krwin Privacy Policy

krwin ("krwin," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the krwin platform, including the website at krwin.one and all associated mobile and digital services (collectively, the "Platform"). This Privacy Policy describes how krwin collects, uses, discloses, stores, and protects your personal information in connection with your use of the Platform.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). By registering an account or using the krwin Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

krwin collects personal data that you provide directly, data generated through your use of the Platform, and data received from third parties in connection with identity verification and payment processing. The categories of personal data we collect include:

2.1 Registration Data

• Full legal name
• Date of birth (for age verification — players must be 21 or older)
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Government-issued identification documents (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys ID)
• Proof of address documents
• Proof of payment method ownership
• Selfie or facial image for identity matching, where required

2.3 Financial Data

• Payment method details (GCash account number, PayMaya account, BPI/BDO/Metrobank account details — stored only to the extent necessary for transaction processing)
• Transaction history, including deposits, withdrawals, and wager records
• Account balance information

2.4 Usage and Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, features used, and time spent on the Platform
• Game history and betting activity
• Session logs and access timestamps

2.5 Communications Data

• Records of your communications with krwin customer support, including live chat transcripts and email correspondence
• Feedback, complaints, and survey responses submitted to krwin

krwin uses the personal data we collect for the following purposes:

• Account creation and management: To register your account, verify your identity, and maintain your account in good standing.
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of krwin Platform services.
• Age and identity verification: To confirm that you meet the minimum age requirement of 21 years and to comply with Know Your Customer (KYC) obligations under applicable Philippine gaming and anti-money laundering regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other prohibited conduct.
• Regulatory compliance: To comply with applicable laws, regulations, and lawful requests from government authorities, including PAGCOR and the National Privacy Commission.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible gaming: To monitor gameplay patterns and enforce responsible gaming tools such as deposit limits and self-exclusion where applicable.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features, performance, and security of the krwin Platform.
• Communications: To send you service-related notifications, account alerts, and, where you have consented, promotional communications about krwin offers and updates.

krwin processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between you and krwin — specifically, to provide the gaming and payment services you have registered to use.
• Legal obligation: Processing is required to comply with applicable laws and regulations, including anti-money laundering obligations, age verification requirements, and regulatory reporting duties.
• Legitimate interests: Processing is necessary for krwin's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — krwin relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

krwin 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 only to the extent necessary for the purposes described in this Privacy Policy:

5.1 Service Providers

krwin engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting providers, and customer support platforms. These providers are contractually bound to process your data only on krwin's instructions and in accordance with applicable data protection laws.

5.2 Regulatory and Law Enforcement Authorities

krwin may disclose your personal data to government agencies, regulatory bodies (including PAGCOR and the NPC), law enforcement authorities, and courts where required by applicable law, court order, or lawful regulatory request.

5.3 Anti-Money Laundering Compliance

In accordance with the Philippine Anti-Money Laundering Act (AMLA) and its amendments, krwin may be required to report certain transactions and disclose player information to the Anti-Money Laundering Council (AMLC) or other competent authorities.

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of krwin's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

krwin retains your personal data for as long as your account remains active and for such additional period as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with applicable gaming and anti-money laundering regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine law.
• KYC documents: Retained for the period required by applicable regulations, typically five (5) years from the end of the business relationship.
• Customer support records: Retained for up to three (3) years from the date of the interaction, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing consent records: Retained until you withdraw consent and for a reasonable period thereafter to demonstrate compliance.

When personal data is no longer required for the purposes for which it was collected and no legal obligation requires its retention, krwin will securely delete or anonymize it.

krwin uses cookies and similar tracking technologies on the Platform to enhance your experience and support Platform operations. The types of cookies we use include:

• Essential cookies: Required for the Platform to function correctly, including session management, authentication, and security features. These cannot be disabled without affecting Platform functionality.
• Preference cookies: Used to remember your settings and preferences, such as language selection and display options.
• Analytics cookies: Used to collect aggregated, anonymized data about how users interact with the Platform, helping krwin identify areas for improvement. This data does not identify you personally.

krwin does not use third-party advertising cookies or cross-site tracking technologies. You may manage cookie preferences through your browser settings; however, disabling essential cookies may impair your ability to use certain features of the Platform.

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

• Right to be informed: The right to know what personal data krwin collects about you and how it is used.
• Right of access: The right to request a copy of the personal data krwin holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to krwin's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact krwin's Data Protection Officer at [email protected]. krwin will respond to verified requests within thirty (30) days, or such longer period as permitted by applicable law.

The krwin Platform is strictly intended for adults aged 21 years and above. krwin does not knowingly collect personal data from persons under the age of 21. If krwin becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended, all associated data will be deleted, and any deposited funds will be returned to the originating payment method.

krwin implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and krwin's servers.
• Encryption of sensitive data at rest, including payment information and identity documents.
• Role-based access controls ensuring that only authorized personnel with a legitimate business need may access personal data.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While krwin takes all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your krwin account credentials and for notifying krwin immediately if you suspect any unauthorized access to your account.

krwin primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or systems located outside the Philippines — for example, cloud infrastructure or identity verification services — krwin ensures that such transfers are subject to appropriate safeguards, including contractual data protection clauses consistent with the requirements of the Philippine Data Privacy Act and NPC regulations.

By using the krwin Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the protections described in this Privacy Policy.

krwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered users via email or an in-Platform notification.

Your continued use of the krwin Platform following the posting of any updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Privacy Policy periodically to stay informed about how krwin protects your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or krwin's data practices, please contact our Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. Information about the NPC and its complaint procedures is publicly available through official Philippine government channels.