hellowin Privacy Policy

1. Who We Are

This Privacy Policy is issued by hellowin ("hellowin," "we," "us," or "our"), the operator of the online gaming platform accessible at hellowin.club ("Platform"). hellowin acts as the Personal Information Controller in respect of the personal data of its registered players and website visitors, as defined under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

hellowin operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and is committed to handling all personal data in a manner that is consistent with the principles of transparency, legitimate purpose, and proportionality as required by Philippine law.

2. Personal Data We Collect

hellowin collects the following categories of personal data from players and visitors:

• Identity Data: Full legal name, date of birth, nationality, government-issued ID number (e.g., PhilSys ID, passport, driver's license, SSS/GSIS number).
• Contact Data: Email address, mobile number, residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, Makati).
• Account Data: Username, encrypted password, account preferences, communication preferences, and security settings.
• Financial Data: GCash account number, PayMaya / Maya account details, bank account information (BPI, BDO, Metrobank, UnionBank, etc.), transaction history, deposit and withdrawal records.
• Gaming Data: Game history, wagering activity, session duration, bonus usage, and responsible gaming tool settings.
• Technical Data: IP address, device type and identifier, browser type and version, operating system, time zone, and platform access logs.
• Usage Data: Pages visited, features used, click-through data, and session recordings (where applicable).
• Communications Data: Records of your correspondence with hellowin's customer support team, including chat logs and email exchanges.

hellowin does not collect sensitive personal information (as defined under the DPA, such as health data, political opinions, or religious beliefs) unless specifically required for responsible gaming or legal compliance purposes, and only with your explicit consent.

3. How We Collect Your Data

hellowin collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing identity verification (KYC), making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-Party Sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering (AML) screening services; payment data from GCash, PayMaya, and banking partners.
• Regulatory Sources: Information received from PAGCOR or other competent Philippine authorities in connection with regulatory compliance obligations.

4. How We Use Your Personal Data

hellowin uses your personal data for the following purposes:

• To create, manage, and maintain your hellowin player account.
• To verify your identity and age (21+ requirement) in compliance with PAGCOR regulations and the DPA.
• To process deposits and withdrawals via GCash, PayMaya, and Philippine bank accounts.
• To deliver the gaming services, bonuses, and promotions you have requested or are entitled to.
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities.
• To comply with our legal and regulatory obligations under Philippine law, including PAGCOR licensing conditions and Anti-Money Laundering Act (AMLA) requirements.
• To provide customer support and respond to your inquiries and complaints.
• To send you service-related communications, including account notifications, security alerts, and policy updates.
• To send you marketing communications about hellowin promotions and new games, where you have consented to receive such communications.
• To analyze Platform usage and improve the hellowin user experience.
• To enforce our Terms & Conditions and other applicable policies.

5. Legal Basis for Processing

hellowin processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you have agreed to, including account management and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AMLA requirements, and tax obligations.
• Legitimate Interests: Processing necessary for hellowin's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications and certain cookie uses. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

hellowin does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only where necessary and lawful:

• Payment Processors: GCash, PayMaya / Maya, and Philippine banking partners, solely to process your financial transactions.
• Identity Verification Providers: KYC and AML service providers engaged to verify your identity and screen for financial crime risks.
• Technology Service Providers: Cloud hosting, platform infrastructure, and customer support software providers operating under strict data processing agreements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law.
• Law Enforcement: Philippine law enforcement agencies, where required by a valid legal order or where disclosure is necessary to prevent or investigate a crime.

All third-party service providers engaged by hellowin are contractually required to process personal data only on hellowin's instructions and in compliance with the Philippine Data Privacy Act.

7. Data Retention

hellowin retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account and identity data is retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR licensing conditions and AMLA record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the last interaction.
• Marketing consent records are retained until you withdraw consent and for a reasonable period thereafter as evidence of consent.

Upon expiry of the applicable retention period, hellowin will securely delete or anonymize your personal data.

8. Data Security

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

• 256-bit SSL/TLS encryption for all data in transit between your device and the hellowin Platform.
• Encryption of sensitive data at rest, including financial information and government ID numbers.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security audits and penetration testing of the Platform's infrastructure.
• Multi-factor authentication options for player accounts.
• Incident response procedures to detect, report, and address personal data breaches in accordance with NPC notification requirements.

While hellowin takes all reasonable steps to protect your data, no method of transmission over the internet is 100% secure. You are responsible for keeping your hellowin login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

9. Cookies & Tracking Technologies

hellowin uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that prevent fraudulent use. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics Cookies: Help us understand how players use the Platform — which pages are most visited, where users encounter issues, and how we can improve the overall experience. Data collected is aggregated and anonymized.
• Marketing Cookies: Used to deliver relevant hellowin promotions and measure the effectiveness of our campaigns. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the hellowin Platform.

10. Your Rights as a Data Subject

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

• Right to be Informed: The right to know whether hellowin holds personal data about you and to receive clear information about how it is processed.
• Right of Access: The right to obtain a copy of your personal data held by hellowin and information about how it is used.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or completed.
• Right to Erasure / Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, or where processing is unlawful.
• Right to Object: The right to object to the processing of your personal data, including for direct marketing purposes.
• Right to Data Portability: The right to receive 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 privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days in accordance with NPC guidelines.

11. Children's Privacy

The hellowin Platform is strictly intended for persons aged 21 years and above in accordance with Philippine law and PAGCOR regulations. hellowin does not knowingly collect personal data from individuals under the age of 21.

If hellowin becomes aware that personal data has been collected from a person under 21, we will immediately suspend the relevant account, delete the data, and report the matter to the appropriate authorities where required. If you believe a minor has registered on the hellowin Platform, please contact us immediately at [email protected].

12. International Data Transfers

hellowin primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines (for example, cloud hosting services), hellowin ensures that such transfers are conducted in compliance with the Philippine Data Privacy Act, including by implementing appropriate safeguards such as data processing agreements that incorporate the NPC's standard contractual clauses or equivalent protections.

hellowin will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

13. Changes to This Privacy Policy

hellowin 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 by email or through a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the hellowin Platform following the posting of an updated Privacy Policy constitutes your acknowledgment of the changes. We encourage you to review this page periodically to stay informed about how hellowin protects your personal data.

14. Contact Us & Data Protection Officer

hellowin has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact:

• Data Protection Officer: [email protected]
• General Support: [email protected]
• Support Hours: 24 hours a day, 7 days a week
• Response Time: Within 30 days for data subject rights requests; within 24 hours for general inquiries

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have not been respected.