Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by yeswin through our website, mobile applications, and related services (collectively, the "Platform"). By creating an account or using yeswin services, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

This Privacy Policy is incorporated into and forms part of our Terms and Conditions. Terms defined in the Terms and Conditions have the same meaning when used in this Privacy Policy unless otherwise specified.

yeswin is committed to transparency in data processing. If you have questions or concerns about how we handle your personal information, please contact our Data Protection Officer using the contact details provided at the end of this policy.

2. Data Controller Information

yeswin acts as the data controller for personal information collected through the Platform. As data controller, yeswin determines the purposes and means of processing your personal data and is responsible for ensuring compliance with applicable data protection laws, including the Philippine Data Privacy Act of 2012.

Our commitment to data protection extends throughout our organization. We have appointed a Data Protection Officer (DPO) who oversees compliance with privacy regulations and serves as the primary contact point for data protection inquiries from users and regulatory authorities.

3. Personal Information We Collect

yeswin collects various categories of personal information to provide gaming services, ensure regulatory compliance, prevent fraud, and enhance user experience. The personal information we collect includes:

3.1 Account Registration Information

• Full legal name as it appears on government-issued identification
• Date of birth (to verify you meet the 21+ age requirement)
• Gender
• Email address
• Mobile phone number
• Residential address in the Philippines
• Username and password (passwords are encrypted and not viewable by yeswin staff)

3.2 Verification and Identity Documents

• Government-issued identification (Philippine Passport, Driver's License, National ID, UMID, SSS ID, Postal ID)
• Proof of address documents (utility bills, bank statements, government correspondence)
• Photographs or scans of identity documents
• Selfie photographs for identity verification purposes

3.3 Financial Information

• Payment method details (GCash account name, Maya account information, bank account details)
• Transaction history (deposits, withdrawals, wagers, winnings)
• Deposit and withdrawal amounts and frequencies
• Payment processor transaction references

3.4 Gaming and Usage Information

• Gaming activity (games played, bet amounts, game outcomes, session duration)
• Bonus and promotion participation
• Customer support interactions (chat transcripts, email correspondence, phone call recordings)
• Preferences and settings configured in your account
• Responsible gaming settings (deposit limits, session timers, self-exclusion choices)

3.5 Technical and Device Information

• IP address and geographic location
• Device type, operating system, and browser information
• Login timestamps and session data
• Cookies and similar tracking technologies data
• Platform interaction data (pages viewed, features used, time spent on Platform)

3.6 Communications

• Marketing communication preferences (email, SMS, push notification opt-ins)
• Feedback and survey responses
• User-generated content (forum posts, reviews, comments if applicable)

4. How We Collect Your Information

yeswin collects personal information through various methods during your interaction with our Platform:

4.1 Direct Collection

We collect information directly from you when you:

• Register for a yeswin account
• Complete account verification by submitting identification documents
• Make deposits or request withdrawals
• Contact customer support via live chat, email, or phone
• Participate in promotions, tournaments, or surveys
• Update your account profile or preferences
• Subscribe to marketing communications

4.2 Automatic Collection

We automatically collect certain information when you access and use the yeswin Platform:

• Technical data through cookies, web beacons, and similar technologies
• Gaming activity and transaction data generated during Platform use
• Device and browser information transmitted during connections to our servers
• IP address and geographic location data for security and regulatory compliance

4.3 Third-Party Sources

In certain circumstances, yeswin may receive information about you from third-party sources:

• Payment processors providing transaction verification and fraud prevention data
• Identity verification service providers confirming document authenticity
• Credit reference agencies for fraud prevention purposes (where legally permitted)
• Publicly available sources to verify information accuracy
• Marketing partners (only if you have consented to such sharing with the third party)

5. Legal Basis for Processing

Under the Philippine Data Privacy Act and international data protection standards, yeswin must have a lawful basis for processing your personal information. We process your personal data based on the following legal grounds:

5.1 Contractual Necessity

Processing is necessary to perform our contract with you (the Terms and Conditions) and provide yeswin services, including account creation, transaction processing, game provision, and customer support.

5.2 Legal Obligation

Processing is required to comply with Philippine and international legal obligations, including anti-money laundering regulations, age verification requirements, tax reporting obligations, and regulatory reporting to gaming authorities.

5.3 Legitimate Interests

Processing is necessary for yeswin's legitimate business interests, including fraud prevention, security monitoring, improving Platform functionality, analyzing usage patterns, and protecting our legal rights. We balance these interests against your rights and freedoms.

