1Introduction
Welcome to the pupwin Privacy Policy. pupwin ("we", "us", "our") is committed to protecting the personal information of every player who uses our online casino platform at pupwin.net. This Privacy Policy describes how pupwin collects, uses, stores, shares, and protects your personal data in connection with your use of the pupwin platform and all related services.
This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines. It applies to all personal data collected from users who access or register on the pupwin platform, regardless of the device or method used to access it.
By registering for a pupwin account or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this policy, please discontinue use of the pupwin platform and contact us to close your account.
Note: This Privacy Policy should be read together with the pupwin Terms & Conditions, which govern your overall use of the platform.
2Data Controller
For the purposes of the Philippine Data Privacy Act of 2012, pupwin is the personal information controller responsible for the personal data collected through the pupwin platform. As the data controller, pupwin determines the purposes and means of processing your personal information.
pupwin has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. Contact details for the DPO are provided in Section 15 of this policy.
Where pupwin engages third-party service providers to process personal data on its behalf (such as payment processors or identity verification providers), those parties act as personal information processors and are bound by data processing agreements that require them to handle your data in accordance with this policy and applicable law .
3Data We Collect
pupwin collects the following categories of personal data from users of the platform:
| Category | Examples | Purpose |
|---|---|---|
| Identity Data | Full legal name, date of birth, government-issued ID number, nationality | Account registration, KYC verification, age verification |
| Contact Data | Email address, mobile number, residential address (city, province) | Account communication, support, regulatory notices |
| Financial Data | GCash number, PayMaya account, bank account details, transaction history | Processing deposits and withdrawals, AML compliance |
| Gaming Data | Game history, wager amounts, session duration, win/loss records | Platform operation, responsible gaming monitoring, dispute resolution |
| Technical Data | IP address, device type, browser type, operating system, login timestamps | Security, fraud prevention, platform optimization |
| Usage Data | Pages visited, features used, click patterns, session duration | Platform improvement, personalization, analytics |
| Communications Data | Support chat logs, email correspondence, feedback submissions | Customer support, quality assurance, dispute resolution |
Sensitive Data: Where pupwin collects sensitive personal information (such as government ID details required for KYC), we apply heightened security measures and process such data only to the extent strictly necessary for regulatory compliance.
4How We Collect Data
pupwin collects your personal data through the following means:
- Direct Collection: Information you provide when registering for a pupwin account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
- Automated Collection: Technical and usage data collected automatically when you access the pupwin platform, including through cookies, web beacons, log files, and similar tracking technologies (see Section 9).
- Third-Party Sources: Identity and fraud-check data received from KYC verification providers, payment processors, and fraud prevention services that pupwin engages to verify your identity and protect the platform.
- Regulatory Sources: Information received from PAGCOR, the NPC, or other Philippine regulatory authorities in connection with compliance obligations.
pupwin does not collect personal data from social media platforms or purchase data lists from third-party data brokers.
5How We Use Your Data
pupwin uses your personal data for the following purposes:
- Account Management: Creating and maintaining your pupwin account, verifying your identity, and managing your account settings and preferences.
- Platform Operation: Processing your deposits and withdrawals, recording your gaming activity, awarding bonuses, and providing the full range of pupwin gaming services.
- Regulatory Compliance: Meeting our obligations under Philippine gaming regulations, anti-money laundering (AML) laws, and the Data Privacy Act of 2012, including reporting to PAGCOR and other competent authorities as required.
- Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the platform.
- Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behavior, enforcing self-exclusion requests, and providing responsible gaming tools and interventions.
- Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance.
- Platform Improvement: Analyzing usage patterns and player feedback to improve the pupwin platform, fix bugs, and develop new features.
- Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where we have a legitimate interest, and always with an easy opt-out option.
Marketing Opt-Out: You may opt out of marketing communications at any time by updating your notification preferences in your pupwin account settings or by contacting our support team. Opting out of marketing will not affect transactional or regulatory communications.
6Legal Basis for Processing
Under the Philippine Data Privacy Act of 2012, pupwin processes your personal data on the following legal bases:
- Contractual Necessity: Processing required to perform our obligations under the pupwin Terms & Conditions, including account management, payment processing, and game operation.
- Legal Obligation: Processing required to comply with applicable Philippine laws, including AML regulations, PAGCOR licensing requirements, and tax reporting obligations.
- Legitimate Interests: Processing necessary for pupwin's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights.
- Consent: Processing based on your freely given, specific, and informed consent, particularly for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.
7Data Sharing & Disclosure
pupwin does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:
- Payment Processors: GCash, PayMaya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive financial data necessary to process your deposits and withdrawals.
- KYC & Identity Verification Providers: Third-party providers engaged to verify your identity and age as required by Philippine gaming regulations.
- Fraud Prevention Services: Specialist providers that help pupwin detect and prevent fraudulent activity, money laundering, and other illegal conduct.
- Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or regulatory order.
- IT and Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on pupwin's behalf under strict data processing agreements.
- Legal and Professional Advisors: Lawyers, auditors, and compliance consultants engaged by pupwin, subject to professional confidentiality obligations.
All third-party processors engaged by pupwin are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with pupwin's documented instructions.
8Data Retention
pupwin retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:
- Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by Philippine AML regulations.
- Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act of 2001 and its amendments.
- Gaming History: Retained for three (3) years from the date of each gaming session for dispute resolution and responsible gaming monitoring purposes.
- Customer Support Records: Retained for two (2) years from the date of each interaction.
- Marketing Consent Records: Retained for the duration of your account and for one (1) year following opt-out, to demonstrate compliance with consent requirements.
Upon expiry of the applicable retention period, pupwin will securely delete or anonymize your personal data in accordance with industry-standard data destruction practices.
9Cookies & Tracking Technologies
The pupwin platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze platform usage. The following types of cookies are used:
- Essential Cookies: Required for the platform to function correctly, including session management, login authentication, and security features. These cannot be disabled without affecting platform functionality.
- Performance Cookies: Collect anonymized data about how users interact with the pupwin platform, including pages visited and features used, to help us improve performance and user experience.
- Functional Cookies: Remember your preferences such as language settings, game display options, and notification preferences to provide a personalized experience.
- Analytics Cookies: Used to understand aggregate usage patterns across the platform. Data collected through analytics cookies is anonymized and cannot be used to identify individual users.
Cookie Control: You can manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the pupwin platform. Essential cookies cannot be disabled as they are required for platform security and operation.
pupwin does not use third-party advertising cookies or allow external advertisers to place tracking technologies on the platform.
10Data Security
pupwin implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:
- Encryption: All data in transit is protected using TLS 1.3 encryption. Sensitive data at rest, including financial information and government ID details, is encrypted using AES-256 encryption.
- Access Controls: Role-based access controls ensure that only authorized pupwin personnel with a legitimate operational need can access personal data. All access is logged and audited.
- Security Audits: pupwin conducts regular internal and third-party security audits and penetration tests to identify and remediate vulnerabilities.
- Incident Response: pupwin maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, pupwin will notify the National Privacy Commission within 72 hours and affected users without undue delay, as required by the DPA.
- Employee Training: All pupwin staff with access to personal data receive regular data protection and security training.
While pupwin takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your account credentials and for notifying pupwin immediately if you suspect unauthorized access to your account.
11Your Rights as a Data Subject
Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pupwin:
- Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed — which this Privacy Policy fulfills.
- Right of Access: The right to request a copy of the personal data pupwin holds about you, along with information about how it is being processed.
- Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by pupwin.
- 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 pupwin'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 legitimate interests.
- Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
- Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.
To exercise any of these rights, please contact the pupwin Data Protection Officer using the contact details in Section 15. pupwin will respond to all data subject requests within fifteen (15) business days of receipt, as required by the DPA's Implementing Rules and Regulations.
Identity Verification: For security purposes, pupwin may require you to verify your identity before processing a data subject request. This is to ensure that personal data is not disclosed to unauthorized parties.
12Children's Privacy
The pupwin platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. pupwin does not knowingly collect personal data from individuals under the age of 21.
If pupwin becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and report the matter to the relevant regulatory authorities as required.
If you are a parent or guardian and believe that your child has registered on the pupwin platform, please contact us immediately at the details provided in Section 15 so that we can take prompt action.
13Cross-Border Data Transfers
In some cases, pupwin may transfer your personal data to service providers or infrastructure partners located outside the Philippines. Where such transfers occur, pupwin ensures that appropriate safeguards are in place to protect your data, including:
- Entering into data transfer agreements that incorporate the standard contractual clauses approved by the National Privacy Commission
- Transferring data only to countries or organizations that provide an adequate level of data protection as recognized under Philippine law
- Conducting transfer impact assessments where required to ensure that your rights are not undermined by the transfer
pupwin will not transfer your personal data to jurisdictions that do not provide adequate data protection safeguards without your explicit consent, except where required by Philippine law.
14Changes to This Privacy Policy
pupwin 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, pupwin will:
- Update the "Last Updated" date at the top of this page
- Notify registered users via the email address associated with their account
- Display a prominent notice on the pupwin platform for a period of at least seven (7) days following the change
Your continued use of the pupwin platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the changes, you must cease using the platform and contact us to close your account and request deletion of your personal data, subject to our legal retention obligations.
The most current version of this Privacy Policy is always available on this page. We encourage you to review it periodically to stay informed about how pupwin protects your personal information.
15Contact & Data Protection Officer
For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by pupwin, please contact our Data Protection Officer:
Please mark all data subject requests and privacy-related correspondence with "Privacy Request" or "DPO" in the subject line to ensure prompt routing to the correct team.
You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated. The NPC can be reached through their official government channels.