winhub Privacy Policy

1Introduction

This Privacy Policy describes how winhub (the "Company," "we," "us," or "our"), a PAGCOR-licensed online casino and sports betting platform, collects, uses, discloses, stores, and protects the personal data of individuals ("you," "player," or "user") who access or use the winhub platform accessible at winhub.cam.

By creating an account on winhub, accessing the platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree with this Privacy Policy, you must not use the winhub platform.

This Privacy Policy should be read in conjunction with the winhub Terms and Conditions, which govern your use of the platform.

2Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, winhub is the data controller responsible for the personal data you provide when using the platform. winhub determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is conducted in compliance with applicable Philippine data protection law.

winhub operates under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the data handling and reporting requirements imposed by PAGCOR as well as the Anti-Money Laundering Council (AMLC) of the Philippines.

3Personal Data We Collect

winhub collects personal data in order to provide gaming services, comply with legal and regulatory obligations, and maintain a secure and fair gaming environment. The categories of personal data we collect include:

3.1 Registration and Account Data

When you create a winhub account, we collect:

• Full legal name (as it appears on your government-issued ID)
• Date of birth
• Philippine mobile phone number
• Email address
• Residential address (for KYC verification purposes)
• Username and password (password is stored in hashed form only)
• Security questions and answers (if enabled)

3.2 Identity Verification (KYC) Data

In compliance with PAGCOR regulations and the Anti-Money Laundering Act, winhub is required to verify the identity of all players. KYC data includes:

• Copies of government-issued identification documents (PhilSys ID, UMID, driver's license, passport, or other valid Philippine ID)
• Proof of address documents (utility bills, bank statements, government correspondence)
• Selfie photographs submitted for identity verification
• Data extracted from ID documents including ID number, issuing authority, and expiration date

3.3 Payment and Financial Data

To process deposits and withdrawals, winhub collects:

• GCash, Maya, or Coins.ph mobile wallet numbers and account holder names
• Bank account numbers and bank names (BPI, BDO, UnionBank, etc.) for bank transfer transactions
• USDT cryptocurrency wallet addresses (TRC20 network)
• Transaction history including deposit amounts, withdrawal amounts, timestamps, and payment method used
• Source of funds documentation where required for large transactions or in response to AML investigation

3.4 Gameplay and Usage Data

winhub automatically collects data about how you use the platform, including:

• Games played, including game titles, bet amounts, win/loss outcomes, and game session durations
• Account balance changes and wagering activity
• Bonuses claimed, wagering progress, and bonus terms compliance
• Sports bets placed, including selections, odds, stake amounts, and outcomes
• Customer support interactions, including live chat transcripts and email correspondence

3.5 Technical and Device Data

When you access winhub, we automatically collect technical information, including:

• IP address and geolocation data
• Device type, operating system, browser type and version
• Device identifiers (e.g., mobile device ID, advertising ID)
• Referring URL and clickstream data showing your path through the platform
• Login timestamps and session duration
• Cookies and similar tracking technologies (see Section 10 below)

4How We Use Your Personal Data

winhub processes your personal data for the following purposes:

4.1 Provision of Gaming Services

• To create and manage your winhub account
• To enable you to play casino games, place sports bets, and participate in other gaming activities
• To process deposits and withdrawals through your chosen payment methods
• To calculate and credit winnings, bonuses, and promotional rewards
• To provide customer support and respond to your inquiries

4.2 Legal and Regulatory Compliance

• To verify your identity and age in compliance with PAGCOR licensing conditions (players must be 21 years or older)
• To comply with anti-money laundering (AML) obligations under Republic Act No. 9160 and related regulations
• To detect, prevent, and investigate fraud, collusion, bonus abuse, and other prohibited conduct
• To respond to lawful requests from PAGCOR, the AMLC, law enforcement agencies, or courts of law
• To maintain records as required by Philippine gaming and financial regulations

