codwin Casino
Privacy Policy

1. Introduction and Scope

This Privacy Policy (the "Policy") describes how codwin Casino, a Philippine online gaming platform operating under PAGCOR License Number COR-12385-2018, collects, uses, processes, discloses, and protects the personal information of users who access our website at https://codwin.cam (the "Website") or use our mobile applications, services, and platforms (collectively, the "Services").

codwin Casino is registered with the National Privacy Commission (NPC) of the Republic of the Philippines under registration number DPP-2018-08547 and operates in full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the NPC.

By creating an account, accessing the Website, or using any of our Services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with any provision of this Policy, you must immediately cease using our Services and refrain from providing us with any personal information.

This Privacy Policy should be read in conjunction with our Terms and Conditions and Responsible Gaming Policy, which form an integral part of your agreement with codwin Casino.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal information is:

codwin Casino
Registered Business Address: Unit 2508, 25th Floor, Joy-Nostalg Center, Ortigas Center, Pasig City, 1605, Metro Manila, Philippines
PAGCOR License Number: COR-12385-2018
NPC Registration Number: DPP-2018-08547
Data Protection Officer: Maria Elena C. Santos
DPO Email: [email protected]
DPO Phone: +63 2 8123-4567 (Mon-Fri, 9:00 AM - 6:00 PM PHT)

Our Data Protection Officer (DPO) is responsible for overseeing our data protection strategy, ensuring compliance with the Data Privacy Act, and serving as the point of contact for data privacy inquiries, complaints, and requests for the exercise of data subject rights.

3. What Data We Collect

codwin Casino collects the following categories of personal information:

3.1 Registration and Account Information

When you create an account with codwin Casino, we collect:

• Personal identification data: Full legal name, date of birth, gender, nationality, place of birth
• Contact information: Email address, mobile phone number, residential address (house number, street, barangay, city, province, postal code)
• Account credentials: Username, password (stored in encrypted form), security questions and answers
• Verification documents: Government-issued identification (passport, driver's license, national ID, UMID, SSS ID, voter's ID), proof of address (utility bills, bank statements), selfie photographs with ID

3.2 Financial and Transaction Data

• Payment information: GCash account details, Maya account details, bank account numbers, cryptocurrency wallet addresses
• Transaction history: Deposit amounts, deposit methods, deposit dates and times, withdrawal amounts, withdrawal methods, withdrawal dates and times, processing fees
• Wagering activity: Bet amounts, game types, bet outcomes (wins/losses), timestamps, jackpot wins, bonus redemptions

3.3 Device and Technical Data

• Device information: IP address, device type and model, operating system and version, browser type and version, screen resolution, device identifiers (IMEI, Android ID, IDFA)
• Usage data: Pages visited, time spent on pages, clickstream data, referral sources, search queries, session duration, game play patterns
• Location data: Approximate geographic location derived from IP address or mobile device GPS (with your consent)

3.4 Communications and Support Data

• Customer support records: Chat transcripts, email correspondence, phone call recordings (with your consent and notification), complaint details, support ticket history
• Marketing preferences: Newsletter subscription status, promotional communication preferences, push notification settings

3.5 Responsible Gaming Data

• Self-exclusion records: Self-exclusion periods, voluntary deposit limits, time-out periods, reality check settings
• Behavioral indicators: Unusual betting patterns, extended play sessions, rapid deposit sequences (used for responsible gaming intervention)

4. How We Collect Your Data

We collect your personal information through the following methods:

4.1 Direct Collection

You provide personal information directly to us when you:

• Register for an account on our Website or mobile application
• Complete identity verification (KYC) procedures
• Make deposits or request withdrawals
• Place bets or play casino games
• Contact customer support via live chat, email, phone, or social media
• Subscribe to our newsletter or promotional communications
• Participate in surveys, contests, or promotional campaigns
• Set responsible gaming limits or request self-exclusion

4.2 Automatic Collection

We automatically collect certain information when you access our Website or use our Services through:

• Cookies and similar technologies: We use cookies, web beacons, pixel tags, and local storage to collect usage data, remember your preferences, and improve your experience
• Server logs: Our web servers automatically record IP addresses, browser types, access times, and pages viewed
• Analytics tools: We use Google Analytics, Hotjar, and proprietary analytics platforms to understand how users interact with our Services
• Mobile device data: Our mobile applications collect device identifiers, operating system version, and app usage data

4.3 Third-Party Sources

In certain circumstances, we may receive personal information about you from third-party sources, including:

• Payment processors: GCash, Maya, Coins.ph, and partner banks provide transaction verification data
• Identity verification services: Third-party KYC providers verify the authenticity of submitted identification documents
• Credit reference agencies: For fraud prevention and AML compliance, we may receive credit and fraud risk assessments
• Social media platforms: If you choose to log in using Facebook or Google, we receive basic profile information you have authorized for sharing
• Affiliate partners: Marketing affiliates may share referral information when you click on a codwin Casino advertisement

5. Purpose of Data Processing

codwin Casino processes your personal information for the following purposes:

