wimph Privacy Policy

In this Privacy Policy, the following terms shall have the meanings set out below:

• "wimph", "we", "us", or "our" refers to the operator of the wimph online casino and sports betting platform at wimph.cam, operating under PAGCOR regulation.
• "Platform" means the wimph website, account systems, games, features, and all related services accessible at wimph.cam.
• "Personal Data" or "Personal Information" means any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably ascertained, as defined under Republic Act 10173.
• "Sensitive Personal Information" has the meaning ascribed to it under Section 3(l) of RA 10173, and includes government-issued identification numbers, financial account details, and information relating to any legal proceedings.
• "Processing" means any operation or set of operations performed upon personal data, including collection, recording, organisation, storage, updating, retrieval, use, consolidation, blocking, erasure, or destruction.
• "Data Subject" means any natural person whose Personal Data is processed by wimph — in this context, primarily players and registered Account holders.
• "Data Protection Officer" or "DPO" means the individual designated by wimph to oversee compliance with RA 10173 and this Privacy Policy.
• "NPC" means the National Privacy Commission of the Philippines, the regulatory body overseeing data privacy compliance.
• "PAGCOR" means the Philippine Amusement and Gaming Corporation.

wimph is the data controller responsible for the personal data of players and users of the wimph Platform. As data controller, wimph determines the purposes for which, and the manner in which, your Personal Data is processed. wimph processes personal data in its capacity as a PAGCOR-licensed online gaming operator in the Philippines.

wimph has designated a Data Protection Officer (DPO) as required under Section 21 of RA 10173. The DPO is responsible for overseeing wimph's compliance with RA 10173, its implementing rules and regulations, and all NPC circulars and advisories applicable to personal data processing by online gaming platforms.

For all data privacy concerns, data subject rights requests, or complaints relating to wimph's handling of your Personal Data, you may contact the wimph Data Protection Officer at [email protected] with the subject line "Data Privacy Request."

wimph collects the following categories of Personal Data from players and Platform users. Collection occurs at various stages of your relationship with wimph, from initial account registration through ongoing platform use.

wimph collects Personal Data through the following means:

• Direct Collection — Account Registration: When you create a wimph Account, you directly provide your name, date of birth, mobile number, email address, and chosen login credentials.
• Direct Collection — KYC Verification: When you submit identity verification documents as required under PAGCOR's Know-Your-Customer (KYC) requirements or AML obligations, you directly provide identity documents and financial account details.
• Direct Collection — Transactions: When you make a deposit or withdrawal via GCash, Maya, BPI, BDO, UnionBank, 7-Eleven Cliqq, USDT TRC20, or Coins.ph, your payment reference details are collected and recorded.
• Direct Collection — Communications: When you contact wimph's customer support via live chat or email, the content of those communications is collected and stored.
• Automated Collection — Platform Usage: When you use the wimph Platform, technical data including your IP address, device type, browser information, session timestamps, and game activity are collected automatically by wimph's systems.
• Automated Collection — Cookies and Similar Technologies: wimph uses cookies and similar tracking technologies to collect certain Technical Data. See Section 8 of this Policy for full details on wimph's cookie practices.
• Third-Party Sources: wimph may receive data about you from third-party identity verification services, fraud detection providers, and payment processors in the course of processing your transactions or verifying your identity.

wimph processes your Personal Data for the following specific purposes:

• Account Creation and Management: To register and maintain your wimph Account, verify your identity and age, manage your login credentials, and administer your account settings and preferences.
• Service Delivery: To provide you with access to the wimph gaming platform, process your bets and wagers, credit your winnings, and facilitate all platform features you use during your sessions.
• Payment Processing: To process your deposits and withdrawals via the supported Philippine payment methods, verify payment references, and maintain accurate financial records of all transactions on your Account.
• Regulatory Compliance — PAGCOR: To fulfil wimph's obligations as a PAGCOR-licensed gaming operator, including maintaining player records, submitting required reports, and cooperating with PAGCOR audits and investigations.
• Anti-Money Laundering (AML) Compliance: To comply with the Anti-Money Laundering Act (RA 9160 as amended), including conducting customer due diligence, monitoring transactions for suspicious activity, and reporting to the Anti-Money Laundering Council (AMLC) where required.
• Fraud Prevention and Security: To detect and prevent fraud, identity theft, account takeovers, collusion, bonus abuse, and other prohibited conduct as described in the wimph Terms and Conditions.
• Responsible Gaming: To administer responsible gaming tools including deposit limits, session alerts, cooling-off periods, and self-exclusion; and to monitor gaming patterns that may indicate problem gambling behaviour as required under PAGCOR responsible gaming standards.
• Customer Support: To respond to your enquiries, complaints, and disputes through wimph's 24/7 support channels.
• Platform Improvement: To analyse aggregate, anonymised usage data for the purpose of improving the Platform, optimising game performance, and enhancing user experience. Individual player data is not used for this purpose without anonymisation.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided your consent to receive such communications. You may withdraw this consent at any time through your Account settings.
• Legal Compliance and Dispute Resolution: To comply with any legal obligation imposed on wimph, and to establish, exercise, or defend legal claims in relation to your Account or your use of the Platform.

