Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how perawin ("we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of users ("you" or "your") who access or use the perawin online gaming platform, including the perawin website and any associated mobile applications (collectively, the "Platform").

perawin is committed to protecting your privacy and handling your personal data responsibly. We process personal information in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines.

By registering an account on perawin or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you should not use the Platform.

This Policy should be read together with perawin's Terms & Conditions, which govern your use of the Platform generally.

2. Data Controller

For the purposes of the Philippine Data Privacy Act, perawin acts as the personal information controller in respect of the personal data it collects from users of the Platform. As the personal information controller, perawin determines the purposes and means of processing your personal data.

perawin has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with the DPA and this Policy. Contact details for the DPO are provided in Section 13 of this Policy.

3. Personal Data We Collect

perawin collects personal data from you in the following categories, depending on how you interact with the Platform:

3.1 Registration and Identity Data

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Residential address (including barangay, city/municipality, province)
• Philippine mobile number
• Email address
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine passport, driver's license, PhilSys national ID, SSS/GSIS ID, PRC ID, voter's ID)
• Proof of address documents
• Selfie or liveness verification image (where required)
• Tax Identification Number (TIN), where applicable under Philippine regulations

3.3 Financial and Transaction Data

• GCash or PayMaya/Maya account details (mobile number associated with the e-wallet)
• Bank account details for bank transfer transactions (account name, account number, bank name)
• Debit card details (card number is not stored in full; only masked card details are retained)
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment methods

3.4 Gaming Activity Data

• Game history, including games played, bets placed, outcomes, and winnings
• Session duration and frequency of play
• Bonus and promotion usage history
• Responsible gaming tool usage (deposit limits set, self-exclusion requests)

3.5 Technical and Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type
• Cookie identifiers and session tokens
• Platform access logs and timestamps

3.6 Communications Data

• Customer support chat transcripts and email correspondence
• Feedback and survey responses
• Marketing communication preferences

4. How We Use Your Personal Data

perawin uses the personal data it collects for the following purposes:

perawin will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, perawin processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform our contract with you — i.e., to provide you with access to the perawin Platform and its gaming services, process your transactions, and manage your account.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including the Anti-Money Laundering Act (AMLA), the Data Privacy Act, PAGCOR regulations, and other applicable gaming regulations.
• Legitimate interests: Processing is necessary for perawin's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and improving our services, provided these interests are not overridden by your rights and interests.
• Consent: For marketing communications and certain non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Data Sharing and Disclosure

perawin does not sell your personal data to third parties. 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/Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals. These providers process your data under their own privacy policies and applicable Philippine financial regulations.
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with Philippine anti-money laundering obligations.
• Game content providers: Licensed game studios and live dealer operators whose games are available on the perawin Platform. These providers may receive limited technical data necessary to deliver game content.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers who process data on perawin's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law, court order, or regulatory requirement.
• Professional advisers: Legal counsel, auditors, and accountants, where necessary for the conduct of perawin's business and subject to professional confidentiality obligations.

Any third party that processes personal data on perawin's behalf is required to do so only in accordance with perawin's instructions and applicable Philippine data protection law.

7. Data Retention

perawin retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

The following general retention periods apply:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AMLA requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• Gaming activity data: Retained for the duration of your account and for up to three (3) years following account closure.
• Customer support communications: Retained for up to two (2) years from the date of the communication.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.
• Technical and log data: Retained for up to twelve (12) months from the date of collection.

When personal data is no longer required, perawin will securely delete or anonymize it in accordance with our data disposal procedures.

8. Cookies and Tracking Technologies

perawin uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device that help us recognize you, remember your preferences, and improve your experience on the Platform.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. These cookies cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and display options, to personalize your experience.
• Analytics cookies: Help us understand how users interact with the Platform — which pages are visited most, how long sessions last, and where users encounter difficulties. This data is aggregated and anonymized.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. For detailed information on managing cookies in your browser, refer to your browser's help documentation.

9. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by perawin:

• Right to be informed: You have the right to be informed about how your personal data is being collected and processed. This Policy fulfills that obligation.
• Right of access: You have the right to request a copy of the personal data perawin holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update basic account information directly through your account settings.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to perawin's legal retention obligations under Philippine law.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests, subject to perawin's overriding legitimate grounds.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that perawin has violated your data privacy rights. The NPC can be reached through its official channels.

To exercise any of your privacy rights, please contact perawin's Data Protection Officer using the contact details provided in Section 13. We will respond to all verified requests within fifteen (15) days, as required under the DPA. In complex cases, we may extend this period by a further fifteen (15) days, with prior notice to you.

Please note that certain rights are subject to limitations under Philippine law. For example, we may be unable to delete data that we are legally required to retain for AML or regulatory compliance purposes.

10. Data Security

perawin implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: Personal and financial data is encrypted in transit using TLS (Transport Layer Security) and at rest using industry-standard encryption protocols.
• Access controls: Access to personal data is restricted to authorized perawin personnel and service providers on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-factor authentication: perawin supports two-factor authentication (2FA) for member accounts to provide an additional layer of security against unauthorized access.
• Regular security assessments: perawin conducts periodic security audits and vulnerability assessments to identify and address potential weaknesses in our systems.
• Incident response: perawin maintains a data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the NPC and affected individuals in accordance with the DPA's breach notification requirements.

While perawin takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the security of your account credentials and for notifying us immediately if you suspect any unauthorized access to your account.

11. Children's Privacy

The perawin Platform is strictly intended for users who are 21 years of age or older, in accordance with Philippine gambling regulations. perawin does not knowingly collect personal data from individuals under the age of 21.

If perawin becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any deposits made by an underage user will be returned to the payment source used, subject to verification.

If you are a parent or guardian and believe that your child has registered on the perawin Platform, please contact our support team immediately so that we can take appropriate action.

12. Changes to This Privacy Policy

perawin reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

When we make material changes to this Policy, we will notify registered members via email or through a prominent notice on the Platform prior to the changes taking effect. We encourage you to review this Policy periodically to stay informed about how perawin protects your personal data.

Your continued use of the Platform following the posting of any changes to this Policy constitutes your acceptance of the revised Policy. If you do not agree with the changes, you should cease using the Platform and may request closure of your account.

13. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or perawin's handling of your personal data, please contact our Data Protection Officer:

• Data Protection Officer: perawin DPO
• Email: [email protected]
• General Support: [email protected]
• Support Hours: 24 hours a day, 7 days a week
• Language: English and Filipino

If you are not satisfied with perawin's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

This Privacy Policy was last reviewed and updated in May 2026. Previous versions are available upon request by contacting our Data Protection Officer.