solowin Privacy Policy

2. Data We Collect

solowin collects the following categories of personal data from players and users of the platform:

2.1 Identity & Contact Information

• Full legal name (as it appears on your government-issued ID)
• Date of birth (for age verification — 21+ requirement)
• Philippine mobile number
• Email address
• Residential address (province, city/municipality)
• Government-issued ID details (e.g., PhilSys ID, passport, driver's license number)

2.2 Financial Information

• GCash or Maya account details (mobile number linked to e-wallet)
• Bank account details (for bank transfer transactions — BPI, BDO, Metrobank, UnionBank, etc.)
• Debit card details (card number, expiry — processed securely via payment gateway)
• Transaction history (deposits, withdrawals, amounts, dates)

2.3 Gaming Activity Data

• Game history (games played, bets placed, outcomes, winnings)
• Session data (login times, session duration, device used)
• Bonus and promotion usage history
• Responsible gaming settings (deposit limits, self-exclusion status)

2.4 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookies and similar tracking technologies (see Section 7)
• Platform interaction logs and clickstream data

2.5 Communications Data

• Customer support chat transcripts and email correspondence
• Survey responses and feedback submissions
• Marketing preferences and communication opt-in/opt-out status

3. How We Collect Your Data

solowin collects your personal data through the following means:

• Account Registration: When you create a solowin account, you directly provide identity and contact information.
• KYC Verification: When you submit identity documents for account verification, we collect the information contained in those documents.
• Deposits & Withdrawals: Financial data is collected when you initiate transactions on the solowin platform.
• Gameplay: Gaming activity data is automatically recorded as you use the solowin platform.
• Customer Support: When you contact solowin support via chat or email, we collect the information you provide in those communications.
• Cookies & Tracking Technologies: Technical and device data is collected automatically when you visit solowin.app (see Section 7).
• Third-Party Verification Services: solowin may receive data from identity verification and fraud prevention service providers as part of the KYC process.

4. How We Use Your Data

solowin uses your personal data for the following purposes:

solowin does not use your personal data for any purpose not listed above without first obtaining your explicit consent, except where required by applicable Philippine law or PAGCOR regulations.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, solowin processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — i.e., to provide the solowin gaming platform, process transactions, and manage your account.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself.
• Legitimate Interests: Processing is necessary for solowin's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights.
• Consent: For marketing communications and non-essential cookies, solowin processes your data based on your explicit consent. You may withdraw this consent at any time.

6. Sharing Your Data

solowin 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:

6.1 Regulatory Authorities

solowin is required to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities as required by law. This includes transaction records, identity information, and gaming activity data where legally mandated.

6.2 Payment Service Providers

To process your deposits and withdrawals, solowin shares necessary financial data with regulated Philippine payment service providers, including GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, and others). These providers are bound by their own privacy policies and Philippine financial regulations.

6.3 Identity Verification Providers

solowin uses third-party KYC and identity verification service providers to assist with age verification and fraud prevention. These providers process your identity data solely for verification purposes and are contractually bound to handle it in accordance with the Philippine Data Privacy Act.

6.4 Technology and Platform Providers

solowin works with game software providers, cloud hosting services, and platform technology partners who may process your data as part of delivering the solowin service. All such providers are subject to data processing agreements that require them to protect your data in accordance with applicable law.

6.5 Legal and Law Enforcement

solowin may disclose your personal data to law enforcement agencies, courts, or other government bodies where required by law, court order, or to protect the rights, property, or safety of solowin, its players, or the public.

7. Cookies & Tracking

solowin uses cookies and similar tracking technologies on solowin.app to enhance your experience, maintain your session, and analyze platform usage. The following types of cookies are used:

• Essential Cookies: Required for the solowin platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences (e.g., language, game settings) to personalize your solowin experience.
• Analytics Cookies: Help solowin understand how players use the platform so we can improve our services. Data collected is aggregated and anonymized where possible.
• Marketing Cookies: Used to deliver relevant promotions and offers to you, based on your activity on solowin. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the solowin platform. For marketing cookies, you may withdraw your consent at any time through your account settings.

8. Data Retention

solowin retains your personal data for as long as necessary to fulfill the purposes for which it was collected, and as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account and Identity Data: Retained for a minimum of 5 years after account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Financial Transaction Records: Retained for a minimum of 5 years in compliance with AMLA and BIR requirements.
• Gaming Activity Data: Retained for 3 years after the relevant gaming session, or longer if required for dispute resolution or regulatory purposes.
• Customer Support Records: Retained for 2 years after the resolution of the relevant support interaction.
• Marketing Data: Retained until you withdraw your consent or request deletion, whichever comes first.

After the applicable retention period, solowin will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

9. Data Security

solowin implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and solowin.app
• Encryption of sensitive data at rest, including financial account details and government ID information
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular security audits and vulnerability assessments of the solowin platform
• Two-factor authentication (2FA) options for player accounts
• Secure, access-controlled data centers for all solowin infrastructure
• Staff training on data privacy and security obligations under the Philippine Data Privacy Act

While solowin takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your solowin login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

10. Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by solowin:

• Right to be Informed: You have the right to know what personal data solowin collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right to Access: You may request a copy of the personal data solowin holds about you at any time.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data solowin holds about you.
• Right to Erasure / Right to be Forgotten: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to solowin's legal retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to applicable legal grounds.
• Right to Data Portability: You may request that solowin provide your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: If you believe solowin has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Minors

The solowin platform is strictly intended for individuals aged 21 years and above, in compliance with Philippine law and PAGCOR regulations governing online gambling. solowin does not knowingly collect personal data from individuals under the age of 21.

If solowin discovers that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data, and return any deposited funds in accordance with applicable regulations.

If you are a parent or guardian and believe that your child under 21 has provided personal data to solowin, please contact us immediately at the details in Section 14 so we can take appropriate action.

12. Third-Party Links

The solowin platform may contain links to third-party websites or services (for example, payment provider portals). solowin is not responsible for the privacy practices of these third-party sites. We encourage you to review the privacy policies of any third-party sites you visit through links on solowin.app.

This Privacy Policy applies solely to personal data collected and processed by solowin through the solowin.app platform and its associated services.

13. Policy Changes

solowin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, solowin will notify registered players via email or an in-platform notification, and will post the updated Privacy Policy on this page with a revised "Last Updated" date.

Your continued use of the solowin platform after any amendments have been posted constitutes your acknowledgment of the updated Privacy Policy. If you do not agree to the revised Privacy Policy, you must stop using the platform and may request account closure by contacting our support team.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or solowin's handling of your personal data, please contact our Data Protection Officer:

You also have 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. The NPC can be reached through their official government channels.