Privacy Policy

1. Who We Are

7winer is an online gaming platform operating at https://7winer.app, providing casino games, slots, bingo, and related entertainment services to players in the Philippines. 7winer acts as the data controller for all personal information collected through the platform, meaning we determine the purposes and means of processing your personal data.

7winer operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC). We are also subject to PAGCOR's data governance requirements as part of our online gaming operations.

2. Personal Data We Collect

7winer collects personal data through several channels, including account registration, identity verification, financial transactions, gameplay activity, and customer support interactions. The categories of personal data we collect include:

2.1 Identity and Contact Information

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (used to verify that you are at least 21 years of age)
• Philippine mobile number and email address
• Residential address in the Philippines (e.g., in Metro Manila, Cebu, Davao, or other regions)
• Government-issued ID details (PhilSys ID, passport, driver's license, SSS/GSIS card, or PRC ID)

2.2 Financial Information

• GCash or PayMaya mobile wallet number
• BPI, BDO, or Metrobank account details (account name and number, for withdrawal verification)
• Deposit and withdrawal transaction history
• Account balance and wagering history

2.3 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, login timestamps, and pages visited on the 7winer platform
• Game activity logs, including games played, bets placed, and outcomes

2.4 Communications Data

• Records of customer support interactions, including live chat transcripts and email correspondence
• Feedback and survey responses submitted through the platform

3. How We Use Your Personal Data

7winer uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your 7winer player account, including processing your registration and verifying your identity.
• Age and Identity Verification (KYC): To verify that you are at least 21 years of age and to confirm your identity as required by PAGCOR regulations and Philippine anti-money laundering laws.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods, and to verify that payment accounts are registered in your name.
• Game Provision: To provide access to 7winer's casino games, slots, bingo, and other gaming products, and to maintain accurate records of your gameplay activity.
• Responsible Gaming: To monitor gameplay patterns for signs of problem gambling, enforce deposit limits and self-exclusion requests, and comply with PAGCOR's responsible gaming requirements.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct on the 7winer platform.
• Legal Compliance: To comply with our obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the 7winer platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may withdraw this consent at any time through your account settings.

4. Legal Basis for Processing

7winer processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you agreed to when registering your 7winer account, including providing gaming services and processing financial transactions.
• Legal Obligation: Processing is required to comply with our obligations under PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws.
• Legitimate Interests: Processing is necessary for 7winer's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your data protection rights.
• Consent: For marketing communications and non-essential cookies, processing is based on your explicit consent, which you may withdraw at any time without affecting the lawfulness of prior processing.

5. Data Sharing and Disclosure

7winer does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to assist with identity verification as required by PAGCOR.
• Game Software Providers: Licensed game developers and content providers whose games are available on the 7winer platform, to the extent necessary to provide gameplay services.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory directive.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other legal process.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and technical support providers engaged by 7winer to operate and secure the platform, subject to strict data processing agreements.

All third-party service providers engaged by 7winer are required to process personal data only in accordance with our instructions and to implement appropriate technical and organizational security measures.

6. Cookies and Tracking Technologies

7winer uses cookies and similar tracking technologies on the platform to enhance your user experience, maintain your session, and analyze platform usage. The types of cookies we use include:

• Essential Cookies: Required for the platform to function correctly, including session management and security features. These cannot be disabled.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the 7winer platform, helping us identify areas for improvement.
• Preference Cookies: Used to remember your platform settings and preferences, such as language and display options.
• Marketing Cookies: Used to deliver relevant promotional content, subject to your consent. You may opt out of marketing cookies through your browser settings or the cookie preference center on the platform.

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies may affect the functionality of the 7winer platform.

7. Data Retention

7winer retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC Records: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• Customer Support Records: Retained for three (3) years from the date of the interaction.
• Marketing Consent Records: Retained until you withdraw your consent, plus one (1) year thereafter for compliance documentation purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 7winer's data disposal procedures.

8. Your Data Protection Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 7winer:

• Right to be Informed: The right to be informed about how your personal data is collected, used, and shared, as described in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data 7winer holds about you, including information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by 7winer.
• Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact 7winer's Data Protection Officer at the contact details provided in Section 13. We will respond to all data rights requests within fifteen (15) business days of receipt.

9. Children's Privacy

The 7winer platform is strictly intended for adults aged 21 years and above, as required by PAGCOR regulations governing online gaming in the Philippines. 7winer does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and return any deposited funds in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that your child has registered on the 7winer platform, please contact our support team immediately at [email protected] so that we can take prompt action.

10. Data Security

7winer implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• AES-256 encryption for all personal data stored on 7winer servers.
• TLS 1.3 encryption for all data transmitted between your device and the 7winer platform.
• Multi-factor authentication requirements for account access and financial transactions.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Continuous monitoring of platform systems for suspicious activity and potential security incidents.
• Regular staff training on data protection obligations and security best practices.

While 7winer takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying 7winer immediately if you suspect unauthorized access to your account.

11. International Data Transfers

7winer's primary data processing operations are conducted within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, for example where cloud infrastructure or game software providers operate servers in other jurisdictions.

Where such transfers occur, 7winer ensures that appropriate safeguards are in place to protect your personal data, including contractual data processing agreements that require overseas recipients to apply data protection standards equivalent to those required under the Philippine Data Privacy Act.

By using the 7winer platform, you consent to the transfer of your personal data to overseas service providers where necessary for the delivery of our services, subject to the safeguards described above.

12. Changes to This Privacy Policy

7winer reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. When material changes are made, we will notify registered players via their registered email address or through a prominent notice on the 7winer platform.

The date of the most recent revision is displayed at the top of this page. Your continued use of the 7winer platform following the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 7winer protects your personal information.

13. Contact and Data Protection Officer

7winer has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact our DPO using the details below:

If you are not satisfied with 7winer's response to your data protection concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through their official channels.