Privacy Policy

1 Introduction

66winn ("66winn," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the 66winn Platform at https://66winn.net. This Privacy Policy ("Policy") describes how 66winn collects, uses, stores, shares, and protects personal information in connection with your use of our website, mobile applications, and all associated services (collectively, the "Platform").

This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as well as applicable PAGCOR regulatory requirements governing the handling of player data by licensed gaming operators.

By registering a 66winn account or using the Platform in any capacity, 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. If you do not agree to this Policy, please discontinue use of the Platform and contact us to close your account.

2 Data Controller

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

66winn
Platform: https://66winn.net
Contact: [email protected]

66winn has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data privacy laws and handling data subject requests. You may contact the DPO directly at the email address above, marking your correspondence "Attention: Data Protection Officer."

3 Personal Data We Collect

66winn collects the following categories of personal data from players and Platform visitors:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, nationality, government ID number	Account registration, KYC verification, age verification (21+)
Contact Data	Email address, Philippine mobile number, residential address	Account communications, support, regulatory notifications
Financial Data	GCash number, Maya account, bank account details, transaction history	Processing deposits and withdrawals, AML compliance
Gaming Data	Game history, bet amounts, win/loss records, session duration	Service delivery, responsible gaming monitoring, dispute resolution
Technical Data	IP address, device type, browser, operating system, cookies	Platform security, fraud prevention, analytics
Communications Data	Support chat logs, email correspondence, feedback submissions	Customer service, quality assurance, dispute resolution
Marketing Data	Promotion preferences, communication opt-in/opt-out status	Sending relevant offers and updates where you have consented

We collect only the minimum personal data necessary for the purposes described in this Policy. Where data is not strictly required, we will indicate clearly that providing it is optional.

4 How We Collect Your Data

4.1 Data You Provide Directly

The majority of personal data 66winn holds about you is information you provide directly when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a promotion. You are responsible for ensuring that all information you provide to 66winn is accurate, complete, and kept up to date.

4.2 Data Collected Automatically

When you access the 66winn Platform, certain technical data is collected automatically through cookies, web beacons, log files, and similar tracking technologies. This includes your IP address, device identifiers, browser type and version, operating system, referring URLs, pages visited, and session timestamps. This data is used primarily for Platform security, fraud detection, and improving the user experience.

4.3 Data from Third Parties

66winn may receive personal data about you from third-party sources in limited circumstances, including:

• Payment processors (GCash, Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of verifying and processing financial transactions.
• Identity verification service providers engaged to assist with KYC compliance.
• Fraud prevention and anti-money laundering screening services.
• PAGCOR and other regulatory bodies, where required by law.

5 How We Use Your Personal Data

66winn uses the personal data we collect for the following purposes:

• Account Management: Creating, maintaining, and administering your 66winn account, including verifying your identity and age (21+ requirement).
• Service Delivery: Providing access to games, processing deposits and withdrawals, and delivering all features of the 66winn Platform.
• Regulatory Compliance: Meeting our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012, including mandatory record-keeping and reporting requirements.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and other security threats to the Platform.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behavior and administering responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: Responding to your enquiries, resolving disputes, and providing technical assistance.
• Marketing Communications: Sending you promotional offers, bonus notifications, and Platform updates where you have provided your consent to receive such communications.
• Platform Improvement: Analyzing aggregated usage data to improve the performance, features, and user experience of the 66winn Platform.
• Legal Proceedings: Establishing, exercising, or defending legal claims where necessary.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, 66winn processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you — i.e., to provide the gaming services you have registered for, including account management, game access, and financial transactions.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AMLA obligations, and tax reporting requirements.
• Legitimate Interests: Processing necessary for 66winn's legitimate business interests, including fraud prevention, Platform security, and improving our services, where these interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and the use of non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing and Disclosure

7.1 Service Providers

66winn engages trusted third-party service providers to assist in delivering the Platform and its services. These providers are granted access to personal data only to the extent necessary to perform their specific functions and are contractually bound to process data solely on 66winn's instructions and in compliance with applicable data privacy laws. Categories of service providers include payment processors, KYC and identity verification providers, cloud hosting and infrastructure providers, customer support platform providers, and analytics service providers.

