wonph Privacy Policy

1 Introduction

wonph ("wonph," "we," "us," or "our") is committed to protecting and respecting the privacy of all players and visitors who access the wonph online gaming platform at wonph.net (the "Platform"). This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by wonph.

This Policy is drafted in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and the guidelines and circulars issued by the National Privacy Commission (NPC). It also reflects wonph's obligations under applicable PAGCOR regulations concerning player data management and anti-money laundering record-keeping.

We encourage you to read this Privacy Policy in full. If you have questions about any part of it, you are welcome to contact wonph's Data Protection Officer at any time using the contact details provided in Section 14 of this Policy.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, wonph is the Personal Information Controller in respect of personal data collected through the Platform. This means wonph determines the purposes for which, and the manner in which, your personal data is processed.

wonph has appointed a designated Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and all applicable Philippine data protection laws. If you wish to exercise any of your data rights or raise a concern about wonph's data practices, you may contact the DPO using the details set out in Section 14 below.

3 Personal Data We Collect

3.1 Data You Provide Directly

When you register for a wonph account, complete KYC verification, make a deposit or withdrawal, or contact our support team, you may provide us with the following categories of personal data:

• Identity data: Full legal name, date of birth, gender, nationality, and government-issued ID details (e.g., Philippine National ID, passport, driver's licence, SSS/GSIS card number).
• Contact data: Email address, mobile number, and residential address (including barangay, city, province, and ZIP code).
• Financial data: GCash or Maya account numbers, bank account details (BPI, BDO, Metrobank), and transaction history on the wonph platform.
• Account credentials: Username and encrypted password (wonph never stores passwords in plain text).
• Communications data: Records of your live chat sessions, email correspondence, and support tickets with the wonph team.

3.2 Data Collected Automatically

When you access the wonph Platform, we automatically collect certain technical and behavioural data, including:

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and time zone.
• Usage data: Pages visited, games played, session duration, bet history, wagering patterns, and login timestamps.
• Cookie and tracking data: Session cookies, preference cookies, and analytics data as described in Section 7 of this Policy.

3.3 Data from Third Parties

In certain circumstances, wonph may receive personal data about you from third-party sources, including payment service providers (such as GCash, Maya, and partner banks), KYC verification partners, fraud prevention and AML screening services, and PAGCOR or other regulatory bodies where required by law.

4 How We Use Your Personal Data

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

wonph does not use your personal data for any purpose that is incompatible with those listed above without first seeking your consent or establishing a new lawful basis for the processing.

5 Legal Basis for Processing

wonph processes your personal data on the following legal grounds as recognised under the Data Privacy Act of 2012:

• Contractual necessity: Processing that is required to perform our contract with you — specifically, to operate your wonph account, process your transactions, and deliver the gaming services you have requested.
• Legal obligation: Processing required to comply with wonph's obligations under Philippine law, including PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160 as amended), and the Data Privacy Act of 2012.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for optional purposes such as direct marketing, personalised promotional offers, and non-essential cookies, where wonph has obtained your prior, freely-given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

6.1 Service Providers

wonph engages trusted third-party service providers who process personal data on our behalf, strictly for the purposes described in this Policy. These include payment processors (GCash, Maya, BPI, BDO, Metrobank, InstaPay), KYC and identity verification providers, fraud detection and AML screening services, cloud hosting and infrastructure providers, and customer support platform operators. All such providers are bound by data processing agreements that prohibit them from using your data for any purpose other than providing the contracted service to wonph.

6.2 Regulatory and Legal Disclosure

wonph may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), law enforcement agencies, or courts of competent jurisdiction where such disclosure is required by applicable Philippine law, a lawful court order, or a legitimate regulatory directive. wonph will notify affected players of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of wonph's business, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and the identity of the new data controller through a prominent notice on the wonph Platform.

6.4 No Sale of Data

wonph does not sell, rent, lease, or otherwise commercially exploit your personal data to any third party for their own independent marketing or business purposes. This commitment is unconditional and applies regardless of whether you are an active or inactive wonph player.

7 Cookies & Tracking Technologies

7.1 Types of Cookies We Use

The wonph Platform uses the following categories of cookies:

• Strictly necessary cookies: Required for the wonph Platform to function. These include session authentication cookies that keep you logged in, security tokens, and load-balancing cookies. These cannot be disabled.
• Preference cookies: Store your chosen settings such as language preference, display theme, and game lobby filters so you do not have to reconfigure them on each visit.
• Analytics cookies: Help wonph understand how players interact with the Platform — which pages are visited most, where players encounter errors, and how the gaming lobby can be improved. Analytics data is aggregated and does not personally identify individual players.

7.2 What We Do Not Use

wonph does not deploy third-party advertising cookies, cross-site tracking pixels, social media tracking tags, or any other technology designed to monitor your behaviour across websites outside of wonph.net. The wonph Platform is a closed gaming environment, and our cookie use reflects that focus.

