Privacy Policy

1 Who We Are

pupwin ("pupwin", "we", "us", "our") operates the online gaming platform accessible at pupwin.app, offering casino games, slots, bingo, live dealer games, and related entertainment services to players in the Philippines and other permitted jurisdictions.

For the purposes of this Privacy Policy, pupwin is the data controller responsible for the personal information you provide when registering an account, making transactions, or otherwise interacting with our platform. This Policy applies to all pupwin services, including our website, mobile-optimised platform, and any communications we send to you.

This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy.

2 Personal Data We Collect

pupwin collects the following categories of personal data from players:

Identity & Contact Data:

• Full legal name, date of birth, and nationality
• Government-issued identification number (e.g., Philippine National ID, passport, driver's licence)
• Residential address (including barangay, city, province)
• Email address and Philippine mobile number

Financial Data:

• GCash or PayMaya account details (mobile number linked to wallet)
• BPI, BDO, or Metrobank account details where applicable
• Transaction history, deposit amounts, withdrawal requests, and account balances

Technical & Usage Data:

• IP address, device type, browser type, and operating system
• Login timestamps, session duration, and pages visited
• Game history, wagering patterns, and bonus usage

Communications Data:

• Records of your correspondence with pupwin customer support
• Responses to surveys, promotions, or feedback requests

3 How We Collect Your Data

pupwin collects personal data through the following means:

• Direct collection: Information you provide when registering your pupwin account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the pupwin platform, including via cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering (AML) screening services; payment confirmation data from GCash, PayMaya, and banking partners.

4 How We Use Your Personal Data

pupwin uses your personal data for the following purposes:

• Account management: To register, verify, maintain, and administer your pupwin account.
• Service delivery: To process deposits and withdrawals, provide access to games, and deliver customer support.
• Legal compliance: To fulfil our obligations under applicable anti-money laundering (AML), know-your-customer (KYC), and responsible gaming regulations.
• Fraud prevention: To detect, investigate, and prevent fraudulent transactions, account abuse, and other prohibited conduct.
• Responsible gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, and to apply responsible gaming tools where appropriate.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided consent or where we have a legitimate interest to do so. You may opt out at any time.
• Platform improvement: To analyse usage patterns and improve the pupwin platform, game selection, and user experience.

5 Legal Basis for Processing

pupwin processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you (i.e., to operate your pupwin account and deliver gaming services).
• Legal obligation: Processing required to comply with applicable laws, including AML, KYC, and responsible gaming regulations.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing for direct marketing communications, where you have given explicit consent. You may withdraw consent at any time by contacting us or using the unsubscribe option in our communications.

6 Sharing Your Personal Data

pupwin may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to process your financial transactions.
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory requirements.
• Game software providers: Licensed game developers whose titles are available on the pupwin platform, to the extent necessary to deliver game services.
• Regulatory authorities: Government agencies and regulators, including those overseeing gaming operations in the Philippines, where disclosure is required by law.
• Professional advisers: Legal, accounting, and auditing firms engaged by pupwin, subject to confidentiality obligations.

All third parties with whom pupwin shares personal data are required to handle that data in accordance with applicable data protection laws and our data processing agreements.

7 Data Retention

pupwin retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. In general:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with AML and financial record-keeping requirements.
• KYC verification documents are retained for the period required by applicable regulations.
• Marketing consent records are retained until you withdraw consent and for a reasonable period thereafter as evidence of compliance.
• Technical and usage logs are retained for up to twelve (12) months for security and fraud prevention purposes.

When personal data is no longer required for the purposes for which it was collected, pupwin will securely delete or anonymise it.

8 Cookies & Tracking Technologies

The pupwin platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and analyse platform usage. The types of cookies we use include:

• Essential cookies: Required for the platform to function correctly, including session management and security features. These cannot be disabled.
• Analytics cookies: Used to understand how players interact with the pupwin platform, helping us improve navigation, game discovery, and overall usability.
• Preference cookies: Used to remember your settings and preferences, such as language and display options.

You can manage your cookie preferences through your browser settings. Please note that disabling non-essential cookies may affect the functionality of certain pupwin features.

9 Data Security

pupwin implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the pupwin platform
• Encrypted storage of sensitive account and financial data
• Multi-factor authentication options for account access
• Regular security audits and vulnerability assessments
• Strict access controls limiting employee access to personal data on a need-to-know basis

10 Your Data Rights

As a pupwin player, you have the following rights with respect to your personal data, subject to applicable law:

• Right of access: You may request a copy of the personal data pupwin holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to restriction: You may request that we restrict processing of your data in certain circumstances.
• Right to data portability: You may request a copy of your data in a structured, machine-readable format.
• Right to object: You may object to processing based on legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us using the details in Section 13. We will respond to all verified requests within thirty (30) days.

11 Children's Privacy

The pupwin platform is strictly intended for adults aged 21 years and above, consistent with Philippine regulations applicable to casino-style gaming. pupwin does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under the minimum age, we will immediately suspend the relevant account, forfeit any associated balances, and delete the personal data in question. If you believe a minor has registered on pupwin, please contact us immediately.

12 Changes to This Privacy Policy

pupwin reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via their registered email address or mobile number, or by displaying a prominent notice on the pupwin platform.

The updated Privacy Policy will take effect on the date specified in the notice. Your continued use of the pupwin platform following that date constitutes your acceptance of the revised Policy.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by pupwin, please contact our Data Privacy team:

• Email: [email protected]
• Live Chat: Available 24/7 via the pupwin platform after login
• Response Time: We aim to respond to all data privacy requests within 30 days

For responsible gaming support, self-exclusion requests, or deposit limit tools, please visit our Responsible Gaming page.