7.2 Regulatory and Law Enforcement Disclosure

66winn may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other government authorities where required to do so by applicable Philippine law, court order, or regulatory directive. Such disclosures will be made only to the extent required and will be documented in accordance with our internal data governance procedures.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 66winn's business, personal data held by 66winn may be transferred to the acquiring entity as part of that transaction. In such circumstances, 66winn will notify affected players via their registered email address prior to any transfer of their personal data and will ensure that the receiving entity is bound by privacy obligations no less protective than those set out in this Policy.

7.4 No Sale of Personal Data

66winn does not sell, rent, lease, or otherwise commercially exploit your personal data to third parties for their own marketing or commercial purposes. Any sharing of data is limited strictly to the purposes described in this Policy.

8 Data Retention

66winn retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods mandated by applicable Philippine law and PAGCOR regulations:

• Account and Identity Data: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and AMLA obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA record-keeping requirements.
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session, for dispute resolution and regulatory audit purposes.
• Customer Support Records: Retained for two (2) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing Consent Records: Retained for the duration of your account and for two (2) years following account closure or withdrawal of consent, whichever is later.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 66winn's data disposal procedures.

9 Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 66winn Platform. They allow the Platform to recognize your device, remember your preferences, and provide a more personalized experience. 66winn also uses similar technologies such as web beacons, pixel tags, and local storage objects for related purposes.

9.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. These cookies cannot be disabled without affecting Platform functionality.
• Performance and Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, which pages are visited most frequently, and where errors occur. This data helps us improve Platform performance.
• Functional Cookies: Used to remember your preferences such as language settings, display preferences, and responsible gaming tool configurations.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of 66winn marketing campaigns. These cookies are only placed with your consent.

9.3 Managing Cookies

You can manage or disable non-essential cookies at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the 66winn Platform. Instructions for managing cookies are available in the help documentation of all major browsers.

10 Data Security

66winn implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 66winn Platform.
• Encryption of sensitive data at rest, including financial data and government ID information.
• Role-based access controls ensuring that 66winn staff can only access personal data necessary for their specific job functions.
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 66winn will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012.

11 Your Data Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 66winn:

• Right to be Informed: The right to be informed about how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data 66winn holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• 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 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 your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact the 66winn Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will respond to all verified requests within thirty (30) days of receipt, in accordance with the Data Privacy Act of 2012.

12 Children's Privacy

The 66winn Platform is strictly intended for individuals aged 21 years and above. 66winn does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the 66winn account registration process, and additional KYC verification may be required to confirm a player's age before withdrawal privileges are activated.

If 66winn becomes aware that personal data has been collected from an individual under the age of 21, we will immediately suspend the associated account, delete the personal data in question, and return any deposited funds to the original payment method. If you believe a minor has registered a 66winn account, please contact our support team immediately at [email protected].

13 International Data Transfers

66winn's primary data processing operations are conducted within the Philippines. However, certain service providers engaged by 66winn — including cloud infrastructure providers and technology platform vendors — may process personal data in data centers located outside the Philippines.

Where personal data is transferred outside the Philippines, 66winn ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual data processing agreements incorporating standard contractual clauses approved by the National Privacy Commission, or transfers to jurisdictions that have been assessed as providing an adequate level of data protection.

14 Updates to This Privacy Policy

66winn reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. Where changes are material, we will provide at least fourteen (14) days' advance notice by sending an email to your registered address and/or displaying a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy will be revised each time an amendment is made. We encourage you to review this Policy periodically to stay informed about how 66winn protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Policy.

15 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 66winn, please contact us through the following channels:

• Live Chat: Available 24/7 via the chat widget on the 66winn Platform — the fastest way to reach our support team.
• Email (General Support): [email protected]
• Email (Data Privacy Requests): [email protected] — subject line: "Data Privacy Request" or "Attention: Data Protection Officer"

Our support and data privacy teams are based in the Philippines and are available around the clock. We aim to acknowledge all data privacy requests within five (5) business days and to provide a full response within thirty (30) days, as required by the Data Privacy Act of 2012.

If you are not satisfied with our response to a data privacy request or complaint, you have the right to escalate your concern to the National Privacy Commission (NPC) of the Philippines, the independent regulatory body responsible for enforcing the Data Privacy Act of 2012.