Privacy Policy

winspire (accessible at winspire.asia) is operated by the Operator as the data controller responsible for the personal data of Players collected through the winspire platform. The Operator is licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR) and operates in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations.

References to "winspire," "we," "us," or "our" in this Privacy Policy refer to the Operator. References to "you," "your," or "the Player" refer to any individual whose personal data is processed in connection with the use of the winspire platform.

winspire collects personal data from Players through multiple channels, including account registration, identity verification, platform usage, payment processing, and support interactions. The categories of personal data we collect include:

winspire does not knowingly collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. We do not collect biometric data beyond photographs submitted for KYC purposes.

winspire processes personal data only for lawful, legitimate purposes directly connected to the operation of the platform and the fulfilment of regulatory obligations. Specific purposes include:

• Account creation and management: Creating and maintaining your winspire account, verifying your identity, and enforcing the one-account-per-player policy.
• Age and eligibility verification: Confirming that you meet the minimum age requirement of 21 years and are located in a permitted jurisdiction.
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, and maintaining transaction records.
• Regulatory compliance: Fulfilling PAGCOR licensing obligations, anti-money laundering (AML) screening, and Know Your Customer (KYC) requirements under applicable Philippine law.
• Platform security: Detecting and preventing fraud, unauthorized access, account takeovers, and other security threats to the winspire platform.
• Customer support: Responding to queries, resolving disputes, and maintaining records of support interactions.
• Responsible gaming: Monitoring gaming activity to identify patterns consistent with problem gambling and administering self-exclusion tools.
• Platform improvement: Analysing aggregated, anonymised usage data to improve game offerings, user experience, and platform performance.
• Marketing communications: Sending promotional offers and platform updates to Players who have consented to receive such communications. Consent may be withdrawn at any time.

winspire processes personal data on the following lawful grounds under the Data Privacy Act of 2012:

• Contractual necessity: Processing necessary to perform the agreement between winspire and the Player, including account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AML obligations under Republic Act No. 9160 (Anti-Money Laundering Act), and other applicable Philippine statutes.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by the Player's privacy rights.
• Consent: Processing for direct marketing communications, where the Player has provided explicit, freely given consent. Consent can be withdrawn at any time without affecting the lawfulness of prior processing.

winspire does not sell, rent, or trade personal data to third parties for their own marketing purposes. Personal data may be shared with the following categories of recipients solely to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash (Mynt/Globe Fintech), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers used to verify government-issued identification documents as required by PAGCOR.
• Game software providers: Game developers and platform providers (including JILI, PG Soft, Pragmatic Play, and others) to the extent required to deliver gaming services, subject to data processing agreements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or court order.
• IT and infrastructure providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged by winspire, operating under data processing agreements that restrict use to winspire's instructions.

All third-party service providers engaged by winspire are contractually required to maintain the confidentiality and security of personal data and to process such data only in accordance with winspire's instructions and applicable law.

winspire uses cookies and similar tracking technologies to operate the platform effectively. Cookies serve the following functions:

• Essential cookies: Required for the platform to function, including session management, login state, and security verification. These cannot be disabled without impairing platform functionality.
• Analytics cookies: Used to collect aggregated, anonymised data about how Players navigate and use the winspire platform, enabling us to improve performance and user experience.
• Preference cookies: Used to remember your settings and preferences, such as language and display options, across sessions.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your access to winspire's core gaming services but may limit certain personalization features.

winspire retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Retention periods are as follows:

• Account data and transaction records: Retained for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and AML regulations.
• KYC identity documents: Retained for a minimum of five (5) years following account closure.
• Support and communications records: Retained for three (3) years following resolution of the relevant inquiry or dispute.
• Technical and usage logs: Retained for up to twelve (12) months, after which they are anonymised or deleted.
• Marketing consent records: Retained for as long as the Player maintains an active winspire account, and for three (3) years after consent is withdrawn, for compliance demonstration purposes.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents identification of the individual.

winspire implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the winspire platform.
• Encrypted storage of sensitive personal data including passwords (which are stored in hashed form and are never accessible to winspire staff in plain text).
• Role-based access controls limiting staff access to personal data to those with a legitimate operational need.
• Regular security audits and penetration testing of platform infrastructure.
• Incident response procedures for detecting, containing, and reporting personal data breaches to the National Privacy Commission within 72 hours of discovery, where required.

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

• Right to be informed: The right to be notified of the collection and processing of your personal data, as set out in this Privacy Policy.
• Right of access: The right to obtain a copy of the personal data winspire holds about you and information about how it is used.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected. You may update most account information directly through your winspire account settings.
• Right to erasure: The right to request deletion of your personal data, subject to applicable retention obligations under PAGCOR regulations and the AML Act.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes. Objection to marketing will not affect your ability to use the winspire platform.
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your privacy rights have been violated.

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

The winspire platform is strictly intended for individuals aged 21 years and above. winspire does not knowingly collect personal data from individuals below the age of 21. If we become aware that personal data has been collected from a person below the minimum age, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has accessed the winspire platform or provided personal data, please contact us immediately at the address in Section 13.

Some of winspire's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to a foreign country, winspire ensures that such transfers are subject to appropriate safeguards consistent with the Data Privacy Act of 2012, including contractual data processing agreements that require the recipient to maintain data protection standards equivalent to those applicable in the Philippines.

winspire will not transfer personal data to jurisdictions that do not provide adequate data protection standards unless additional contractual safeguards are in place and NPC approval has been obtained where required.

winspire reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Material changes will be communicated to registered Players via email or in-platform notification at least seven (7) days before taking effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the winspire platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by winspire, please contact us through the following channel:

Email: [email protected]

Live Chat: Available 24/7 within the winspire platform. Filipino and English-speaking agents.

winspire's Data Protection Officer is available to handle privacy-specific inquiries and will respond to verified requests within thirty (30) calendar days of receipt. For complaints that remain unresolved, you may escalate to the National Privacy Commission of the Philippines through their official government channels.