codwin Privacy Policy

codwin is an online gaming platform operating at codwin.one, providing Filipino players with access to a range of online casino games, live dealer experiences, bingo, slots, and other gaming products. For the purposes of the Data Privacy Act of 2012, codwin acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players and visitors to the platform.

If you have any questions about this Policy or about how codwin handles your personal data, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 13 of this Policy.

codwin collects the following categories of personal data from players and platform visitors:

codwin collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the codwin platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from government databases or third-party KYC service providers; fraud-screening data from payment processors; publicly available information where permitted by law.

codwin processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill our obligations under the Terms and Conditions you agreed to when registering your codwin account, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR requirements, Anti-Money Laundering Act (AMLA) obligations, and the Data Privacy Act of 2012.
• Legitimate interests: Processing necessary for codwin's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent, particularly in relation to direct marketing communications. You may withdraw your consent at any time.

codwin uses the personal data we collect for the following purposes:

• To create, verify, and manage your codwin player account.
• To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card.
• To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine law.
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity.
• To monitor your gaming activity for responsible gaming purposes, including identifying signs of problem gambling.
• To provide customer support and respond to your inquiries and complaints.
• To send you transactional communications, including account notifications and security alerts.
• To send you promotional and marketing communications, where you have consented to receive them.
• To improve the codwin platform, personalize your experience, and conduct internal analytics.
• To comply with our legal and regulatory obligations under Philippine law.

codwin does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where required by law or regulation.
• Payment processors: GCash, Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing financial transactions.
• Identity verification providers: Third-party KYC service providers engaged to assist with age and identity verification, operating under strict data processing agreements.
• Technology service providers: Cloud hosting, cybersecurity, and analytics providers who process data on our behalf under binding data processing agreements that prohibit independent use of your data.
• Law enforcement: Where codwin is legally compelled to disclose personal data by a court order, subpoena, or other lawful process.

codwin uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit the codwin website. We use the following types of cookies:

• Strictly necessary cookies: Essential for the platform to function, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences and settings to provide a more personalized experience on codwin.
• Analytics cookies: Help us understand how players use the platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Security cookies: Used to detect and prevent fraudulent activity, protect player accounts, and maintain platform integrity.

You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the codwin platform. For more information, refer to your browser's help documentation.

codwin retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following general retention periods apply:

• Account data: Retained for the duration of your active account, plus a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• Identity verification documents: Retained for the duration of your account plus five (5) years, or longer if required by law.
• Marketing data: Retained until you withdraw your consent or opt out of marketing communications, after which it will be deleted or anonymized within thirty (30) days.
• Technical and usage logs: Retained for up to twelve (12) months for security and fraud prevention purposes, then deleted or anonymized.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with codwin's data disposal procedures.

codwin implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the codwin platform.
• AES-256 encryption for sensitive data stored on codwin servers.
• Multi-factor authentication options for player accounts.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by codwin:

• Right to be informed: The right to know what personal data codwin collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data codwin holds about you.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact codwin's Data Protection Officer using the contact details in Section 13. We will respond to all verified requests within thirty (30) days.

The codwin platform is strictly intended for individuals who are 21 years of age or older. codwin does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

codwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email or through a prominent notice on the codwin platform. The date of the most recent revision is displayed at the top of this page.

Your continued use of the codwin platform following the effective date of any update constitutes your acknowledgment of the revised Policy. We encourage you to review this Policy periodically to stay informed about how codwin protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by codwin, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.