Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") applies to all personal data collected and processed by 226phwin in connection with your use of the 226phwin website at https://226phwin.net, the 226phwin mobile application, and any related services, features, or communications (collectively, the "Platform").

226phwin is committed to protecting the personal data of all players and visitors in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. By accessing or using the 226phwin 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.

This Policy should be read together with the 226phwin Terms & Conditions, which govern your overall use of the Platform. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, 226phwin acts as the Personal Information Controller in respect of all personal data collected through the Platform. This means 226phwin determines the purposes and means by which your personal data is processed.

If you have any questions about how 226phwin handles your personal data, or if you wish to exercise any of your data rights described in Section 11 of this Policy, you may contact our Data Protection Officer using the contact details provided in Section 14.

3. Information We Collect

226phwin collects personal data that is necessary to provide you with a safe, compliant, and functional gaming experience. The categories of personal data we collect include:

226phwin does not collect sensitive personal information — such as racial or ethnic origin, political opinions, religious beliefs, or health data — unless it is strictly necessary for compliance with applicable law (for example, in connection with responsible gaming assessments) and only with your explicit consent where required.

4. How We Collect Your Information

226phwin collects personal data through the following means:

• Direct interactions: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs (see Section 10 for details);
• Third-party sources: Identity verification data from KYC service providers; payment confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank; fraud detection signals from security partners. All third-party data sources used by 226phwin are contractually bound to handle data in compliance with applicable privacy laws.

5. How We Use Your Information

226phwin uses the personal data we collect for the following purposes:

• To create, verify, and manage your 226phwin player account;
• To process deposits, withdrawals, and other financial transactions in Philippine Peso;
• To verify your identity and age in compliance with PAGCOR regulations and the Data Privacy Act of 2012;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity;
• To provide customer support and respond to your enquiries and complaints;
• To administer bonuses, promotions, and loyalty programmes;
• To monitor your gaming activity for responsible gaming purposes, including identifying patterns that may indicate problem gambling;
• To send you account-related notifications, security alerts, and service updates;
• To send you marketing communications about 226phwin promotions and new games, where you have consented to receive such communications;
• To improve the Platform's performance, usability, and game offering based on aggregated usage data;
• To comply with our legal and regulatory obligations under Philippine law.

226phwin 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.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, 226phwin processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements and anti-money laundering obligations;
• Legitimate interests: Processing necessary for 226phwin's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw your consent at any time by contacting our support team.

7. Sharing and Disclosure of Data

226phwin 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, strictly on a need-to-know basis:

• Identity verification providers: Third-party KYC service providers who assist 226phwin in verifying the identity and age of registered players;
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers necessary to process your financial transactions;
• Regulatory authorities: PAGCOR and other Philippine government agencies where disclosure is required by law, court order, or regulatory directive;
• Law enforcement: Philippine law enforcement agencies where disclosure is required in connection with the investigation of fraud, money laundering, or other criminal activity;
• Technology service providers: Cloud hosting, cybersecurity, analytics, and customer support platform providers who process data on 226phwin's behalf under strict data processing agreements;
• Professional advisers: Lawyers, auditors, and accountants where necessary for the conduct of 226phwin's business operations.

All third parties with whom 226phwin shares personal data are required to implement appropriate technical and organisational measures to protect that data and to process it only in accordance with 226phwin's instructions and applicable Philippine privacy law.

8. Data Retention

226phwin retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR anti-money laundering record-keeping requirements;
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, in accordance with Philippine financial record-keeping obligations;
• Customer support communications: Retained for three (3) years from the date of the last interaction, for quality assurance and dispute resolution purposes;
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of your consent decision;
• Technical and usage data: Retained for up to twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.

When personal data is no longer required, 226phwin will securely delete or anonymise it in accordance with our internal data disposal procedures.

9. Data Security

226phwin implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 226phwin Platform;
• Encryption of sensitive data at rest, including financial account details and identity documents;
• Role-based access controls ensuring that only authorised 226phwin personnel can access personal data, and only to the extent necessary for their role;
• Regular security audits, vulnerability assessments, and penetration testing of the Platform;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Staff training on data privacy obligations and secure data handling practices.

While 226phwin takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 226phwin will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

You also play an important role in keeping your data secure. Please ensure that your 226phwin account password is strong and unique, and that you do not share your login credentials with any third party.

10. Cookies and Tracking Technologies

226phwin uses cookies and similar tracking technologies to enhance your experience on the Platform, to keep you logged in between sessions, and to collect usage data that helps us improve our services. The types of cookies used by 226phwin include:

• Strictly necessary cookies: Essential for the Platform to function correctly. These cookies cannot be disabled as they are required for core features such as account login, session management, and security. No consent is required for these cookies;
• Functional cookies: Used to remember your preferences, such as language settings and game display options, to provide a more personalised experience;
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the Platform — such as which pages are visited most frequently and how long sessions last — to help 226phwin improve the Platform's performance and usability;
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and other security threats.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 226phwin Platform. 226phwin does not use cookies to serve third-party advertising or to track your activity across other websites.

11. Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 226phwin:

• Right to be informed: The right to be told what personal data 226phwin holds about you and how it is being used — which is the primary purpose of this Policy;
• Right of access: The right to request a copy of the personal data 226phwin holds about you;
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to erasure: 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 226phwin's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on 226phwin's legitimate interests;
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact 226phwin's Data Protection Officer using the contact details in Section 14. 226phwin will respond to all verified data rights requests within fifteen (15) business days. We may need to verify your identity before processing your request.

If you are not satisfied with 226phwin's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

12. Children and Minors

Upon receiving a credible report that personal data has been collected from a minor, 226phwin will promptly close the relevant account, delete the associated personal data, and reverse any financial transactions where possible. 226phwin employs age verification procedures during registration to prevent underage access, in compliance with PAGCOR's regulatory requirements.

13. Changes to This Policy

226phwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, 226phwin will notify registered players via the email address associated with their account and will display a prominent notice on the Platform.

The date of the most recent revision is indicated at the top of this document. We encourage you to review this Policy periodically to stay informed about how 226phwin protects your personal data. Your continued use of the Platform following the publication of a revised Policy constitutes your acknowledgment of the changes.

14. Contact and Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or about how 226phwin handles your personal data, please contact our Data Protection Officer through the following channel:

If you are not satisfied with 226phwin's handling of your complaint, you may escalate the matter to the National Privacy Commission of the Philippines. 226phwin is committed to cooperating fully with the National Privacy Commission in the resolution of any complaint.