66winn Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") applies to all personal information collected, processed, and stored by 66winn ("we," "us," "our," "the Company") in connection with the operation of the online casino and sports betting platform accessible at 66winn.org ("the Platform"). This Policy applies to:

• All registered members of 66winn who have created an account on the Platform
• Visitors to 66winn.org who have not registered but whose browsing data is processed via cookies and analytics tools
• Applicants who begin the registration process but do not complete it
• Former members whose data is retained pursuant to legal and regulatory obligations

By accessing the Platform, registering an account, or submitting any personal information to 66winn, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal information as described herein. If you do not agree to this Policy, you must not use the Platform.

This Policy should be read alongside 66winn's Terms and Conditions and Responsible Gaming Policy, both of which form part of the agreement between you and 66winn.

2. Data Controller Identity

For the purposes of the Philippines' Data Privacy Act of 2012 (Republic Act 10173, "DPA") and its Implementing Rules and Regulations (IRR), 66winn acts as the Personal Information Controller in respect of personal data collected through the Platform. 66winn has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with data privacy obligations. Inquiries relating to the exercise of your data privacy rights may be directed to the DPO via the contact details set out in Section 15 of this Policy.

3. Information We Collect

3.1 Registration and Identity Information

When you create a 66winn account, we collect the following information:

• Full legal name as it appears on your Philippine government-issued identification document
• Date of birth (to verify that you are 21 years of age or older, as required by PAGCOR)
• Philippine mobile phone number
• Email address
• Residential address in the Philippines
• Username and encrypted password

3.2 KYC Identity Verification Documents

To comply with PAGCOR licensing requirements and the Anti-Money Laundering Act (Republic Act 9160, as amended), we collect copies of:

• Philippine government-issued photo identification (e.g., PhilSys National ID, Passport, LTO Driver's License, SSS UMID, GSIS e-Card)
• Selfie photograph for identity matching purposes
• Proof of residential address where required by PAGCOR regulations

3.3 Financial and Transaction Information

We collect information related to deposits, withdrawals, and gaming transactions, including:

• GCash account number or Maya account details used for transactions (not your full GCash PIN or password)
• Bank account details where bank transfers are used (BPI, BDO, Metrobank, and others)
• Transaction amounts, timestamps, and reference numbers
• Gaming transaction records including bets placed, games played, winnings, and losses

3.4 Technical and Usage Information

When you access the Platform, we automatically collect certain technical information, including:

• IP address and approximate geolocation derived from IP address
• Device type, operating system, and browser type and version
• Session duration, pages visited, and features used on the Platform
• Login timestamps and session activity logs
• Cookies and similar tracking technologies (see Section 10)

3.5 Communications

Records of communications between you and 66winn, including live chat transcripts, emails, and support tickets, are retained for quality assurance and dispute resolution purposes.

4. How We Use Your Information

66winn uses the personal information it collects for the following purposes:

• Account Management: To register your account, verify your identity, and provide you with access to the Platform
• Age Verification: To verify that you meet the PAGCOR-mandated minimum age of 21 years before permitting access to casino services
• Payment Processing: To process deposits and withdrawals via GCash, Maya, QR Ph, GrabPay, BDO, BPI, Metrobank, and 7-Eleven CLiQQ
• PAGCOR Regulatory Compliance: To fulfill our licensing obligations, including player identification, transaction reporting, and exclusion register checks
• Anti-Money Laundering Compliance: To monitor transactions for potential money laundering activity as required under Republic Act 9160 and report suspicious transactions to the Anti-Money Laundering Council (AMLC) as legally mandated
• Responsible Gaming: To monitor gaming patterns and identify indicators of problem gambling, and to administer self-exclusion and deposit limit requests
• Customer Support: To provide assistance, investigate complaints, and resolve disputes
• Platform Security: To detect and prevent fraud, unauthorized account access, and prohibited conduct as defined in the Terms and Conditions
• Personalization: To display game recommendations and promotions relevant to your gaming history and preferences
• Communications: To send account-related notifications, security alerts, and, where you have consented, promotional communications
• Legal Compliance: To comply with court orders, subpoenas, or other legally mandated disclosures

5. Legal Bases for Processing

Under the Philippines' Data Privacy Act and its IRR, 66winn processes your personal information on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 66winn (i.e., providing casino and sports betting services) — this covers account creation, payment processing, and service delivery
• Legal Obligation: Processing is required to comply with PAGCOR regulations, the Anti-Money Laundering Act (RA 9160), the Data Privacy Act (RA 10173), and other applicable Philippine laws
• Legitimate Interests: Processing is necessary for 66winn's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your data privacy rights
• Consent: For optional processing activities, including promotional email communications and personalization beyond what is required for service delivery, we rely on your explicit consent, which you may withdraw at any time

6. Data Sharing & Disclosure

66winn does not sell your personal information to third parties. We share personal information only in the following circumstances:

• PAGCOR: As a licensed operator, we are required to provide player data to PAGCOR upon request for regulatory oversight purposes, including for the operation of the PAGCOR exclusion register
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports and covered transaction reports as required under Republic Act 9160
• Payment Processors: Information necessary to process your deposits and withdrawals is shared with GCash (GXI), Maya (Voyager Innovations), and other payment service providers. These providers process your financial data under their own privacy policies and applicable Philippine financial regulations
• Game Providers: Limited account and session information may be shared with 66winn's game content providers (e.g., JILI Games, PG Soft, Pragmatic Play) for game delivery and RNG certification purposes
• KYC Verification Partners: Identity documents may be processed by third-party KYC verification technology providers operating under data processing agreements with 66winn
• Law Enforcement & Courts: We may disclose personal information to Philippine law enforcement agencies, courts, or other government authorities in response to lawful requests, subpoenas, or court orders
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all assets of 66winn, personal data may be transferred to the successor entity, subject to the same privacy protections

All third parties with whom 66winn shares personal data are required to maintain the confidentiality of that data and to process it only for the purposes for which it was shared.

