CodeWin Privacy Policy —
How We Handle Your Data in the Philippines

01Introduction

CodeWin takes the privacy and security of its players seriously. This Privacy Policy explains how CodeWin collects, uses, stores, and protects the personal information of individuals who access or use the CodeWin platform, including our website and any associated mobile services.

This policy is written in plain language because we believe Filipino players deserve to understand what happens with their data — not wade through pages of incomprehensible legal language just to find out something basic. If you ever have a question that this document doesn't answer clearly enough, our support team is available around the clock.

CodeWin processes personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission (NPC). By registering an account or continuing to use the CodeWin platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

02Data We Collect

CodeWin collects only the personal data that is necessary for the lawful operation of the platform, including registration, identity verification, transaction processing, fraud prevention, and customer support. The categories of personal data we collect include:

03How We Collect Your Data

CodeWin collects personal data through the following channels:

Direct Collection

Most of your personal data is collected directly from you when you register for a CodeWin account, complete identity verification, make a deposit or withdrawal, contact customer support, or participate in promotions. You always know when you're providing data because you're the one entering it.

Automated Collection

When you browse or use the CodeWin platform, certain technical and usage data is collected automatically through cookies, server logs, and similar technologies. This includes your IP address, device identifiers, and information about how you interact with the platform. See Section 6 for more about cookies and how to manage them.

Third-Party Sources

In some cases, CodeWin may receive personal data about you from third parties, including:

• Payment service providers such as GCash and Maya, who share transaction confirmation data.
• Identity verification service providers used during the KYC (Know Your Customer) process.
• Fraud detection and risk management partners who may flag suspicious activity linked to your details.

04How We Use Your Data

CodeWin uses personal data only for lawful, specified, and legitimate purposes. The main ways we use your data include:

• Account creation and management: Processing your registration, verifying your identity, and maintaining your CodeWin account.
• Transaction processing: Handling deposits, withdrawals, and bet settlements in Philippine Peso through your chosen payment channel.
• Legal and regulatory compliance: Meeting obligations under applicable Philippine laws, including anti-money laundering (AML) requirements and PAGCOR regulations where applicable.
• Fraud prevention and security: Monitoring account activity to detect and prevent fraud, collusion, multi-accounting, and other prohibited activities.
• Responsible gaming: Monitoring wagering patterns to identify signs of problem gambling and applying responsible gaming tools where appropriate.
• Customer support: Using your account and communication history to resolve disputes, answer questions, and provide technical assistance.
• Marketing communications: Sending you information about promotions, bonuses, and updates relevant to your CodeWin account, if you have opted in or where permitted by applicable law. You can opt out at any time.
• Platform improvement: Analysing aggregated usage data to improve the CodeWin platform, fix issues, and develop new features.

05Who We Share Your Data With

CodeWin does not sell your personal data. We share personal data with third parties only when necessary to operate the platform, comply with legal obligations, or protect our legitimate interests. Categories of recipients include:

Payment Service Providers

To process deposits and withdrawals, CodeWin shares necessary transaction data with payment providers such as GCash, Maya, GrabPay, and partner banks (BDO, BPI, UnionBank). These providers process data under their own privacy policies and are subject to applicable financial data protection obligations.

Identity Verification Providers

During the KYC verification process, CodeWin may share identity documents with accredited verification service providers. These providers are contractually bound to use the data only for verification purposes and to maintain appropriate security standards.

Fraud Prevention and Security Partners

CodeWin works with fraud detection services to identify suspicious activity. These services may receive technical data such as device identifiers and IP addresses to perform risk assessments.

Regulatory and Legal Authorities

CodeWin may disclose personal data to Philippine government agencies, law enforcement, or regulatory bodies when required by law, court order, or regulatory instruction. This includes reporting obligations under anti-money laundering regulations.

IT Infrastructure and Cloud Providers

CodeWin uses reputable cloud infrastructure and technology service providers to host and operate the platform. These providers access data only in the course of providing technical services and are subject to strict data processing agreements.

