winspire Privacy Policy

1 About This Policy

This Privacy Policy ("Policy") applies to all personal information collected by winspire ("winspire," "we," "us," "our") through the winspire online gaming platform at winspire.one, including any associated mobile applications, customer support channels, and marketing communications (collectively, the "Platform").

By registering an account with winspire or using any part of the Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal information as described herein. If you do not agree with this Policy, you must not use the winspire Platform.

This Policy should be read together with winspire's Terms & Conditions and Responsible Gaming Policy, which together govern your use of the Platform.

2 Data We Collect

winspire collects personal information that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal information we collect include:

winspire does not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for legal compliance purposes, such as anti-money laundering verification. Where sensitive information is collected, we apply heightened security and access controls.

3 How We Use Your Data

winspire uses your personal information for the following purposes:

• Account Management: To create, verify, maintain, and secure your winspire account;
• Identity Verification (KYC): To comply with PAGCOR licensing requirements and Philippine anti-money laundering laws (RA 9160, as amended);
• Payment Processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card;
• Gaming Services: To provide access to live casino, sports betting, bingo, Lucky Dice, slots, and all other Platform features;
• Customer Support: To respond to your inquiries, complaints, and support requests;
• Responsible Gaming: To monitor gaming behavior, enforce deposit limits, process self-exclusion requests, and identify players who may need support;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct;
• Legal Compliance: To comply with applicable Philippine laws, PAGCOR regulations, court orders, and regulatory directives;
• Marketing & Promotions: To send you relevant offers, bonuses, and updates — only where you have provided consent or where permitted by law. You may opt out at any time;
• Platform Improvement: To analyze usage patterns and improve the winspire Platform's features, performance, and user experience.

winspire will not use your personal information for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by law.

4 Legal Basis for Processing

winspire processes your personal information on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions) — including account management, payment processing, and game delivery;
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act, and tax reporting requirements;
• Legitimate Interests: Processing is necessary for winspire's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights;
• Consent: For marketing communications and certain optional data uses, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5 Sharing Your Data

winspire does not sell your personal information to third parties. We may share your personal information with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions;
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged to verify your identity and comply with Philippine law;
• Game Technology Providers: Licensed game software providers who supply the games available on the winspire Platform;
• IT & Cloud Service Providers: Technology partners who host and maintain the winspire Platform infrastructure, subject to strict data processing agreements;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies as required by law;
• Law Enforcement: Philippine law enforcement agencies where required by a valid court order, subpoena, or legal process;
• Professional Advisors: Legal counsel, auditors, and compliance consultants bound by professional confidentiality obligations.

All third parties with whom winspire shares personal information are required to handle such information in accordance with the Philippine Data Privacy Act and winspire's data protection standards.

6 Cookies & Tracking Technologies

winspire uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze Platform usage.

The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function — including session management, login authentication, and security features. These cannot be disabled;
• Functional Cookies: Remember your preferences such as language settings and display options to personalize your experience;
• Analytics Cookies: Help us understand how players use the Platform so we can improve performance and features. Data collected is aggregated and anonymized where possible;
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the winspire Platform.

7 Data Retention

winspire retains your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specific retention periods include:

• Account and KYC records: Retained for a minimum of five (5) years after account closure, in compliance with PAGCOR requirements and the Anti-Money Laundering Act;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction;
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session;
• Customer support communications: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter.

When personal information is no longer required, winspire will securely delete or anonymize it in accordance with our data disposal procedures.

8 Data Security

Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the winspire Platform;
• AES-256 encryption for sensitive data stored in our databases;
• Multi-factor authentication (MFA) for player accounts and internal administrative access;
• Regular security audits, penetration testing, and vulnerability assessments;
• Strict access controls ensuring that only authorized winspire personnel can access personal data on a need-to-know basis;
• 24/7 security monitoring and intrusion detection systems;
• Secure data centers with physical access controls.

While winspire takes all reasonable steps to protect your personal information, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that poses a risk to your rights and freedoms, winspire will notify the National Privacy Commission and affected players in accordance with the Data Privacy Act's breach notification requirements.

9 Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal information held by winspire:

• Right to be Informed: The right to know what personal information winspire collects about you and how it is used — as described in this Policy;
• Right of Access: The right to request a copy of the personal information winspire holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal information;
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal information, subject to winspire's legal retention obligations;
• Right to Object: The right to object to the processing of your personal information for direct marketing purposes or on grounds relating to your particular situation;
• Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact winspire's Data Protection Officer at the contact details provided in Section 14 of this Policy. winspire will respond to all verified data subject requests within fifteen (15) business days, as required by the Data Privacy Act.

10 Children's Privacy

If winspire discovers that personal information has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal information, and return any deposits in accordance with applicable regulations. If you believe that a minor has registered on the winspire Platform, please contact us immediately at [email protected].

11 International Data Transfers

winspire primarily stores and processes your personal information within the Philippines. In certain circumstances, your personal information may be transferred to or accessed by winspire's service providers located outside the Philippines — for example, cloud infrastructure providers or game technology partners operating in other jurisdictions.

Where such transfers occur, winspire ensures that appropriate safeguards are in place to protect your personal information, including:

• Entering into data processing agreements that require overseas recipients to apply data protection standards equivalent to those required under the Philippine Data Privacy Act;
• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the National Privacy Commission;
• Applying contractual clauses approved by the NPC where no adequacy determination exists.

By using the winspire Platform, you acknowledge and consent to the transfer of your personal information as described in this section, subject to the safeguards outlined above.

12 Third-Party Links

The winspire Platform may contain references to third-party services such as payment processors (GCash, Maya, partner banks) and game providers. While winspire takes care to work only with reputable partners, we are not responsible for the privacy practices of third-party services.

When you interact with a third-party service — for example, when completing a GCash transaction — you will be subject to that third party's own privacy policy and terms of service. winspire encourages you to review the privacy policies of any third-party services you use in connection with the Platform.

13 Changes to This Policy

winspire reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, winspire will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable.

The most current version of this Policy will always be available at winspire.one/privacy-policy. The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. Your continued use of the winspire Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

If you do not agree with any changes to this Policy, you must stop using the Platform and may request account closure by contacting winspire customer support.

14 Contact & Data Protection Officer

winspire has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal information, please contact:

If you are not satisfied with winspire's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines: