pasawin Privacy Policy

1 Introduction

1.1 pasawin is committed to protecting the privacy and security of the personal data of all players and platform visitors. We recognise that the players who trust us with their personal information — from Manila and Cebu to Davao and beyond — deserve clear, honest answers about how that information is handled.

1.2 pasawin operates as a data controller in respect of personal data collected through the pasawin.vip Platform. This means pasawin determines the purposes for which and the means by which personal data is processed.

1.3 Our data processing activities are governed primarily by Republic Act No. 10173 (Philippine Data Privacy Act of 2012) and its Implementing Rules and Regulations, as overseen by the National Privacy Commission of the Philippines.

1.4 The terms "personal data," "processing," "data subject," and "data controller" used in this Policy carry the meanings given to them under the Philippine Data Privacy Act of 2012.

2 Personal Data We Collect

pasawin collects personal data in the following categories, depending on how you interact with the Platform:

2.1 Registration Data

When you create a pasawin account, we collect your full legal name, date of birth, email address, mobile phone number, and a password of your creation. This data is necessary to create and maintain your account.

2.2 Identity Verification (KYC) Data

To comply with anti-money laundering obligations and verify your age, we collect a copy of a valid government-issued identification document (such as a Philippine passport, driver's license, SSS card, or UMID card) and, where applicable, proof of payment method ownership.

2.3 Financial Data

We collect details necessary to process deposits and withdrawals, including GCash or PayMaya account references, bank account numbers, and transaction records. We do not store full credit or debit card numbers on our servers — card data is processed by our certified payment service providers.

2.4 Gaming Activity Data

We record your gaming history on the Platform, including game sessions, bet amounts, game outcomes, bonus usage, and responsible gaming tool settings. This data is used to provide the service, resolve disputes, and comply with regulatory reporting obligations.

2.5 Technical and Device Data

When you access the Platform, we automatically collect certain technical data including your IP address, device type and operating system, browser type and version, referring URL, pages visited, and session duration. This data is collected via cookies and server logs.

2.6 Communications Data

If you contact pasawin support — via live chat or email — we retain records of that correspondence, including the content of your messages, the date and time of contact, and the resolution provided.

3 How We Use Your Personal Data

pasawin uses personal data collected from players for the following purposes:

pasawin will not use your personal data for any purpose materially different from those listed above without obtaining your prior consent or as otherwise required by law.

4 Legal Basis for Processing

pasawin processes personal data on one or more of the following legal bases as provided under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between pasawin and you, including operating your account, processing transactions, and providing gaming services;
• Legal obligation: Processing is necessary to comply with applicable Philippine laws and regulations, including anti-money laundering legislation, gaming regulations administered by PAGCOR, and the Data Privacy Act;
• Legitimate interests: Processing is necessary for pasawin's legitimate interests in operating a secure, fair, and commercially viable gaming platform — provided those interests are not overridden by your rights and interests;
• Consent: Where processing is not covered by the above bases — for example, sending marketing communications — pasawin will obtain your explicit, informed, and freely given consent before processing begins. You may withdraw consent at any time.

5 Data Sharing & Disclosure

5.1 pasawin does not sell, rent, or trade personal data to third parties for their own commercial purposes.

5.2 pasawin may share personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and card processors — to facilitate deposits and withdrawals;
• Identity verification providers: Certified KYC and document verification service providers — to authenticate player identity and age;
• Game providers: Licensed game studios supplying titles on the pasawin Platform — limited to data necessary to operate the game session and prevent fraud;
• Cloud and infrastructure providers: Hosting and database services used to operate the pasawin Platform — access is strictly controlled and encrypted;
• Legal and regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, and courts — where required by law or lawful order;
• Professional advisers: Legal counsel, auditors, and accountants — under strict professional confidentiality obligations.

6 International Data Transfers

6.1 Some of the third-party service providers used by pasawin may be located in, or process data in, countries outside the Philippines. Where personal data is transferred outside the Philippines, pasawin takes steps to ensure that the transfer complies with the requirements of the Philippine Data Privacy Act.

6.2 Appropriate safeguards for international transfers may include: contractual clauses that impose data protection obligations equivalent to those applicable in the Philippines, transfers to countries determined to have adequate levels of data protection, or other safeguards recognised under Philippine data protection law.

