

09How We Protect Your Data

phlwen implements a range of technical and organisational security measures designed to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and phlwen's servers
• Encryption at rest for sensitive data stored in phlwen's databases
• Role-based access controls that limit internal access to personal data to only those employees and contractors who need it to perform their duties
• Regular security assessments and penetration testing of phlwen's platform infrastructure
• Two-factor authentication options for player accounts to reduce the risk of unauthorised access
• Monitoring systems that flag unusual account activity indicative of fraud or unauthorised access
• Staff training on data protection responsibilities and security best practices

10Cookies & Tracking Technologies

phlwen uses cookies and similar tracking technologies on phlwen.net. Cookies are small text files placed on your device by your browser when you visit the platform. They help phlwen function correctly, remember your preferences, and understand how the platform is being used.

The types of cookies used on phlwen include:

• Essential cookies: Required for the basic functioning of phlwen — including maintaining your logged-in session and remembering items in your account. These cannot be disabled without breaking core platform features.
• Functional cookies: Remember your preferences — such as language settings and display options — to personalise your phlwen experience. Disabling these may reduce personalisation but won't prevent you from using the platform.
• Analytics cookies: Help phlwen understand how players navigate the platform — which pages are visited most, where users encounter issues, and how features are used. This data is aggregated and used to improve the platform.
• Marketing cookies (with consent only): Used to deliver relevant promotional content to you based on your phlwen usage patterns. These are only activated where you have given explicit consent.

You can manage your cookie preferences through your browser settings. Most modern browsers allow you to view, delete, and block cookies. Note that blocking certain cookies may affect the functionality of phlwen. For more detailed guidance, refer to the help section of your specific browser.

11Your Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, Filipino data subjects have the following rights in relation to their personal data held by phlwen:

To exercise any of the above rights, contact phlwen's Data Privacy team at privacy@phlwen.net with subject line "Data Rights Request". phlwen will respond within 15 business days of receiving a verifiable request. We may require identity verification before actioning certain requests to protect your data from unauthorised disclosure.

If you believe phlwen has not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).

12Minors

phlwen's platform is strictly for adults aged 21 years and above. phlwen does not knowingly collect or process personal data from anyone under the age of 21. Age verification is a mandatory part of the phlwen registration and KYC process.

If phlwen discovers that an account has been registered by someone under 21, the account will be immediately closed, all transactions will be voided, and any deposited funds will be returned to the originating payment method following verification. If you have reason to believe a minor has registered a phlwen account, please contact us at support@phlwen.net as soon as possible.

13Changes to This Privacy Policy

phlwen may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or platform features. The "Last Updated" date at the top of this page will always reflect the current version.

Where changes are material — meaning they significantly affect how we use your personal data or your rights as a data subject — phlwen will notify active players via email to their registered address, or via a notice displayed on the platform at login. For non-material changes, the updated policy will be published on this page without direct notification.

We recommend reviewing this Privacy Policy periodically. Your continued use of phlwen after a revised policy takes effect constitutes your acknowledgement of the updated content. If you object to any change, please contact us before the effective date or discontinue use of the platform.

14Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or how phlwen handles your personal data, please reach out through one of the following channels:

For related policies, please also see the phlwen Terms and Conditions and the Responsible Gaming Policy.