crowdwin Privacy Policy

1. Introduction

crowdwin ("we," "us," or "our") operates the online casino and sports betting platform accessible at crowdwin.club ("Platform"). This Privacy Policy ("Policy") applies to all personal information collected from individuals who register accounts, access the Platform, or otherwise interact with crowdwin's services, including the crowdwin Casino, slots, Bingo, fishing games, live dealer tables, and sports betting offerings.

crowdwin is committed to responsible data stewardship. We collect only the personal data necessary to deliver our services, we process it lawfully and transparently, and we take appropriate technical and organizational measures to protect it. By registering a crowdwin account or using any part of the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

The data controller responsible for the personal information collected through crowdwin.club is crowdwin ("crowdwin," "the Company"). Questions about this Policy, requests to exercise your data subject rights, or concerns about our data practices may be directed to our Data Protection Officer using the contact details provided in Section 15 of this Policy.

crowdwin processes personal data in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission of the Philippines.

3. Personal Data We Collect

crowdwin collects personal data through the following means: direct submission by you during registration and account use; automatic collection via technical systems when you use the Platform; and collection from third-party service providers where necessary for identity verification, payment processing, or fraud prevention.

Registration and Identity Data:

• Full legal name, date of birth, and Philippine mobile number or email address.
• Residential address and nationality.
• Government-issued identification document details (e.g., passport number, UMID, driver's license, PhilSys ID) submitted for KYC verification.
• Selfie or live photo submitted for identity verification purposes.

Financial and Transaction Data:

• GCash account number or PayMaya account details used for deposits and withdrawals.
• Bank account details (BDO, BPI, Metrobank, or other Philippine bank) where used for transactions.
• Deposit amounts, withdrawal amounts, and transaction history.
• Source of funds information provided for AML compliance.

Gaming Activity Data:

• Game session records, including games played, wagers placed, wins, and losses.
• Bonus usage and promotional participation records.
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status).

Technical and Usage Data:

• IP address, device type, operating system, and browser type.
• Login timestamps and session duration.
• Geolocation data (country-level, used for regulatory compliance).
• Cookie identifiers and analytics data as described in Section 7.

Communications Data:

• Records of correspondence with crowdwin's customer support team, including live chat transcripts and email communications.
• Feedback and survey responses submitted voluntarily.

4. How We Use Your Personal Data

crowdwin processes your personal data for the following purposes:

• Account registration and management: Creating and maintaining your crowdwin player account, verifying your identity and age (21+), and providing access to the Platform.
• Service delivery: Processing deposits and withdrawals, awarding winnings, applying bonuses, and delivering the gaming services you request.
• Legal and regulatory compliance: Fulfilling obligations under the Anti-Money Laundering Act (AMLA), PAGCOR regulations, and other applicable Philippine laws. This includes maintaining transaction records, filing suspicious transaction reports where required, and cooperating with regulatory and law enforcement authorities.
• Fraud prevention and security: Detecting and preventing fraudulent activity, account takeovers, and prohibited conduct as described in our Terms & Conditions.
• Responsible gaming: Operating deposit limits, session controls, self-exclusion tools, and conducting responsible gaming checks in accordance with our Responsible Gaming Policy.
• Customer support: Responding to your enquiries, complaints, and requests, and maintaining records of our communications.
• Platform improvement: Analyzing aggregated usage data to improve the performance, security, and user experience of the crowdwin Platform.
• Marketing communications: Sending promotional offers, bonus notifications, and updates about new games or features, where you have not opted out. See Section 13 for opt-out information.

5. Legal Basis for Processing

crowdwin processes your personal data on the following legal bases as defined under the Data Privacy Act of 2012:

• Performance of a contract: Processing necessary to deliver the services described in our Terms & Conditions, including account management, game provision, and payment processing.
• Compliance with a legal obligation: Processing required by AMLA, PAGCOR regulations, the Data Privacy Act, and other applicable Philippine laws, including KYC verification, transaction record-keeping, and suspicious transaction reporting.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming compliance, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing & Disclosure of Personal Data

crowdwin does not sell your personal data to third parties. We share personal data only as necessary for the following purposes, and only with entities bound by appropriate data processing agreements:

• Payment processors: GCash, PayMaya, and Philippine banking partners (BDO, BPI, Metrobank) receive transaction data necessary to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party identity verification services receive identity document images and selfies to verify your age and identity in compliance with PAGCOR requirements.
• Game software providers: Game studios providing slots, live dealer, Bingo, and fishing games receive session data necessary to operate game outcomes and record results.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and Philippine law enforcement may receive personal data where required by law or court order.
• IT and security service providers: Cloud hosting, cybersecurity, and analytics providers who process data on crowdwin's behalf under strict data processing agreements.

All third-party processors engaged by crowdwin are evaluated for data protection compliance and are contractually required to process personal data only as instructed by crowdwin and in accordance with applicable privacy law.

