winspire Privacy Policy

This Privacy Policy is issued by winspire ("winspire," "we," "us," or "our"), the operator of the online gaming platform accessible at winspire.app and its related subdomains and mobile interfaces. winspire acts as the Personal Information Controller (PIC) in respect of all personal data collected from members and visitors of the Platform, as that term is defined under Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines.

By registering an account on winspire, depositing funds, placing wagers, or otherwise interacting with the Platform, you acknowledge that your personal data will be processed in accordance with this Privacy Policy. If you are accessing the Platform on behalf of another person, you confirm that you have obtained that person's consent for the processing described herein.

winspire collects and processes the following categories of personal data from members and visitors:

2.1 Identity Information

Full legal name, date of birth, nationality, and copies of government-issued Philippine identification documents (such as UMID, passport, PhilSys national ID, driver's license, or voter's ID) collected as part of the Know Your Customer (KYC) verification process.

2.2 Contact Information

Email address, registered mobile number, and residential address. These are collected during registration and may be updated by the member through their account settings.

2.3 Account Credentials

Your chosen username and a hashed (irreversible encrypted) version of your password. winspire does not store passwords in readable format. Your withdrawal PIN, in similarly secured form.

2.4 Financial Information

GCash account number or mobile number, Maya account details, bank account numbers (where provided for bank transfer withdrawals), transaction histories including deposit amounts, withdrawal requests, game session wagering records, and bonus utilisation records.

2.5 Device and Technical Data

IP address, browser type and version, device type and operating system, screen resolution, session timestamps, referring URLs, and pages visited within the Platform. This data is collected automatically when you access the Platform.

2.6 Behavioural and Game Data

Game preferences, game session records (rounds played, wager amounts, outcomes), sports betting selections, bingo participation records, session duration, and feature usage patterns within the Platform. This data is used to personalise your experience, detect fraudulent activity, and fulfil responsible gaming obligations.

winspire collects personal data through the following channels:

• Directly from you during account registration, KYC document submission, deposit and withdrawal transactions, customer support interactions, survey participation, and any other direct input you provide through the Platform.
• Automatically through the Platform's technical infrastructure — server logs, session tracking, and device fingerprinting — which collect technical and behavioural data as described in Section 2.5 and 2.6 each time you access or use the Platform.
• Through cookies and similar technologies placed on your device when you visit winspire.app, as further described in Section 7 of this Policy.
• From payment service providers such as GCash, Maya, and partner banking institutions, who may transmit transactional confirmation data to winspire in connection with deposits and withdrawals processed through their platforms.
• From fraud prevention and identity verification partners where winspire engages third-party services to verify the authenticity of identity documents or to screen members against regulatory watchlists as part of AML compliance obligations.

winspire processes your personal data for the following documented and legitimate purposes:

• Account creation and management: To register your winspire account, authenticate your identity at login, and maintain your account profile and history in a secure and accessible state.
• Age verification and KYC compliance: To confirm that you are at least 21 years of age, as required under Philippine gambling regulations, and to verify your identity in compliance with PAGCOR licensing requirements and anti-money laundering (AML) obligations.
• Payment processing: To facilitate deposits and withdrawals through your chosen payment method (GCash, Maya, BPI, BDO, Metrobank, 7-Eleven, or other approved channels) and to maintain accurate transaction records.
• Platform operation and personalisation: To operate the winspire casino, sportsbook, bingo, and live dealer services; to personalise your lobby experience; and to display content, promotions, and game recommendations relevant to your preferences and history.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, identity theft, money laundering, unauthorised account access, and violations of winspire's Terms & Conditions.
• Responsible gaming: To monitor gaming patterns for indicators of problematic gambling behaviour, to enforce deposit limits and self-exclusion restrictions, and to comply with PAGCOR's player protection requirements.
• Customer support: To respond to your enquiries, resolve disputes, process complaints, and maintain a record of support interactions for quality and compliance purposes.
• Legal and regulatory compliance: To comply with applicable Philippine laws, PAGCOR regulatory requirements, court orders, and legitimate requests from law enforcement authorities.
• Marketing communications (opt-in only): To send promotional offers, bonus notifications, and platform news to members who have explicitly opted in to receive marketing communications from winspire.

winspire processes personal data only where a lawful basis exists under the Data Privacy Act of 2012 and its Implementing Rules and Regulations. The applicable legal bases for winspire's processing activities are:

• Contractual necessity: Processing required to fulfil our obligations under the winspire Terms & Conditions, including account management, payment processing, and provision of gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML obligations, PAGCOR regulations, tax reporting requirements, and responses to valid legal process.
• Legitimate interests: Processing for fraud prevention, security monitoring, platform improvement, and responsible gaming monitoring, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where your explicit opt-in consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of prior processing.

winspire does not sell, rent, or disclose your personal data to third parties for their own commercial purposes. Personal data is shared with third parties only in the following limited and controlled circumstances:

• Payment service providers: GCash, Maya, BPI, BDO, Metrobank, and other approved payment partners receive the minimum data necessary to process your deposit or withdrawal transaction. These providers are subject to their own privacy policies and regulatory obligations under Bangko Sentral ng Pilipinas (BSP) supervision.
• KYC and identity verification providers: Third-party verification services that assist winspire in authenticating the identity documents you submit and screening your details against regulatory watchlists for AML compliance purposes.
• Game content providers: Software providers whose games are hosted on the winspire platform may receive session-level data necessary for game operation, RNG auditing, and technical support. These providers do not receive your identity or financial data.
• Technology and infrastructure providers: Cloud hosting, cybersecurity, fraud detection, and customer support platform vendors who provide technical infrastructure to winspire. These providers operate as Personal Information Processors (PIPs) under binding data processing agreements and are prohibited from using your data for any purpose other than providing their contracted service to winspire.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission of the Philippines, Philippine law enforcement agencies, and courts, where winspire is legally required to disclose information in response to a valid regulatory request, subpoena, or court order.