5.4 Consent

For certain processing activities, particularly marketing communications and non-essential cookies, we rely on your explicit consent. You have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

6. How We Use Your Information

yeswin uses your personal information for the following purposes:

6.1 Service Provision

• Creating and managing your yeswin account
• Processing deposits, withdrawals, and financial transactions
• Providing access to games and gaming services
• Calculating and crediting bonuses and promotional rewards
• Maintaining gaming session integrity and recording game outcomes
• Providing customer support and responding to inquiries

6.2 Compliance and Security

• Verifying your identity and age (21+ requirement)
• Complying with Philippine gaming regulations and licensing requirements
• Meeting anti-money laundering and counter-terrorism financing obligations
• Preventing fraud, money laundering, and other illegal activities
• Detecting and preventing multiple account registrations and bonus abuse
• Protecting yeswin systems and infrastructure from security threats
• Responding to legal requests from Philippine authorities

6.3 Responsible Gaming

• Monitoring gaming behavior for signs of problem gambling
• Implementing and enforcing deposit limits and self-exclusion requests
• Providing access to responsible gaming tools and resources
• Contacting players with concerning gambling patterns to offer support

6.4 Platform Improvement

• Analyzing usage patterns to improve Platform functionality and user experience
• Conducting market research and gathering user feedback
• Testing new features and services
• Personalizing content and game recommendations
• Optimizing Platform performance and resolving technical issues

6.5 Marketing and Communications

• Sending promotional offers, bonuses, and tournament announcements (with your consent)
• Providing transactional communications (deposit confirmations, withdrawal notifications)
• Sending service updates, policy changes, and important notices
• Conducting customer satisfaction surveys

7. Information Sharing and Disclosure

yeswin does not sell your personal information to third parties. We share your information only in the following limited circumstances:

7.1 Service Providers

We engage trusted third-party service providers to support yeswin operations, including:

• Payment processors (GCash, Maya, banking partners) for transaction processing
• Identity verification services for document authentication
• Cloud hosting and data storage providers
• Customer support platform providers
• Marketing and communication service providers
• Data analytics and performance monitoring services

All service providers are contractually obligated to protect your personal information and use it only for authorized purposes specified by yeswin.

7.2 Game Providers

Limited information (username, gaming activity) is shared with game developers and providers whose games are featured on yeswin Platform to enable game functionality and maintain gaming records.

7.3 Legal and Regulatory Authorities

We disclose information to Philippine government agencies, regulatory bodies, and law enforcement when legally required, including:

• Complying with court orders, subpoenas, or legal processes
• Reporting suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Responding to requests from Philippine gaming regulators
• Cooperating with law enforcement investigations
• Filing tax reports as required by the Bureau of Internal Revenue (BIR)

7.4 Business Transfers

If yeswin undergoes merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you of any such change in ownership or control of your personal information.

7.5 With Your Consent

We may share your information with other parties when you explicitly consent to such sharing, such as participating in co-branded promotions or third-party tournaments.

8. Data Retention and Storage

yeswin retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

8.1 Retention Periods

Data Category	Retention Period
Account registration information	Duration of account activity plus 5 years after account closure
Identity verification documents	5 years after account closure or as required by law
Financial transaction records	7 years from transaction date (tax and AML compliance)
Gaming activity records	5 years from transaction date (regulatory requirement)
Customer support communications	3 years from last communication
Marketing consent records	Until consent is withdrawn plus 1 year

8.2 Data Storage Location

Your personal information is primarily stored on secure servers located within the Philippines and in secure international data centers that meet Philippine data protection standards. All international transfers comply with cross-border data transfer requirements under the Philippine Data Privacy Act.

8.3 Secure Deletion

When retention periods expire, yeswin securely deletes or anonymizes your personal information using industry-standard data destruction methods to prevent unauthorized access or recovery.

9. Security Measures

yeswin employs comprehensive technical, organizational, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

9.1 Technical Security

• 256-bit SSL/TLS encryption for all data transmitted between your device and yeswin servers
• Encryption of sensitive data at rest, including passwords and financial information
• Regular security audits and penetration testing by independent security firms
• Firewall protection and intrusion detection systems
• Secure authentication mechanisms and multi-factor authentication options
• Regular security patches and system updates

9.2 Organizational Security

• Role-based access controls limiting employee access to personal data on need-to-know basis
• Mandatory security awareness training for all yeswin staff
• Confidentiality agreements binding all employees and contractors
• Incident response procedures for security breaches
• Regular privacy and security policy reviews

9.3 Physical Security

• Secure data centers with restricted physical access
• Environmental controls and backup power systems
• 24/7 surveillance and monitoring of data center facilities

10. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal information:

10.1 Right to Information

You have the right to be informed about the collection, use, and sharing of your personal information. This Privacy Policy fulfills that obligation by providing transparent information about yeswin data practices.