Under RA 10173, wimph processes your Personal Data on the basis of one or more of the following lawful criteria, depending on the specific processing activity:

• Contractual Necessity: Processing necessary for the performance of the contract between you and wimph — i.e., the wimph Terms and Conditions — including account management, service delivery, and payment processing.
• Legal Obligation: Processing necessary for wimph to comply with its obligations under PAGCOR regulation, RA 9160 (Anti-Money Laundering Act), RA 10173 (Data Privacy Act), and all other applicable Philippine laws and regulations.
• Legitimate Interests: Processing necessary for wimph's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, provided those interests do not override your rights and freedoms as a data subject.
• Consent: For specific processing activities where consent is the appropriate basis — primarily marketing communications — wimph will obtain your explicit consent prior to processing. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

wimph does not sell, rent, or otherwise commercially transfer your Personal Data to third parties. Personal Data is shared only in the following circumstances and only to the extent strictly necessary for the stated purpose:

• Game Providers: Anonymised or pseudonymised player session data may be shared with wimph's licensed game suppliers (JILI, PG Soft, Pragmatic Play, Evolution Gaming, Spade Gaming, and others) solely for the technical operation of games on the Platform. These providers operate under contractual data processing agreements that prohibit independent use of your data.
• Payment Processors: Necessary payment reference data is shared with GCash, Maya, BPI, BDO, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT network processors to facilitate your deposits and withdrawals. These are independent entities subject to their own privacy policies.
• Identity Verification Services: For KYC and AML compliance, wimph may use third-party identity verification providers. These providers process your identity documents and biometric data strictly under wimph's instruction and applicable Philippine data privacy law.
• PAGCOR: wimph provides player data and transaction records to PAGCOR as required under its licensing obligations and upon request by PAGCOR in the course of any regulatory investigation or audit.
• Anti-Money Laundering Council (AMLC): wimph is legally required to report covered transactions and suspicious transactions to the AMLC under RA 9160. Such reports may include your personal and transaction data.
• Law Enforcement and Courts: wimph will disclose your Personal Data to Philippine law enforcement authorities, courts, or other government bodies where required by a lawful court order, subpoena, or other valid legal process, or where wimph is required to do so by Applicable Law.
• Professional Advisers: wimph's lawyers, auditors, and compliance consultants may have access to Personal Data in the course of providing professional services, subject to professional confidentiality obligations.

wimph uses cookies and similar tracking technologies (including web beacons and local storage) on the Platform. Cookies are small data files stored on your device that help wimph provide a functional and personalised experience. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable core features such as account login session maintenance, security token management, and navigation between pages. These cookies cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymised information about how players use the Platform — which pages are visited most frequently, error messages encountered, and session durations. This data is used in aggregate form to improve Platform performance. No individual player is identified through these cookies.
• Functional Cookies: These cookies remember your preferences — such as language settings, responsible gaming limit displays, and recently played games — to provide a more personalised experience on subsequent visits.
• Security Cookies: wimph uses security cookies to support fraud detection and account security functions, including identifying unusual login locations and flagging potentially compromised sessions.

Most web browsers allow you to control cookies through their settings. You may disable non-essential cookies without affecting your ability to use core Platform features, though some functional preferences may not be retained between sessions. Please refer to your browser's help documentation for instructions on managing cookie settings.

wimph implements technical, administrative, and physical safeguards designed to protect your Personal Data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and wimph's servers is encrypted using 256-bit SSL/TLS protocol, the same standard used by Philippine banks and financial institutions.
• Password Hashing: Account passwords are never stored in plain text. wimph uses a one-way cryptographic hashing algorithm to store password credentials. Even wimph personnel cannot read your actual password.
• Access Controls: Access to personal data held by wimph is restricted to authorised personnel who require such access in the performance of their job functions, subject to role-based access controls and audit logging.
• Data Minimisation: wimph collects only the Personal Data necessary for the identified processing purposes. Data that is no longer needed is securely deleted in accordance with wimph's retention schedule.
• Penetration Testing and Security Audits: wimph conducts regular security assessments of the Platform and its data systems, including penetration testing by qualified security professionals, to identify and remediate vulnerabilities.
• Two-Factor Authentication: wimph offers 2FA as an additional Account security layer. Players are encouraged to activate this feature to reduce the risk of unauthorised access to their Accounts and personal data.
• Incident Response Plan: wimph maintains a documented data breach response plan. In the event of a confirmed breach affecting personal data, wimph will follow its incident response procedures, notify affected players, and report to the NPC in accordance with NPC Circular 16-03.

wimph retains Personal Data for the periods set out below, after which it is securely deleted or anonymised unless a longer retention period is required or permitted by Applicable Law:

Where a legal dispute arises involving your Account, wimph may retain relevant Personal Data beyond the standard retention periods set out above until the dispute is fully and finally resolved. Upon expiry of the applicable retention period, Personal Data is securely deleted using methods that prevent recovery.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your Personal Data held by wimph. These rights can be exercised by submitting a written request to wimph's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request."