7.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will impair the functionality of the wonph Platform and may prevent you from accessing certain features, including your account dashboard and the cashier.

8 Data Retention

wonph retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

Upon expiry of the applicable retention period, wonph will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9 Data Security

wonph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS 1.2 and above) encryption for all data in transit between your device and wonph servers.
• AES-256 encryption for sensitive data at rest, including payment credentials and government ID records.
• Strict role-based access controls ensuring that only authorised wonph personnel with a documented business need can access player personal data.
• Regular penetration testing and vulnerability assessments conducted by qualified third-party security professionals.
• Comprehensive audit logging of all access to player data systems, with automated alerts for anomalous access patterns.
• Multi-factor authentication (MFA) enforced for all wonph staff accounts with access to personal data systems.
• Incident response procedures that include mandatory notification to affected players and the National Privacy Commission in the event of a data breach involving personal data, in compliance with the NPC Circular on Personal Data Breach Management.

While wonph employs robust security measures, no online platform can guarantee absolute security. You are responsible for keeping your wonph login credentials confidential and for notifying wonph support immediately if you suspect unauthorised access to your account.

10 Your Data Rights

Under the Data Privacy Act of 2012 (RA 10173) of the Philippines, you have the following rights with respect to your personal data held by wonph:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, which this Privacy Policy fulfils.
• Right of access: You may request a copy of the personal data wonph holds about you, together with information about how it is processed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data held in your wonph account, either through your account settings or by contacting our support team.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to wonph's legal retention obligations under Philippine law.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to object: You may object to processing based on legitimate interests or for direct marketing purposes. Where processing is for direct marketing, wonph will cease such processing immediately upon receipt of your objection.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.
• Right to lodge a complaint: If you believe wonph has processed your personal data in violation of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please contact wonph's Data Protection Officer using the details in Section 14. wonph will respond to all verified data rights requests within fifteen (15) calendar days of receipt, as required by NPC regulations.

11 Children's Privacy & Age Restriction

As part of the wonph registration process, all players are required to declare that they are at least 21 years of age. wonph's KYC verification process, which involves the submission of government-issued photo identification, provides a further layer of age assurance. Accounts found to belong to individuals under the age of 21 will be immediately suspended, all associated personal data will be deleted (to the extent permitted by law), and any funds held in the account will be handled in accordance with PAGCOR's guidelines on underage gambling.

If wonph becomes aware that it has inadvertently collected personal data from a person under 21 years of age, it will take immediate steps to delete such data without undue delay. If you have reason to believe that a person under 21 has registered on the wonph Platform, please notify us immediately at the contact details in Section 14.

12 International Data Transfers

wonph primarily stores and processes player data within the Philippines. Where wonph engages service providers or infrastructure partners whose systems are located outside of the Philippines — for example, cloud hosting providers or KYC verification services — any transfer of personal data outside the Philippines will be conducted in accordance with Section 21 of the Data Privacy Act of 2012 and the NPC's rules on cross-border data flows.

Specifically, wonph will only transfer personal data to a recipient in a foreign jurisdiction where: (a) the recipient country provides an adequate level of protection for personal data as determined by the NPC; (b) appropriate safeguards are in place, such as standard contractual clauses or binding corporate rules approved by the NPC; or (c) the transfer is necessary for the performance of your wonph account agreement or for the implementation of pre-contractual measures taken at your request.

You may request further information about the safeguards wonph has in place for international data transfers by contacting the Data Protection Officer.

13 Updates to This Privacy Policy

wonph may update this Privacy Policy from time to time to reflect changes in our data practices, updates to Philippine privacy law, new regulatory guidance from the NPC or PAGCOR, or the introduction of new platform features that affect how we process personal data.

When material changes are made to this Privacy Policy, wonph will notify registered players by email, via an in-platform notification, or by displaying a prominent notice on the wonph website at least seven (7) days before the changes take effect. The "Last Updated" date at the top of this Policy will be revised accordingly.

Your continued use of the wonph Platform after a revised Privacy Policy has taken effect constitutes your acknowledgement of and agreement to the updated terms. If you do not agree with any material change to this Policy, you should stop using the Platform and may request account closure in accordance with Section 13.2 of the wonph Terms and Conditions.

14 Contact Us & Data Rights Requests

If you have any questions about this Privacy Policy, wish to exercise any of your data rights under the Data Privacy Act of 2012, or wish to raise a concern about how wonph handles your personal data, please contact wonph's Data Protection Officer through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week through the wonph Platform. Support agents are available in both Filipino and English.
• Email: [email protected] — please include "Data Rights Request" or "Privacy Enquiry" in the subject line so we can route your message to the DPO promptly.

wonph aims to acknowledge all data rights requests within three (3) business days and to resolve them within fifteen (15) calendar days, in line with NPC guidelines. Where a request is complex or voluminous, wonph will notify you of any extension to this timeframe.

If you are not satisfied with wonph's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (privacy.gov.ph).