Processing Purpose	Categories of Data
Account registration and management	Registration data, contact information, account credentials
Identity verification and KYC compliance	Personal identification data, verification documents, biometric data (selfie)
Processing deposits and withdrawals	Financial data, payment information, transaction history
Providing gaming services	Account information, wagering activity, game play data
Fraud prevention and AML compliance	Transaction history, device data, behavioral indicators, verification documents
Customer support and communication	Contact information, communications data, support records
Responsible gaming protection	Responsible gaming data, wagering patterns, self-exclusion records
Marketing and promotions	Contact information, marketing preferences, usage data
Legal compliance and dispute resolution	All categories of data as required by law or court order
Analytics and service improvement	Device data, usage data, technical data

6. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, codwin Casino processes your personal information based on the following legal grounds:

6.1 Consent

You provide explicit consent when you create an account, accept this Privacy Policy, and opt-in to marketing communications. You may withdraw your consent at any time by contacting our Data Protection Officer.

6.2 Contractual Necessity

Processing is necessary to fulfill our contractual obligations to you under the Terms and Conditions, including providing gaming services, processing transactions, and maintaining your account.

6.3 Legal Obligation

We are legally required to process certain personal information to comply with:

• PAGCOR licensing requirements and regulatory obligations
• Anti-Money Laundering Act (AMLA) and Terrorism Financing Prevention Act
• Philippine Electronic Commerce Act (RA 8792)
• Tax laws and revenue regulations (BIR compliance)
• Court orders, subpoenas, and law enforcement requests

6.4 Legitimate Interests

Processing is necessary for our legitimate business interests, including fraud prevention, security protection, service improvement, and direct marketing, provided that such interests do not override your fundamental rights and freedoms.

7. Data Sharing and Disclosure

codwin Casino does not sell, rent, or trade your personal information to third parties for their marketing purposes. We only share your personal information with third parties in the following limited circumstances:

7.1 Service Providers and Processors

We engage trusted third-party service providers who process personal information on our behalf under strict data processing agreements:

• Payment processors: GCash, Maya, Coins.ph, Philippine banks, cryptocurrency payment gateways
• Identity verification providers: KYC verification services, document authentication platforms
• Cloud hosting providers: AWS Asia Pacific (Singapore), Google Cloud Platform Philippines
• Customer support platforms: Zendesk, Intercom, Telegram Business API
• Marketing and analytics tools: Google Analytics, Facebook Pixel, SendGrid (email delivery)
• Game providers: MG Live, Evolution Gaming, Pragmatic Play, PG Soft

All service providers are contractually obligated to process your personal information only in accordance with our instructions and to implement appropriate security measures.

7.2 Legal and Regulatory Authorities

We may disclose your personal information to government agencies and regulatory bodies when legally required:

• PAGCOR: Licensing compliance, audit requests, regulatory investigations
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports, covered transaction reports
• Bureau of Internal Revenue (BIR): Tax withholding reports, winner documentation for amounts exceeding ₱10,000
• National Privacy Commission (NPC): Compliance audits, data breach notifications
• Law enforcement agencies: Court orders, subpoenas, criminal investigations

7.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the successor entity, subject to the same privacy protections outlined in this Policy. We will notify you via email and website notice before your personal information is transferred and becomes subject to a different privacy policy.

7.4 Fraud Prevention and Security

We may share limited personal information with fraud prevention services, cybersecurity firms, and industry databases to detect and prevent fraudulent activity, money laundering, and account takeover attempts.

8. Data Security Measures

codwin Casino implements industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:

8.1 Technical Security Controls

• Encryption: All data transmissions are protected with 256-bit SSL/TLS encryption (same standard used by Philippine banks)
• Data storage encryption: Personal information stored in our databases is encrypted at rest using AES-256 encryption
• Password security: User passwords are hashed using bcrypt with salt, making them irreversible even in the event of a database breach
• Firewalls and intrusion detection: Multi-layered firewalls, DDoS protection, and real-time intrusion detection systems
• Vulnerability scanning: Regular penetration testing and security audits conducted by independent third-party firms
• Two-factor authentication (2FA): Available to all users for enhanced account security

8.2 Organizational Security Measures

• Access controls: Personal information is accessible only to authorized employees on a need-to-know basis
• Employee training: All staff members receive regular data privacy and security awareness training
• Confidentiality agreements: All employees and contractors sign confidentiality and non-disclosure agreements
• Incident response plan: Documented procedures for detecting, responding to, and reporting data breaches
• Vendor management: Due diligence and security assessments of all third-party service providers

8.3 Data Breach Notification

In the unlikely event of a personal data breach, codwin Casino will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by the Data Privacy Act. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly via email and on-site notification within the same timeframe.

9. Data Retention and Deletion

codwin Casino retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

9.1 Active Account Data

Personal information associated with active accounts is retained for the duration of your account's active status and for five (5) years following account closure, as required by PAGCOR regulations and Anti-Money Laundering compliance.

9.2 Financial Records

Transaction records, deposit and withdrawal history, and financial documentation are retained for ten (10) years from the date of the transaction, in accordance with AMLA record-keeping requirements and BIR tax documentation rules.