• Right to Be Informed: You have the right to be informed of how wimph collects, uses, retains, and discloses your Personal Data. This Privacy Policy is wimph's primary means of fulfilling this right.
• Right to Access: You have the right to obtain a copy of the Personal Data that wimph holds about you, together with information about how it is being processed. wimph will respond to access requests within 15 business days.
• Right to Correction: You have the right to require wimph to correct any inaccurate or incomplete Personal Data held about you. Corrections to Account details may require identity re-verification.
• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your Personal Data where (a) it is no longer necessary for the purposes for which it was collected, (b) you withdraw consent and there is no other legal basis for processing, or (c) the data has been unlawfully processed. This right is subject to wimph's legal retention obligations under PAGCOR regulation and AMLA.
• Right to Object: You have the right to object to the processing of your Personal Data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though such objections may be overridden where wimph has compelling legitimate grounds for the processing.
• Right to Data Portability: You have the right to receive the Personal Data you have provided to wimph in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe wimph has processed your Personal Data in violation of RA 10173. Information about the NPC complaints process is available on the NPC's official website.

wimph will respond to all data subject rights requests within the timeframes prescribed by RA 10173 and NPC implementing rules. There is no charge for making a data subject rights request. If a request is manifestly unfounded or excessive, wimph reserves the right to refuse the request or charge a reasonable administrative fee, subject to NPC guidelines.

The wimph Platform is strictly for persons who are 21 years of age or older, as required by Philippine law governing casino-style gambling under PAGCOR. wimph does not knowingly collect Personal Data from any person under the age of 21.

Age is verified during the Account registration process. Where wimph discovers or is notified that an Account has been created by a person under 21 years of age, it will immediately close that Account, delete all associated Personal Data to the extent not required to be retained under PAGCOR or AMLA obligations, and take appropriate action in accordance with its regulatory duties.

If you believe that a person under 21 has registered an Account on the wimph Platform, please report this to wimph immediately at [email protected]. wimph will investigate and act promptly on any such reports. We also encourage parents and guardians to use parental control software on devices accessible to minors to prevent access to online gaming sites.

The wimph Platform is operated with servers and data infrastructure that may be located in jurisdictions outside the Philippines, including regions where game provider servers and cloud infrastructure are hosted. Where your Personal Data is transferred outside the Philippines, wimph ensures that appropriate safeguards are in place to protect your data in accordance with Section 21 of RA 10173 and NPC guidelines on cross-border data flows.

Such safeguards include contractual data transfer agreements that impose obligations on recipient entities equivalent to those under RA 10173, and assessment of the data protection framework of the destination jurisdiction prior to any transfer. Cross-border transfers occur primarily in connection with:

• Game provider server infrastructure (for real-time game data processing by JILI, Evolution Gaming, PG Soft, and other licensed providers)
• Cloud hosting and content delivery network (CDN) services used for Platform performance optimisation
• Third-party identity verification and KYC service providers whose processing infrastructure may be located abroad

All entities receiving Personal Data in cross-border transfers are bound by contractual obligations to process that data only for the specified purposes and to maintain appropriate security measures. wimph will notify the NPC of any cross-border data sharing arrangements as required under NPC rules.

wimph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in Applicable Law, or changes in PAGCOR or NPC regulatory requirements. The effective date at the top of this Privacy Policy will be updated each time a material change is made.

Where changes to this Privacy Policy are material — meaning they affect your rights as a data subject or significantly change how wimph processes your Personal Data — wimph will notify registered Account holders via email or in-Platform notification prior to the changes taking effect. We recommend that you review this Privacy Policy periodically to stay informed of how wimph handles your data.

Your continued use of the wimph Platform following the posting of any amendment to this Privacy Policy constitutes your acknowledgement of, and agreement to, the updated Policy. If you do not agree to any amendment, you should cease using the Platform and request closure of your Account in accordance with the process described in the wimph Terms and Conditions.

For all queries, concerns, requests, or complaints relating to this Privacy Policy or wimph's processing of your Personal Data, you may contact wimph's Data Protection Officer through the following channels:

• Email: [email protected] — Please use the subject line "Data Privacy Request" or "DPO Enquiry" to ensure your message is routed to the correct team. Responses are provided within 15 business days on Philippine Standard Time.
• Live Chat: wimph's 24/7 live chat support can assist with initial data privacy queries and can escalate formal data subject rights requests to the DPO.
• Platform: Certain data subject rights functions — such as marketing opt-out, data access requests, and deposit limit settings — are available directly from within your wimph Account dashboard.

If you are not satisfied with wimph's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the government authority responsible for enforcing RA 10173 and protecting the data privacy rights of Filipino citizens and residents.