7. International Data Transfers

Some of 66winn's technology infrastructure and game providers are located outside the Philippines. Where personal information is transferred to recipients in other jurisdictions, 66winn ensures that such transfers are made in accordance with Section 21 of the Data Privacy Act and applicable NPC (National Privacy Commission) issuances, including through the use of data processing agreements that impose appropriate safeguards equivalent to Philippine data protection standards. 66winn will not transfer your personal information to a foreign jurisdiction unless that jurisdiction provides an adequate level of protection or appropriate contractual safeguards are in place.

8. Data Retention

66winn retains personal information for the following periods:

• Account data and KYC records: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and anti-money laundering regulations
• Transaction records: Retained for a minimum of five (5) years in accordance with Republic Act 9160 (Anti-Money Laundering Act) and PAGCOR record-keeping requirements
• Game session logs: Retained for a minimum of ninety (90) days for dispute resolution purposes; longer retention may apply for accounts subject to investigation
• Support communications: Retained for two (2) years from the date of the last communication or resolution of the relevant issue
• Marketing consent records: Retained for the duration of your consent and for one (1) year thereafter as evidence of consent

Upon expiry of applicable retention periods, personal information is securely deleted or anonymized in a manner that prevents re-identification.

9. Security Measures

66winn implements technical and organizational security measures appropriate to the nature and volume of personal data processed, including:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 66winn Platform
• Encryption of sensitive stored data including passwords (hashed with bcrypt) and financial information
• Two-factor authentication (2FA) available to all account holders and mandatory for administrative access
• Access controls limiting internal access to personal data to authorized personnel with a need-to-know basis
• Regular penetration testing and security audits of the Platform infrastructure
• 24/7 monitoring for unauthorized access, anomalous login patterns, and suspicious transactions
• Incident response protocols aligned with NPC notification requirements for personal data breaches

In the event of a personal data breach that is likely to result in harm to affected data subjects, 66winn will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with Section 20(f) of the Data Privacy Act.

10. Cookies & Tracking Technologies

66winn uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for Platform functionality including session management, login state, and security. These cannot be disabled without impairing Platform use.
• Performance Cookies: Used to analyze Platform usage patterns, page load performance, and error detection. Data collected is aggregated and anonymized.
• Functional Cookies: Used to remember your preferences such as language, game settings, and display options.
• Analytics Cookies: Used to understand how players interact with different sections of the Platform to improve user experience and game offerings.

You may manage your cookie preferences through your browser settings. Note that disabling essential cookies will impair the functionality of the 66winn Platform, including the ability to log in and place bets. 66winn does not use third-party advertising cookies or sell cookie-derived data to advertising networks.

11. Your Rights Under Republic Act 10173 (Data Privacy Act)

As a data subject under the Philippines' Data Privacy Act, you have the following rights in respect of your personal information held by 66winn:

• Right to be Informed: The right to be informed of how your personal information is collected, used, shared, and retained — which this Policy fulfills
• Right of Access: The right to request a copy of the personal information 66winn holds about you
• Right to Rectification: The right to correct inaccurate or incomplete personal information in your account
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal information, subject to overriding legal retention obligations (e.g., PAGCOR and AMLC record-keeping requirements may prevent full deletion)
• Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format
• Right to Object: The right to object to the processing of your personal information where processing is based on legitimate interests, including profiling for direct marketing purposes
• 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 privacy rights have been violated

To exercise any of the above rights, please contact 66winn's Data Protection Officer at [email protected]. We will respond to all data subject requests within thirty (30) days in accordance with NPC guidelines. Requests may require identity verification before processing to ensure data is disclosed to the correct individual.

12. Children & Age Restriction

The 66winn Platform is strictly prohibited for persons under twenty-one (21) years of age. 66winn does not knowingly collect personal information from persons under 21. If we become aware that personal information has been collected from a person under 21, we will immediately suspend the account, delete the associated personal information to the extent permitted by law, and report the matter to PAGCOR as required by our licensing conditions.

If you are a parent or guardian and believe that a person under 21 in your care has created a 66winn account, please contact us immediately at [email protected].

13. Third-Party Links

The 66winn Platform does not contain links to third-party websites. However, third-party service integrations within the Platform (such as GCash and Maya payment flows) may redirect you to the interfaces of those payment service providers. Those providers' privacy policies govern the processing of your information on their platforms. 66winn is not responsible for the privacy practices of third-party payment providers, and we encourage you to review their respective privacy policies before providing personal information on their platforms.

14. Changes to This Privacy Policy

66winn reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, or our data processing practices. Material changes to this Policy will be communicated to registered members via email to the address on file and via a notice on the Platform. The revised Policy will indicate the effective date of the amendments. Your continued use of the Platform after the effective date of any amendments constitutes your acceptance of the updated Policy. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure.

15. How to Contact Us

For all privacy-related inquiries, requests to exercise your data privacy rights, or to contact our Data Protection Officer, please reach us through the following channels:

• Email (DPO & Privacy Inquiries): [email protected]
• Live Chat Support (24/7): Available via the live chat icon on the Platform at 66winn.org
• Response Time: Privacy inquiries and data subject requests will receive a substantive response within thirty (30) days

If you believe that 66winn has violated your data privacy rights and you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through NPC's official government channels.