davaowin Privacy Policy

1. Introduction

davaowin ("davaowin," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the davaowin platform (the "Platform"). This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you access or use the davaowin website and all associated gaming services.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). It applies to all personal data processed by davaowin in connection with the operation of the Platform.

By registering a davaowin account, accessing the Platform, or otherwise providing your personal information to us, 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 Privacy Policy, you must not use the Platform.

This Privacy Policy should be read together with the davaowin Terms & Conditions and Responsible Gaming Policy, which are incorporated herein by reference.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, davaowin acts as the personal information controller in respect of the personal data collected through the Platform. This means that davaowin determines the purposes and means of processing your personal information.

If you have any questions, concerns, or requests relating to the processing of your personal data by davaowin, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Privacy Policy.

davaowin is committed to ensuring that a designated Data Protection Officer is available to handle all data privacy matters in accordance with the requirements of the NPC.

3. Personal Data We Collect

davaowin collects personal data from you in the following ways: directly from you when you register an account or use the Platform; automatically when you interact with the Platform; and from third parties where permitted by law. The categories of personal data we collect include:

davaowin does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for regulatory compliance purposes, such as identity verification. Where sensitive personal information is collected, we apply additional safeguards to its processing.

4. How We Use Your Personal Data

davaowin uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your davaowin player account, including verifying your identity and eligibility to use the Platform.
• Service Delivery: To provide you with access to the games, features, and services available on the davaowin Platform, and to process your deposits and withdrawals.
• Regulatory Compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) requirements, know-your-customer (KYC) obligations, and responsible gaming regulations.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, cheating, collusion, and other prohibited conduct on the Platform.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor your gaming activity and provide responsible gaming tools, including deposit limits, session reminders, and self-exclusion, in accordance with our Responsible Gaming Policy.
• Marketing and Promotions: To send you information about davaowin promotions, bonuses, and new features, where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the performance, features, and user experience of the davaowin Platform.
• Legal Claims: To establish, exercise, or defend legal claims in connection with the Platform or your account.

5. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary for the performance of the contract between you and davaowin (i.e., the Terms & Conditions), including account management, service delivery, and payment processing.
• Legal Obligation: Processing is necessary for davaowin to comply with its legal obligations under Philippine law, including AML, KYC, and responsible gaming requirements.
• Legitimate Interests: Processing is necessary for the legitimate interests of davaowin, including fraud prevention, security, and Platform improvement, provided that such interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing Your Personal Data

davaowin does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Service Providers: GCash, PayMaya/Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML service providers who assist us in verifying your identity and screening for financial crime risks, as required by Philippine law.
• Game Software Providers: Licensed game developers and live dealer studios whose games are available on the davaowin Platform. These providers may receive limited technical data necessary to deliver their games.
• IT and Platform Service Providers: Cloud hosting, data storage, cybersecurity, and analytics providers who support the operation of the davaowin Platform under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: Philippine government agencies, including the National Privacy Commission, PAGCOR, the Anti-Money Laundering Council (AMLC), and law enforcement authorities, where disclosure is required by law or court order.
• Professional Advisers: Lawyers, auditors, and accountants who provide professional services to davaowin, subject to confidentiality obligations.

All third parties with whom davaowin shares personal data are required to process such data in accordance with applicable Philippine data privacy law and our data protection requirements. davaowin remains responsible for ensuring that your data is handled appropriately by our service providers.

7. Cookies and Tracking Technologies

davaowin uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and support security functions. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against fraud. These cookies cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and game display options, to personalise your experience on davaowin.
• Analytics Cookies: Help us understand how players use the Platform — which pages are visited most, how long sessions last, and where players encounter difficulties. This data is used in aggregate form to improve the Platform.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and activity on the Platform. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the davaowin Platform. Most browsers allow you to refuse cookies or delete existing cookies through their settings menus.

8. Data Retention

davaowin retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Our general data retention periods are as follows:

• Account Data: Retained for the duration of your account and for a period of five (5) years following account closure, in compliance with AML record-keeping requirements under Philippine law.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 (RA 9160, as amended).
• KYC and Verification Documents: Retained for five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for legal proceedings.
• Marketing Data: Retained until you withdraw your consent or opt out of marketing communications, after which it will be deleted or anonymised within a reasonable period.
• Technical and Usage Data: Retained in identifiable form for up to twelve (12) months, after which it is anonymised for analytical purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with davaowin's data disposal procedures.

9. Data Security

davaowin implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the davaowin Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Access controls ensuring that personal data is accessible only to authorised davaowin personnel and service providers on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Staff training on data privacy and security obligations under Philippine law.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, davaowin will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular 16-03.

While davaowin 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 davaowin account credentials.

10. Your Data Privacy Rights

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

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed by davaowin. This Privacy Policy fulfils that obligation.
• Right of Access: You have the right to request a copy of the personal data that davaowin holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data that davaowin holds about you.
• Right to Erasure: You have 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 davaowin's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests, subject to davaowin's overriding legitimate grounds.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that davaowin has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. We will respond to all verified requests within the timeframes required by the Data Privacy Act of 2012. We may need to verify your identity before processing your request.

11. Children's Privacy and Age Restriction

The davaowin Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law governing casino-style gambling. davaowin does not knowingly collect personal data from individuals under the age of 21.

If davaowin becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered a davaowin account or provided personal data to us, please contact our support team immediately.

Parents and guardians are encouraged to use parental control tools and to monitor their children's online activity to prevent access to gambling platforms.

12. Third-Party Links

The davaowin Platform may contain references to third-party services, such as payment providers and game software developers. This Privacy Policy applies only to the davaowin Platform and does not cover the privacy practices of any third-party services.

davaowin is not responsible for the privacy practices or content of any third-party services. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the davaowin Platform.

13. Updates to This Privacy Policy

davaowin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. When material changes are made, we will notify registered players via their registered email address or Philippine mobile number, or by displaying a prominent notice on the Platform.

The date of the most recent revision is indicated at the top of this page. Your continued use of the davaowin Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We recommend reviewing this page periodically to stay informed of any updates.

14. Contact Us and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by davaowin, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the davaowin Platform
• Response Time: We aim to respond to all data privacy requests within 15 business days, as required by the Data Privacy Act of 2012.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with our response to your data privacy concern.