06Cookies & Tracking Technologies

The CodeWin platform uses cookies and similar tracking technologies to provide core functionality, improve the user experience, and analyse platform performance. Here's a breakdown of what we use and why:

Essential Cookies

These cookies are required for the platform to function. They keep you logged in between pages, maintain your session, and enable security features. These cannot be disabled without breaking the platform's functionality.

Performance and Analytics Cookies

CodeWin uses analytics tools to understand how players use the platform — which pages are most visited, where sessions end, and how different features are used. This data is aggregated and anonymised where possible, and it's used solely to improve the CodeWin experience.

Functional Cookies

Functional cookies remember your preferences — such as language settings or your last viewed section — so you don't have to reconfigure things every time you visit.

Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Most browsers allow you to block third-party cookies or clear all cookies for a specific site. Note that disabling essential cookies will affect your ability to use the CodeWin platform normally. Instructions for managing cookies vary by browser — check your browser's help section for specific guidance.

07Data Retention

CodeWin retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account data: Retained for the duration of your account and for a minimum of five years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction records: Retained for a minimum of five years following the date of each transaction, as required under Philippine AML regulations.
• KYC documentation: Retained for the period required by applicable law, typically five years after the end of the business relationship.
• Communication and support logs: Retained for up to three years to assist with dispute resolution and service quality monitoring.
• Technical and usage data: Typically retained for up to 24 months, after which it is aggregated, anonymised, or deleted.

When personal data is no longer required and no legal obligation requires its retention, CodeWin will securely delete or anonymise it. Players may also request earlier deletion of certain data — see Section 9 for details on your rights.

08Data Security

CodeWin implements technical and organisational security measures appropriate to the risk level of the data being processed. Our security practices include:

• SSL/TLS Encryption: All data in transit between your device and CodeWin servers is encrypted using SSL/TLS protocols.
• Encrypted Storage: Sensitive data — including financial information and identity documents — is encrypted at rest in our databases.
• Access Controls: Personal data is accessible only to CodeWin personnel who require it to perform their role, and only through role-based access systems with audit logging.
• Two-Factor Authentication: CodeWin supports two-factor authentication on player accounts to reduce the risk of unauthorised access.
• Regular Security Reviews: Our systems undergo periodic security assessments and vulnerability testing to identify and remediate weaknesses before they can be exploited.
• Incident Response: In the event of a data breach that may affect your rights and freedoms, CodeWin will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act and NPC rules.

09Your Rights as a Data Subject

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

To exercise any of these rights, please contact our Data Protection Officer (DPO) using the details in Section 12. CodeWin will respond to valid requests within the timeframes required by the Data Privacy Act. We may need to verify your identity before processing a request to protect against unauthorised access to your data.

If you believe your data privacy rights have been violated, you have the right to file a complaint directly with the National Privacy Commission of the Philippines.

10Minors

The CodeWin platform is strictly for individuals who are 21 years of age or older. CodeWin does not knowingly collect personal data from anyone under the age of 21. During registration, we require date of birth information and conduct age verification checks.

If CodeWin becomes aware that personal data has been collected from an individual who is under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the CodeWin platform, please contact our support team immediately.

11Changes to This Privacy Policy

CodeWin may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or regulatory requirements. When we make significant changes, we will notify registered players by email and/or by displaying a prominent notice on the platform before the changes take effect.

The date of the most recent revision is shown at the top of this page. We encourage you to review this policy periodically so you remain informed about how we handle your data. Your continued use of the CodeWin platform following any updates constitutes acceptance of the revised Privacy Policy.

12Contact Us & Data Protection Officer

If you have any questions about this Privacy Policy, want to exercise your data subject rights, or need to report a privacy concern, please contact CodeWin's Data Protection Officer:

• Email: privacy@codewin.best
• General Support: support@codewin.best
• Live Chat: Available 24/7 within the CodeWin platform

We aim to acknowledge all data privacy enquiries within 72 hours and to resolve substantive requests within the timeframes specified under the Data Privacy Act.

For complaints that cannot be resolved directly with CodeWin, you may escalate to the National Privacy Commission (NPC) of the Philippines through the NPC's official complaint process.