4.3 Platform Security and Integrity

• To monitor account activity and detect unusual or suspicious behavior
• To enforce the winhub Terms and Conditions and prevent multiple account creation
• To protect against unauthorized access, cyberattacks, and other security threats
• To maintain audit logs for security incident investigation

4.4 Marketing and Communication

• To send you promotional offers, bonuses, and news about winhub services (you may opt out at any time)
• To send transactional communications such as deposit confirmations, withdrawal notifications, and account security alerts
• To conduct player satisfaction surveys and request feedback on our services

4.5 Analytics and Service Improvement

• To analyze usage patterns and preferences in order to improve the platform's functionality and user experience
• To develop new features, games, and promotional offers based on player behavior
• To conduct responsible gaming analysis and identify players who may benefit from responsible gaming tools

5Legal Basis for Processing

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

• Consent: By registering on winhub and accepting this Privacy Policy, you provide explicit consent for the processing of your personal data as described herein.
• Contractual Necessity: Processing is necessary to perform the contract between you and winhub (the Terms and Conditions), including providing gaming services and processing financial transactions.
• Legal Obligation: Processing is required to comply with Philippine laws and regulations, including PAGCOR licensing conditions, AML obligations, and data retention requirements.
• Legitimate Interests: Processing is necessary for the legitimate interests of winhub, including fraud prevention, platform security, responsible gaming monitoring, and improving our services, provided that such interests are not overridden by your fundamental rights and freedoms.

6Data Sharing & Disclosure

winhub does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only where necessary and lawful:

6.1 Regulatory and Law Enforcement Authorities

winhub is required by Philippine law to disclose player information to:

• The Philippine Amusement and Gaming Corporation (PAGCOR) in connection with licensing audits, compliance reviews, and investigations.
• The Anti-Money Laundering Council (AMLC) where transactions meet mandatory reporting thresholds or are flagged as suspicious under Republic Act No. 9160.
• Philippine law enforcement agencies, courts, and other government bodies in response to lawful orders, warrants, or legal process.

6.2 Service Providers and Technology Partners

winhub engages third-party service providers who process data on our behalf under strict contractual data protection obligations. These include:

• Identity verification (KYC) service providers
• Payment processors and e-wallet partners (GCash, Maya, BPI, BDO, UnionBank, Coins.ph)
• Game software providers (including JILI and other licensed game studios)
• Cloud hosting and infrastructure providers
• Fraud detection and cybersecurity service providers
• Customer support platform providers

All third-party service providers are contractually required to process personal data only on winhub's instructions and in accordance with applicable data protection law.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of winhub's business, your personal data may be transferred as part of that transaction. You will be notified of any such transfer and any material changes to how your data is processed.

7International Data Transfers

Some of winhub's third-party service providers — including cloud infrastructure providers and game software vendors — may process data on servers located outside the Philippines. Where personal data is transferred outside the Philippines, winhub ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required by the Philippine Data Privacy Act.

Such safeguards may include contractual clauses approved by the National Privacy Commission, binding corporate rules, adequacy determinations, or other legally recognized transfer mechanisms. By using the winhub platform, you consent to your personal data being processed in jurisdictions outside the Philippines where such transfers are necessary to deliver our services.

8Data Security

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

• Encryption: All data transmitted between your device and the winhub platform is encrypted using industry-standard 256-bit SSL/TLS protocols. Sensitive data at rest, including financial information and identity documents, is encrypted in storage.
• Access Controls: Access to personal data within winhub's systems is restricted on a strict need-to-know basis. All staff with access to personal data undergo background checks and regular data protection training.
• Two-Factor Authentication: winhub offers two-factor authentication (2FA) for player account logins as an additional layer of account security.
• Intrusion Detection: winhub's infrastructure is protected by automated intrusion detection systems that monitor for unauthorized access attempts and anomalous activity in real time.
• Penetration Testing: winhub engages independent security professionals to conduct regular penetration testing and security audits of the platform.
• Incident Response: winhub maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, winhub will notify you and the National Privacy Commission in accordance with the timelines required by Philippine data protection law.