10.2 Right of Access

You may request a copy of the personal information yeswin holds about you. We will provide this information in a structured, commonly used format within thirty (30) days of your request.

10.3 Right to Rectification

You have the right to correct inaccurate or incomplete personal information. You can update most information directly through your yeswin account settings or by contacting customer support for assistance.

10.4 Right to Erasure

You may request deletion of your personal information when it is no longer necessary for the purposes collected or when you withdraw consent. However, yeswin may retain certain information where legal obligations require retention (e.g., financial records for tax compliance).

10.5 Right to Object

You may object to processing of your personal information for direct marketing purposes at any time. You can unsubscribe from marketing communications through the unsubscribe link in emails or by updating preferences in your account.

10.6 Right to Data Portability

You have the right to receive your personal information in a portable format and transmit it to another data controller where technically feasible.

10.7 Right to Lodge Complaint

If you believe yeswin has violated your data privacy rights, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC). Contact details are available at privacy.gov.ph.

10.8 Exercising Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected] with "Privacy Rights Request" in the subject line. We will respond within the timeframe required by law and may request verification of your identity before processing your request.

11. Cookies and Tracking Technologies

yeswin uses cookies and similar tracking technologies to enhance Platform functionality, analyze usage patterns, and deliver personalized experiences.

11.1 What Are Cookies

Cookies are small text files placed on your device when you visit the yeswin Platform. Cookies enable the Platform to recognize your device and remember information about your visit.

11.2 Types of Cookies We Use

• Essential Cookies: Necessary for Platform operation, enabling core functionality like login authentication and account access. These cannot be disabled.
• Performance Cookies: Collect information about Platform usage, helping us understand how players interact with yeswin and identify areas for improvement.
• Functionality Cookies: Remember your preferences and settings to provide enhanced, personalized experiences.
• Marketing Cookies: Track your activity across websites to deliver relevant advertisements and measure campaign effectiveness. Used only with your consent.

11.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse all cookies or accept only certain types. However, disabling essential cookies may prevent proper Platform functionality. For more information about cookies and how to manage them, visit aboutcookies.org.

12. Third-Party Services

The yeswin Platform may contain links to third-party websites or integrate third-party services (payment processors, social media platforms). This Privacy Policy applies only to yeswin. We are not responsible for the privacy practices of third-party services.

When you interact with third-party services through yeswin, such as making a GCash deposit or sharing content on social media, those third parties may collect information about you subject to their own privacy policies. We encourage you to review the privacy policies of any third-party service before providing personal information.

13. International Data Transfers

While yeswin primarily stores data within the Philippines, some personal information may be transferred to and processed in countries outside the Philippines where our service providers operate. These transfers comply with Philippine Data Privacy Act requirements for cross-border data transfers.

When transferring data internationally, yeswin ensures adequate protection through:

• Contractual clauses requiring recipients to protect personal information to Philippine standards
• Selecting service providers in countries with adequate data protection laws
• Implementing supplementary security measures for sensitive information
• Obtaining National Privacy Commission approval for transfers where required

14. Children's Privacy

yeswin services are intended exclusively for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21 years of age. If we discover that we have inadvertently collected information from a person under 21, we will immediately delete that information and close the associated account.

Parents or guardians who believe their child has provided personal information to yeswin should contact us immediately at [email protected]. We take underage gambling prevention seriously and cooperate fully with authorities on such matters.

15. Changes to This Privacy Policy

yeswin reserves the right to update this Privacy Policy periodically to reflect changes in our data practices, legal requirements, or business operations. When material changes are made, we will notify you through:

• Email notification to your registered email address
• Prominent notice on the yeswin Platform
• Pop-up notification upon login requiring acknowledgment

The effective date at the top of this Privacy Policy indicates when it was last updated. Continued use of yeswin services after changes become effective constitutes acceptance of the updated Privacy Policy. If you do not agree with changes, you must cease using yeswin services and may request account closure.

16. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or yeswin's data protection practices, please contact us:

• Data Protection Officer Email: [email protected]
• Subject Line: Privacy Inquiry or Privacy Rights Request
• Customer Support: Available 24/7 via live chat through the Platform

When contacting us about privacy matters, please provide your full name, registered email address, and detailed description of your inquiry or request. We will respond to all privacy inquiries within fifteen (15) business days.