6.3 You may request information about the specific safeguards applied to international transfers of your personal data by contacting pasawin at [email protected].

7 Cookies & Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They are widely used to make websites work efficiently and to provide information to website operators.

7.2 How pasawin Uses Cookies

pasawin uses the following categories of cookies on the Platform:

• Strictly necessary cookies: These are essential to operate the Platform and enable core features such as login session management, account security, and navigation. These cookies cannot be disabled without breaking core platform functionality;
• Performance cookies: These collect anonymised, aggregated data about how players use the Platform — such as which game categories are most visited — to help pasawin improve platform design and performance. No personally identifiable information is collected by these cookies;
• Functional cookies: These remember your preferences — such as language settings and responsible gaming tool configurations — to provide a more personalised experience.

pasawin does not use advertising cookies, cross-site tracking cookies, or cookies that serve third-party advertisements.

7.3 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling strictly necessary cookies may impair or prevent access to certain features of the pasawin Platform. For further guidance on managing cookies, refer to the help documentation provided by your browser.

8 Data Security

8.1 pasawin implements technical and organisational security measures appropriate to the risk associated with processing your personal data. These include:

• 256-bit SSL/TLS encryption for all data in transit between your device and pasawin servers;
• Encryption of sensitive data at rest within our databases;
• Role-based access controls restricting internal access to personal data on a strict need-to-know basis;
• Multi-factor authentication for administrative access to systems containing personal data;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Fraud detection systems that monitor for suspicious login and transaction activity in real time.

8.2 While pasawin takes all reasonable steps to protect your personal data, no internet transmission or electronic storage is completely secure. You are responsible for keeping your pasawin account credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

9 Data Retention

9.1 pasawin retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by law.

9.2 The following retention periods apply as a general guide:

• Account and KYC data: Retained for the duration of your active account plus five (5) years following account closure, to satisfy regulatory and anti-money laundering record-keeping requirements;
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction, consistent with Philippine anti-money laundering law;
• Gaming activity data: Retained for three (3) years from the date of the activity, or longer where required for dispute resolution or regulatory compliance;
• Customer support records: Retained for two (2) years from the date of the last interaction, unless the subject matter involves an ongoing dispute;
• Technical and server log data: Retained for ninety (90) days in identifiable form, after which it may be retained in anonymised aggregate form indefinitely.

9.3 Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised. Where deletion is not immediately technically feasible, the data will be isolated and protected from further processing until deletion can be effected.

10 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by pasawin. To exercise any of these rights, contact us at [email protected].

pasawin will respond to all verified data privacy rights requests within thirty (30) calendar days of receipt. We may request proof of identity before processing a request to protect against unauthorised access to personal data.

11 Children's and Minors' Privacy

11.1 The pasawin Platform is strictly intended for individuals who are 21 years of age or older. pasawin does not knowingly collect personal data from persons under the age of 21.

11.2 Age verification is a mandatory step in the KYC process for all players. Any account found to belong to an individual under 21 will be immediately suspended and all personal data associated with that account will be deleted in accordance with our retention policy, except where retention is required by law.

11.3 If you have reason to believe that a minor has submitted personal data to pasawin, please contact us immediately at [email protected] so that we can take prompt remedial action.

12 Third-Party Links

12.1 The pasawin Platform may contain links to third-party websites or services — for example, links to game provider information pages. pasawin is not responsible for the privacy practices of those third parties.

12.2 We encourage you to review the privacy policies of any third-party websites or services you visit through links on the pasawin Platform. This Policy applies solely to personal data collected through pasawin.vip and pasawin's own services.

13 Amendments to This Policy

13.1 pasawin 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 guidance. The effective date of any revision will be displayed at the top of this Policy.

13.2 Where a change to this Policy is material — meaning it substantially alters your rights or our data processing obligations — pasawin will notify registered players by email and/or prominent notice on the Platform in advance of the change taking effect.

13.3 Your continued use of the pasawin Platform following the effective date of a revised Policy constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the revised Policy, you should cease using the Platform and may request account closure as described in our Terms & Conditions.

14 Contact Us & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way pasawin handles your personal data, please contact our Data Privacy team:

If you are not satisfied with pasawin's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. Information about how to file a complaint with the NPC is available through their official government website.

For responsible gaming concerns — including self-exclusion requests, deposit limit adjustments, or problem gambling support — please visit our Responsible Gaming page.