While winhub takes all reasonable precautions to protect your data, no internet-based service can guarantee absolute security. You are responsible for maintaining the confidentiality of your account password and for notifying winhub immediately if you suspect unauthorized access to your account.

9Data Retention

winhub retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. 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, as required by PAGCOR regulations and Philippine AML law.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction in compliance with Philippine AML and gaming regulatory requirements.
• Gameplay Data: Game history and wagering records are retained for a minimum of two (2) years from the date of activity, or longer where required by regulatory obligation.
• Communication Records: Customer support interactions and correspondence are retained for two (2) years from the date of the last interaction.
• Marketing Data: If you opt out of marketing communications, your opt-out preference is recorded and retained indefinitely to ensure we do not contact you contrary to your stated preference.

At the end of the applicable retention period, personal data will be securely deleted, anonymized, or pseudonymized, subject to any overriding legal obligation to retain the data for a longer period.

10Cookies & Tracking Technologies

winhub uses cookies and similar tracking technologies to operate the platform, analyze usage, personalize content, and measure the effectiveness of our marketing activities. The categories of cookies we use are:

• Strictly Necessary Cookies: These cookies are essential for the platform to function correctly and cannot be disabled. They include session management cookies that keep you logged in during your gameplay session.
• Analytics Cookies: These cookies collect anonymized data about how players interact with the winhub platform, enabling us to improve functionality and user experience. Data collected is aggregated and does not identify individual players.
• Functional Cookies: These cookies remember your preferences — such as your preferred language and display settings — to provide a more personalized experience.
• Marketing Cookies: Where you have provided consent, these cookies are used to deliver relevant promotional content and measure the effectiveness of our advertising campaigns.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the winhub platform. Strictly necessary cookies cannot be disabled without impacting your ability to use the service.

11Exercising Your Data Rights

Under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by winhub:

• Right to Access: Request a copy of the personal data winhub holds about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations.
• Right to Object: Object to the processing of your personal data for marketing purposes or other processing based on legitimate interests.
• Right to Data Portability: Receive your personal data in a structured, commonly used format.
• Right to Lodge a Complaint: File a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact the winhub Data Privacy Officer by emailing [email protected] with the subject line "Data Privacy Request". Please include your registered account email address and a description of your request. winhub will acknowledge your request within 72 hours and provide a substantive response within fifteen (15) business days, as required by Philippine data protection law.

12Children's Privacy

The winhub platform is strictly intended for adults. Under Philippine law and PAGCOR regulations, players must be at least 21 years of age to register and participate in real-money gaming. winhub does not knowingly collect or process personal data from individuals under the age of 21.

Age verification is conducted as part of the KYC process for all registered players. Where winhub discovers that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, all associated data will be handled in accordance with legal requirements, and the matter may be referred to PAGCOR and relevant Philippine authorities.

Parents or guardians who believe that a minor may have registered on or accessed the winhub platform are encouraged to contact the support team immediately at [email protected].

13Policy Updates

winhub may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or platform functionality. Where material changes are made, winhub will notify registered players via email or prominent platform notification prior to the changes taking effect.

The effective date at the top of this Privacy Policy indicates when the current version was last reviewed and updated. Continued use of the winhub platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.

We recommend that you review this Privacy Policy periodically. The most current version is always available at winhub.cam/privacy-policy.

14Contact the Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way winhub handles your personal data, please contact our Data Privacy Officer using the following details:

• Email: [email protected]
• Subject Line: Data Privacy Inquiry
• Support Hours: 24 hours a day, 7 days a week

If you are not satisfied with winhub's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines, the independent government body responsible for administering and enforcing the Data Privacy Act of 2012.

For general account support, bonus inquiries, or responsible gaming assistance, you may also visit the winhub FAQ page or reach out to the support team via live chat when logged in to your account.