shewin Casino
Privacy Policy

1. Introduction

1.1 This Privacy Policy applies to all personal information collected by shewin Casino through the shewin.club website, mobile browser platform, customer support channels, and any other services operated by shewin (collectively, the "Platform").

1.2 shewin acts as the Personal Information Controller (PIC) as defined under the Philippine Data Privacy Act of 2012 (RA 10173). We are responsible for ensuring that personal data collected through the Platform is processed lawfully, fairly, and transparently.

1.3 This Policy should be read alongside shewin's Terms & Conditions, available at /terms-conditions, and our Responsible Gaming Policy at /responsible-gaming.

1.4 If you have any questions about how shewin handles your personal data, please contact our Data Protection Officer (DPO) using the details provided in Section 14 of this Policy.

2. Personal Data We Collect

2.1 shewin collects personal data that you provide directly, data generated through your use of the Platform, and data obtained from third parties where permitted by law. The categories of personal data we collect include:

2.2 shewin does not collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

2.3 You are not required to provide all requested information, but failure to provide certain data (particularly KYC documentation) may limit your ability to use certain features of the Platform, including withdrawals.

3. How We Use Your Personal Data

3.1 shewin uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your shewin account, including processing registrations, verifying your identity, and managing account settings;
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver the core services of the shewin Platform;
• Regulatory Compliance: To comply with PAGCOR licensing requirements, the Philippine Data Privacy Act, Anti-Money Laundering Act (AMLA), and other applicable laws and regulations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, money laundering, and other illegal activities;
• Responsible Gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, and to enforce self-exclusion requests;
• Customer Support: To respond to your enquiries, complaints, and support requests;
• Marketing Communications: To send you promotional offers, bonuses, and platform updates, where you have consented to receive such communications;
• Platform Improvement: To analyse usage patterns and improve the functionality, performance, and user experience of the shewin Platform.

3.2 shewin will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by law.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary for the performance of the contract between you and shewin (i.e., the Terms & Conditions), including account management, game access, and payment processing;
• Legal Obligation: Processing is required to comply with PAGCOR regulations, AMLA obligations, tax reporting requirements, and other applicable Philippine laws;
• Legitimate Interests: Processing is necessary for shewin's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights;
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, and informed consent, which you may withdraw at any time.

5. Data Sharing & Disclosure

5.1 shewin 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:

• PAGCOR and Regulatory Authorities: As required by our gaming licence and applicable Philippine law, including for audit, compliance, and dispute resolution purposes;
• Anti-Money Laundering Council (AMLC): Where we are legally obligated to report suspicious transactions under the Anti-Money Laundering Act;
• Payment Service Providers: GCash, Maya, and partner banks, solely for the purpose of processing your deposits and withdrawals;
• KYC Verification Partners: Third-party identity verification service providers engaged to assist with KYC compliance;
• Game Providers: Licensed game software providers who supply the games available on the shewin Platform, to the extent necessary for game operation and fairness auditing;
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged by shewin under strict data processing agreements;
• Law Enforcement: Philippine law enforcement agencies, courts, or other government bodies where disclosure is required by law or court order.

5.2 All third-party service providers engaged by shewin are required to process personal data only on shewin's instructions and in accordance with applicable data protection laws.

6. Cookies & Tracking Technologies

6.1 shewin uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse Platform usage.

6.2 The types of cookies used by shewin include:

• Strictly Necessary Cookies: Essential for the Platform to function, including session management and security. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and login status.
• Analytics Cookies: Help us understand how players use the Platform so we can improve it. Used only with your consent.
• Marketing Cookies: Used to deliver relevant promotional content. Used only with your consent.

6.3 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the shewin Platform.

7. Data Retention

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

7.2 In accordance with PAGCOR requirements and the Anti-Money Laundering Act, shewin retains account and transaction records for a minimum of five (5) years from the date of the last transaction or account closure, whichever is later.

7.3 KYC verification documents are retained for a minimum of five (5) years following account closure, as required by applicable AML regulations.

7.4 Where personal data is no longer required, shewin will securely delete or anonymise it in accordance with its data retention schedule.

8. Your Data Privacy Rights

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

• Right to be Informed: The right to be informed of how your personal data is being collected and processed;
• Right of Access: The right to request a copy of the personal data shewin 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, subject to shewin's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• 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.

8.2 To exercise any of these rights, please contact shewin's Data Protection Officer using the contact details in Section 14. shewin will respond to all verified requests within thirty (30) days.

9. Data Security

9.1 shewin implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the shewin Platform;
• Encryption of sensitive data at rest, including financial and identity data;
• 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;
• Multi-factor authentication for account access;
• Incident response procedures for detecting and responding to data breaches.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, shewin will notify the National Privacy Commission and affected individuals in accordance with the requirements of RA 10173 and its Implementing Rules.

9.3 While shewin takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the security of your account credentials.

10. Children's Privacy

10.1 The shewin Platform is strictly intended for individuals aged 21 years and above. shewin does not knowingly collect personal data from persons under the age of 21.

10.2 If shewin becomes aware that personal data has been collected from a person under 21 years of age, it will immediately terminate the associated account, delete the personal data, and report the matter to PAGCOR as required by its licensing obligations.

10.3 If you believe that shewin may have inadvertently collected personal data from a person under 21, please contact our Data Protection Officer immediately using the details in Section 14.

11. International Data Transfers

11.1 shewin's primary operations and data storage are based in the Philippines. In certain circumstances, your personal data may be transferred to, stored, or processed in countries outside the Philippines, for example where shewin engages international game providers or cloud infrastructure providers.

11.2 Where personal data is transferred outside the Philippines, shewin ensures that appropriate safeguards are in place to protect your data in accordance with the requirements of RA 10173, including the use of contractual clauses approved by the National Privacy Commission.

11.3 By using the shewin Platform, you consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

12. Third-Party Links

12.1 The shewin Platform may contain references to third-party services such as payment providers. shewin is not responsible for the privacy practices of third-party services and encourages you to review the privacy policies of any third-party services you use in connection with the Platform.

12.2 This Privacy Policy applies solely to personal data collected and processed by shewin through the shewin Platform. It does not apply to data collected by third parties operating independently of shewin.

13. Updates to This Privacy Policy

13.1 shewin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The most current version of this Policy will always be available at shewin.club/privacy-policy.

13.2 Where changes are material, shewin will notify registered players via email or an in-platform notification prior to the changes taking effect. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

13.3 We encourage you to review this Privacy Policy periodically to stay informed about how shewin protects your personal data.

14. Contact Our Data Protection Officer

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the way shewin handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the shewin Platform

14.2 You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated. The NPC can be reached through its official government channels.

14.3 shewin aims to acknowledge all data privacy requests within five (5) business days and to resolve them within thirty (30) days of receipt.