Privacy Policy

1 Scope and Application

This Privacy Policy ("Policy") is issued by 37winph ("the Platform," "we," "us," or "our") and applies to all personal data collected, processed, and stored in connection with your use of the 37winph website, mobile application, and all associated gaming services (collectively, the "Services").

This Policy applies to all registered players, prospective players who browse the platform without registering, and any individual whose personal data is processed by 37winph in connection with the Services. By accessing or using the 37winph platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

This Policy should be read together with the 37winph Terms & Conditions and Responsible Gaming policy, both of which form part of the overall agreement between you and 37winph.

2 Data We Collect

37winph collects personal data that is necessary to provide the Services, verify player identity, process financial transactions, and comply with applicable legal and regulatory obligations. The categories of personal data we collect include:

We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by law or where you voluntarily provide such information in the context of a responsible gaming request.

3 How We Collect Your Data

37winph collects personal data through the following means:

• Direct submission: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the platform, including cookies, web beacons, server logs, and similar tracking technologies that record your device and usage information.
• Third-party providers: Data received from payment processors (such as GCash and PayMaya), identity verification services, and fraud prevention partners in connection with the processing of your transactions and account verification.
• Publicly available sources: In limited circumstances, we may verify information against publicly available records or databases where required for compliance purposes.

Where data is collected via automated technologies, we will provide appropriate notice through our cookie consent mechanism. You may adjust your cookie preferences at any time, though disabling certain cookies may affect the functionality of the 37winph platform.

4 How We Use Your Data

37winph uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and administer your 37winph player account, including processing your registration and verifying your identity and age (21+ requirement).
• Service delivery: To provide access to all games and features on the platform, including Casino, Fortune Bingo, Plinko, Darts, and Fruit Shop.
• Payment processing: To process deposits and withdrawals in Philippine Peso (₱) via your chosen payment method, and to maintain accurate transaction records.
• Legal and regulatory compliance: To meet our obligations under Philippine law, including anti-money laundering (AML) requirements, know-your-customer (KYC) obligations, and responsible gaming regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the platform.
• Customer support: To respond to your enquiries, resolve disputes, and provide assistance with account or technical issues.
• Platform improvement: To analyse usage patterns, identify technical issues, and improve the overall performance and user experience of the 37winph platform.
• Responsible gaming: To monitor gaming behaviour, identify potential problem gambling indicators, and administer self-exclusion or deposit limit requests.
• Communications: To send you important account notifications, security alerts, and — where you have opted in — promotional communications about 37winph offers and updates.

37winph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis for the new processing activity.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its implementing rules, 37winph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML/KYC requirements and responsible gaming obligations.
• Legitimate interests: Processing carried out for the legitimate interests of 37winph, such as fraud prevention, platform security, and service improvement, where those interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent, such as the sending of promotional communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing and Disclosure

37winph does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and eligibility to use the platform.
• Fraud prevention and security partners: Service providers that assist 37winph in detecting and preventing fraudulent activity, money laundering, and other prohibited conduct.
• Technology and infrastructure providers: Cloud hosting, data storage, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Government agencies, regulators, and law enforcement bodies where disclosure is required by applicable Philippine law, court order, or regulatory directive.
• Professional advisers: Legal counsel, auditors, and other professional advisers where necessary for the conduct of 37winph's business operations.

All third-party service providers who process personal data on behalf of 37winph are required to implement appropriate technical and organisational security measures and to process data only in accordance with our instructions and applicable law.

7 Data Retention

37winph retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention principles apply:

• Active account data: Retained for the duration of your account's active status on the 37winph platform.
• Transaction and financial records: Retained for a minimum of five (5) years following the date of the transaction, in accordance with Philippine AML and financial record-keeping requirements.
• Identity verification documents: Retained for the period required by applicable KYC regulations, typically five (5) years from the date of verification or account closure, whichever is later.
• Support and communications records: Retained for up to three (3) years from the date of the last communication, unless a longer period is required for dispute resolution or legal proceedings.
• Closed account data: Following voluntary account closure, personal data is retained for the minimum period required by law before being securely deleted or anonymised.

Where personal data is no longer required for any lawful purpose, 37winph will securely delete or anonymise it in accordance with our internal data disposal procedures. Anonymised data that can no longer be linked to an individual may be retained indefinitely for statistical and analytical purposes.

8 Cookies and Tracking Technologies

37winph uses cookies and similar tracking technologies — including web beacons, pixel tags, and local storage — to operate the platform, remember your preferences, and understand how players interact with the site. The types of cookies we use include:

Strictly necessary and security cookies cannot be disabled as they are essential to the operation of the platform. You may manage your preferences for non-essential cookies through your browser settings. Please note that disabling functional or analytics cookies may affect your experience on the 37winph platform.

9 Data Security

37winph implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 37winph platform.
• Encryption of sensitive data at rest, including financial account details and identity documents.
• Access controls limiting internal access to personal data to authorised personnel on a need-to-know basis.
• Regular security assessments and vulnerability testing of platform infrastructure.
• Incident response procedures to detect, contain, and report data security incidents in accordance with applicable law.

While 37winph takes data security seriously and maintains robust protective measures, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 37winph will notify affected players and the relevant authorities in accordance with applicable Philippine law.

You also have a role to play in keeping your account secure. Please use a strong, unique password for your 37winph account, do not share your login credentials with anyone, and contact support immediately if you suspect unauthorised access to your account.

10 Your Rights

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by 37winph:

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data 37winph holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update certain account details directly through your 37winph account settings.
• 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 our legal retention obligations.
• Right to object: The right to object to the processing of your personal data where that processing is based on legitimate interests, including the right to object to direct marketing communications.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting prior processing.

To exercise any of these rights, please contact the 37winph support team. We will respond to all valid requests within a reasonable timeframe and in accordance with applicable law. We may need to verify your identity before processing certain requests to protect the security of your account.

11 Children and Minors

The 37winph platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. The minimum age requirement is a firm condition of registration and use of the platform, consistent with Philippine regulations governing casino-style online gaming.

If 37winph becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to close the relevant account, void any associated balances, and securely delete the personal data in question. If you believe that a minor has registered on the 37winph platform, please contact our support team immediately.

Parents and guardians are encouraged to make use of parental control tools and internet filtering software to prevent minors from accessing online gaming platforms. 37winph supports responsible gaming and the protection of vulnerable individuals, including minors.

12 Policy Updates

37winph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform operations. When material changes are made, we will notify registered players via email or through a prominent notice on the platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how 37winph protects your personal data. Your continued use of the platform following notification of changes constitutes your acceptance of the revised Policy.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way 37winph handles your personal data, please contact our support team. We take all privacy enquiries seriously and will respond promptly. You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.