9.3 Responsible Gaming Records

Self-exclusion records are retained permanently to ensure that excluded players cannot re-register or access gaming services during their exclusion period. Responsible gaming history is retained for seven (7) years after account closure.

9.4 Dormant Account Deletion

Accounts that have been inactive for twelve (12) consecutive months with a zero balance may be classified as dormant. You will receive notification via email before your account is deleted. Upon deletion, personal information will be anonymized or securely destroyed, except for records that must be retained for legal compliance.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal information:

10.1 Right to Be Informed

You have the right to be informed about the collection, use, processing, and disclosure of your personal information. This Privacy Policy serves as our primary disclosure document.

10.2 Right to Access

You have the right to request access to all personal information we hold about you. You may view and download your account information, transaction history, and communications records through your account dashboard. For additional records, contact our Data Protection Officer.

10.3 Right to Rectification

You have the right to correct inaccurate, incomplete, or outdated personal information. You may update your contact information, residential address, and communication preferences directly in your account settings. For changes to name, date of birth, or other verified information, contact customer support with supporting documentation.

10.4 Right to Erasure (Right to Be Forgotten)

You have the right to request deletion of your personal information when:

• The information is no longer necessary for the purposes for which it was collected
• You withdraw consent and there is no other legal basis for processing
• You object to processing and there are no overriding legitimate grounds
• The information has been unlawfully processed
• Erasure is required to comply with a legal obligation

Please note that this right is not absolute. We may be required to retain certain information to comply with PAGCOR regulations, AMLA requirements, or other legal obligations.

10.5 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes. You may opt-out of marketing communications at any time by clicking the "unsubscribe" link in promotional emails, adjusting notification settings in your account, or contacting customer support.

10.6 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format (CSV or JSON) and to transmit that information to another data controller. You may request a data export through your account settings or by contacting our DPO.

10.7 Right to Lodge a Complaint

If you believe that codwin Casino has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

National Privacy Commission
5th Floor, Philippine International Convention Center (PICC)
Vicente Sotto Street, Pasay City, 1307, Metro Manila
Email: [email protected]
Complaints Hotline: (+63 2) 8234-2228

10.8 Exercising Your Rights

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] or submit a formal request through your account dashboard. We will respond to your request within fifteen (15) days, as required by the Data Privacy Act. For complex requests, we may extend the response period by an additional fifteen (15) days with prior notification.

11. Cookies and Tracking Technologies

codwin Casino uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your user experience, analyze website traffic, and deliver personalized content.

11.1 Types of Cookies We Use

• Essential cookies: Required for website functionality, account login, session management, and security features. These cookies cannot be disabled.
• Performance cookies: Collect anonymous usage statistics to understand how visitors interact with our Website (Google Analytics, Hotjar).
• Functionality cookies: Remember your preferences, language settings, and account preferences to provide a personalized experience.
• Marketing cookies: Track your browsing activity across websites to deliver targeted advertisements and measure campaign effectiveness (Facebook Pixel, Google Ads).

11.2 Cookie Management

You may control cookie preferences through your browser settings or our cookie consent banner. Disabling certain cookies may limit functionality and prevent you from accessing certain features of the Website.

12. Children's Privacy

codwin Casino is strictly for individuals aged 21 years or older. We do not knowingly collect, use, or process personal information from individuals under the age of 21. If you are under 21, do not register an account, deposit funds, or provide any personal information.

If we discover that we have inadvertently collected personal information from an individual under 21, we will immediately delete that information and terminate the associated account. If you believe that we may have collected information from a minor, please contact our Data Protection Officer immediately.

13. International Data Transfers

codwin Casino primarily stores personal information on servers located in the Republic of the Philippines and the Asia-Pacific region (Singapore, Hong Kong). Some of our service providers may process data outside the Philippines, including:

• Cloud hosting providers with data centers in Singapore, Australia, and Japan
• Customer support platforms with servers in the United States and Europe
• Game providers with servers in Malta, Curaçao, and the United Kingdom

When personal information is transferred outside the Philippines, we ensure that adequate safeguards are in place through:

• Data processing agreements with contractual clauses approved by the National Privacy Commission
• Service providers certified under internationally recognized data protection frameworks (ISO 27001, SOC 2)
• Encryption of data in transit and at rest

14. Changes to This Policy

codwin Casino reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. Changes will be effective immediately upon posting to the Website. The "Last Updated" date at the top of this Policy indicates when it was last revised.

Significant changes to this Privacy Policy will be communicated to registered users via email notification and prominent on-site notice. Your continued use of our Services following any changes constitutes acceptance of the revised Policy.

We recommend that you periodically review this Privacy Policy to stay informed about how we protect your personal information.

15. Contact Our Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact our Data Protection Officer:

Data Protection Officer
codwin Casino
Unit 2508, 25th Floor, Joy-Nostalg Center
Ortigas Center, Pasig City, 1605, Metro Manila, Philippines

Email: [email protected]
Phone: +63 2 8123-4567 (Mon-Fri, 9:00 AM - 6:00 PM PHT)
Online Form: Submit a data privacy request through your account dashboard

For general customer support inquiries unrelated to data privacy, please contact our 24/7 customer support team via live chat, email at [email protected], or Facebook Messenger.