winspire uses cookies and similar technologies on the Platform to enable core functionality, improve your experience, and support security and fraud detection. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during a game session and security tokens that protect your account from cross-site request forgery. These cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, lobby display preferences, and notification configurations. These cookies are not strictly necessary but improve your experience.
• Analytics Cookies: Collect aggregated, anonymised data about how members use the Platform, which pages are visited most frequently, and where users encounter difficulties. This data helps winspire improve the Platform. Analytics cookies are enabled by default but may be disabled through your browser settings.
• Security and Fraud Detection Cookies: Identify unusual access patterns and flag potential fraudulent activity by comparing your current session characteristics against your typical usage profile. These cookies form part of winspire's account protection infrastructure.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log in and use the Platform.

winspire employs a comprehensive set of technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data in transit between your device and winspire's servers is encrypted using 256-bit SSL/TLS. Sensitive data at rest — including passwords, withdrawal PINs, and financial identifiers — is stored in encrypted or cryptographically hashed form.
• Access controls: Access to personal data within winspire's systems is restricted to personnel who require it to perform their specific job function, on a need-to-know basis. All access is logged and subject to periodic review.
• Two-factor authentication: Available to all winspire members and enforced for internal system access by winspire staff, requiring a one-time verification code in addition to standard credentials.
• Regular security audits: winspire engages independent security professionals to conduct penetration testing and security assessments of the Platform's infrastructure on a regular schedule.
• Breach response procedures: winspire maintains a documented data breach response plan that includes notification obligations to the National Privacy Commission of the Philippines and affected members in accordance with RA 10173 and its implementing regulations.

winspire retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised so that it can no longer be linked to an identifiable individual. Anonymised and aggregated data may be retained indefinitely for statistical and platform improvement purposes.

As a data subject under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by winspire. You may exercise any of these rights by contacting winspire's Data Protection Officer through the details provided in Section 15.

winspire will respond to data subject rights requests within 30 days of receipt. We reserve the right to extend this period by a further 30 days where the request is complex or where multiple requests have been received concurrently, in which case we will notify you within the initial 30-day period.

If you are dissatisfied with winspire's response to a data subject rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

The winspire platform is not directed at, and is not intended for use by, persons under 21 years of age. winspire does not knowingly collect personal data from individuals under the age of 21. The minimum age requirement for the use of winspire is 21 years, in compliance with PAGCOR regulations governing online gambling in the Philippines.

If winspire becomes aware that it has inadvertently collected personal data from an individual who is under 21 years of age, the following actions will be taken immediately:

• The account will be suspended and access to the Platform disabled;
• All personal data associated with the account will be deleted;
• Any deposited funds will be returned to the original payment source;
• Any winnings accumulated during the period of underage use will be forfeited and not paid out.

winspire sends marketing communications — including promotional offers, bonus announcements, game launch notifications, and platform news — only to members who have explicitly opted in to receive such communications. Marketing consent is collected separately from the mandatory account registration consent and is entirely optional.

You may opt in to or withdraw from winspire marketing communications at any time by:

• Updating your communication preferences in your winspire account settings under the "Notifications" tab;
• Using the "unsubscribe" link included in any marketing email sent by winspire;
• Contacting winspire's support team via live chat and requesting removal from all marketing lists.

Withdrawal of marketing consent does not affect the delivery of transactional communications — such as deposit confirmations, withdrawal notifications, security alerts, and account verification messages — which are sent regardless of your marketing preference setting as they are necessary for account operation.

winspire does not use your personal data to deliver targeted advertising on third-party platforms (such as social media networks) without your explicit separate consent.

Some of the third-party service providers engaged by winspire — including cloud infrastructure providers and certain game content providers — may process or store data in jurisdictions outside the Philippines. Where such cross-border transfers occur, winspire ensures that adequate safeguards are in place to protect your personal data at a standard equivalent to Philippine data privacy law requirements.

These safeguards may include:

• Binding contractual provisions in our agreements with overseas processors that require them to protect your data to Philippine Data Privacy Act standards;
• Transfers to processors located in countries that the National Privacy Commission of the Philippines has recognised as providing an adequate level of data protection;
• Standard contractual clauses approved by the National Privacy Commission or equivalent data protection authority.

By using the winspire Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines in the controlled and safeguarded manner described above.

winspire may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, regulatory requirements, or Platform functionality. All updates will be published on this page with a revised "Last Reviewed" date.

Where changes are material — meaning they significantly affect how we process your data or your rights as a data subject — winspire will notify registered members via email to the address on file at least 14 days before the updated Policy takes effect. Continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms.

We encourage you to review this Privacy Policy periodically to stay informed about how winspire protects your personal data. The current version of this Policy is always available at winspire.app/privacy-policy.

If you have any questions about this Privacy Policy, wish to exercise a data subject right, or wish to raise a concern about how winspire processes your personal data, please contact winspire's designated Data Protection Officer through the following channels:

• Live Chat: Available 24/7 directly through the winspire Platform. This is the fastest way to reach our support team and have a data subject request logged and assigned.
• Email: [email protected] — mark your subject line "Data Privacy Request" to ensure your message is routed to the Data Protection Officer's queue.

winspire is committed to responding to all data privacy enquiries promptly and in accordance with the timelines set out in the Data Privacy Act and its Implementing Rules and Regulations.

If you are not satisfied with winspire's response to a privacy concern, you may lodge a complaint with the National Privacy Commission of the Philippines, which is the independent regulatory body responsible for enforcing the Data Privacy Act.