7. Cookies & Tracking Technologies

crowdwin uses cookies and similar tracking technologies on crowdwin.club to operate the Platform, analyze usage, and where applicable, deliver personalized content. The types of cookies we use include:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your crowdwin account. These cannot be disabled.
• Performance and analytics cookies: Collect anonymized data about how visitors use the Platform, which pages are visited most frequently, and how users navigate between sections. Used to improve Platform performance.
• Functional cookies: Remember your preferences, such as language settings and responsible gaming tool configurations, to personalize your crowdwin experience.

You may adjust your browser settings to refuse or delete non-essential cookies. Note that disabling certain cookies may affect the functionality of the crowdwin Platform. A full cookie preference center is available through your crowdwin account settings.

8. Data Retention

crowdwin retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC records: Retained for a minimum of 5 years from the date of account closure, as required by the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, consistent with AMLA and BIR record-keeping requirements.
• Game session records: Retained for a minimum of 2 years from the date of each session for dispute resolution and regulatory audit purposes.
• Customer support communications: Retained for 2 years from the date of closure of each support interaction.
• Marketing consent records: Retained for the duration of your account plus a reasonable period to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized. Data subject to a regulatory hold or pending legal proceedings will be retained until resolution.

9. International Data Transfers

crowdwin's primary operations and data storage are based in the Philippines. Where personal data is transferred to or processed by third parties outside the Philippines — for example, where a game studio or technical service provider is located abroad — crowdwin ensures that such transfers comply with Section 21 of the Data Privacy Act and NPC guidelines on cross-border data transfers.

Transfers to countries without an adequate level of data protection are subject to appropriate safeguards, including standard contractual clauses or binding corporate rules, as approved by the National Privacy Commission of the Philippines.

10. Security Measures

crowdwin implements appropriate technical and organizational security 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 transmitted between your device and crowdwin's servers.
• AES-256 encryption at rest for stored personal data, including identity documents and financial records.
• Role-based access controls ensuring that crowdwin staff can only access personal data necessary for their specific job function.
• Multi-factor authentication for internal crowdwin systems that store or process player personal data.
• Regular security audits and penetration testing conducted by independent cybersecurity professionals.
• Data breach response procedures enabling crowdwin to notify affected players and the National Privacy Commission within 72 hours of becoming aware of a qualifying personal data breach.

While crowdwin implements industry-standard security controls, no data transmission or storage system can be guaranteed to be 100% secure. You are encouraged to use a strong, unique password for your crowdwin account and to enable two-factor authentication where available.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules, you have the following rights with respect to your personal data processed by crowdwin:

• Right to be informed: The right to know what personal data crowdwin holds about you and how it is being processed.
• Right of access: The right to request a copy of the personal data crowdwin 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 personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations under AMLA and other applicable laws.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds of legitimate interests.
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please contact crowdwin's Data Protection Officer using the details in Section 15. We will respond to all verified data subject requests within 30 calendar days of receipt.

12. Children & Minors

The crowdwin Platform is strictly intended for adults aged 21 years or older, in compliance with Philippine gaming regulations. crowdwin does not knowingly collect or process personal data of persons under the age of 21. If crowdwin becomes aware that personal data has been collected from an individual under 21 years of age, we will immediately close the relevant account, forfeit any associated balances where required by law, and securely delete all personal data associated with that account.

If you believe a minor has registered a crowdwin account, please contact our Data Protection Officer immediately using the contact details in Section 15 so that we can take prompt action.

13. Marketing Communications

With your consent, crowdwin may send you marketing communications about promotions, new games, bonuses, and platform updates via SMS, email, or in-platform notifications. You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in your crowdwin account settings.
• Clicking the unsubscribe link in any crowdwin marketing email.
• Contacting crowdwin's customer support team via live chat or email and requesting removal from marketing communications.

Withdrawal of marketing consent will not affect the delivery of transactional communications necessary for your account — such as deposit confirmations, withdrawal notifications, and security alerts — which are sent on the basis of contractual necessity rather than consent.

14. Changes to This Privacy Policy

crowdwin reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, crowdwin will notify registered players via email or in-platform notification at least seven (7) days before the changes take effect, unless immediate changes are required by law.

The "Last Updated" date at the top of this page reflects the most recent revision. The current version of this Privacy Policy is always available at crowdwin.club/privacy-policy. Continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms.

15. Contact & Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or your personal data rights, please contact crowdwin's Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: "Data Privacy Request – [Your Name]"
• Live Chat: Available 24/7 via crowdwin.club (request DPO escalation)
• Response Time: Within 30 calendar days for formal data subject requests; within 24 hours for general privacy enquiries

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

This Privacy Policy was last reviewed and updated in June 2026. crowdwin processes personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and applicable NPC issuances.