Legal
At 38winph, your privacy is not an afterthought — it is a core part of how we operate. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have as a 38winph player under Philippine law.
Last Updated: May 2026This Privacy Policy ("Policy") is issued by 38winph ("38winph," "we," "us," or "our"), the operator of the online gaming platform accessible at 38winph.app. This Policy governs the collection, use, storage, disclosure, and protection of personal information provided by users ("you," "your") of the 38winph platform, including its website, mobile interface, and all associated services.
38winph is committed to protecting the privacy and personal data of all its users in full compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC") of the Philippines.
By registering for an account or otherwise using the 38winph platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the 38winph platform immediately.
Plain-language summary: We collect your data to run your account, comply with Philippine regulations, and improve your experience on 38winph. We do not sell your personal information to third parties for their own marketing purposes.
For the purposes of the Data Privacy Act of 2012 and its IRR, 38winph acts as the personal information controller ("PIC") with respect to the personal data collected through the 38winph platform. As PIC, 38winph determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.
38winph has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 14 of this Policy.
38winph collects the following categories of personal data from users of the platform:
38winph collects personal data through the following means:
38winph processes your personal data for the following purposes:
| Purpose | Data Used |
|---|---|
| Account registration and management | Identity, contact, KYC data |
| Age verification (21+ requirement) | Date of birth, KYC documents |
| Processing deposits and withdrawals | Financial data, identity data |
| Anti-money laundering (AML) compliance | Identity, financial, transaction data |
| Fraud prevention and platform security | Technical, behavioral, identity data |
| Responsible gaming monitoring | Gaming, behavioral, communications data |
| Customer support | Identity, communications data |
| Marketing and promotions (with consent) | Contact, behavioral data |
| Platform improvement and analytics | Technical, behavioral data (aggregated) |
| Regulatory reporting to PAGCOR / AMLC | Identity, financial, transaction data |
Under the Data Privacy Act of 2012, 38winph processes your personal data on the following legal bases:
38winph 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 recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:
Third-party vendors engaged by 38winph to provide services on its behalf, including KYC and identity verification providers, payment processors (GCash, PayMaya, banking partners), IT infrastructure and cloud hosting providers, customer support platform providers, and analytics service providers. All service providers are contractually bound to process personal data only on 38winph's instructions and in compliance with applicable data protection laws.
38winph is required by law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other Philippine government agencies where required by applicable law, court order, or regulatory directive.
In the event of a merger, acquisition, or sale of all or substantially all of 38winph's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in accordance with applicable law.
Where personal data is transferred outside the Philippines (for example, to cloud infrastructure providers), 38winph ensures that such transfers are subject to appropriate safeguards, including contractual clauses approved by the NPC or equivalent data protection standards, in compliance with Section 21 of the Data Privacy Act.
38winph retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:
Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 38winph's data disposal procedures.
38winph implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:
While 38winph takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying 38winph immediately of any suspected unauthorized access to your account.
38winph uses cookies and similar tracking technologies to operate and improve the platform, personalize your experience, and analyze usage patterns. The following categories of cookies are used:
These cookies are essential for the 38winph platform to function correctly. They enable core features such as session management, account authentication, and security. These cookies cannot be disabled without affecting platform functionality.
These cookies remember your preferences and settings — such as your preferred language, game lobby layout, and responsible gaming tool configurations — to provide a more personalized experience on 38winph.
With your consent, 38winph uses analytics cookies to collect aggregated, anonymized data about how users interact with the platform. This data helps us understand which features are most used, identify technical issues, and improve the overall 38winph experience. No personally identifiable information is shared with analytics providers in identifiable form.
With your consent, marketing cookies may be used to deliver relevant promotional content about 38winph offers and games. You may withdraw consent for marketing cookies at any time through your account settings or browser cookie controls.
Managing cookies: You can control and delete cookies through your browser settings at any time. Note that disabling strictly necessary cookies may impair your ability to use certain features of the 38winph platform.
Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 38winph:
To exercise any of the above rights, please contact the 38winph Data Protection Officer using the contact details provided in Section 14. 38winph will respond to all verified requests within fifteen (15) business days, in accordance with NPC guidelines. We may require you to verify your identity before processing your request.
The 38winph platform is strictly intended for users who are twenty-one (21) years of age or older, in accordance with PAGCOR regulations governing online gaming in the Philippines. 38winph does not knowingly collect personal data from individuals under the age of 21.
If 38winph becomes aware that personal data has been collected from a person under 21 years of age, it will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the 38winph platform, please contact our Data Protection Officer immediately using the details in Section 14.
Parents and guardians are encouraged to use parental control tools and to monitor the online activities of minors in their care to prevent underage access to online gaming platforms.
38winph 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. Material changes to this Policy will be communicated to registered users via email or in-platform notification at least seven (7) days before the changes take effect.
The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how 38winph protects your personal data. Your continued use of the 38winph platform following the effective date of any amendment constitutes your acceptance of the revised Policy.
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 38winph, please contact our Data Protection Officer:
Data Protection Officer — 38winph
Email: [email protected]
General support: [email protected]
38winph's customer support team is available 24 hours a day, 7 days a week. For data privacy-specific requests, please include "Data Privacy Request" in your subject line along with your registered account username and a clear description of your request to ensure prompt handling by the DPO.
You also have the right to escalate unresolved privacy concerns to the National Privacy Commission of the Philippines through its official channels.
Your Data, Protected
38winph fully complies with Republic Act No. 10173, the Philippine Data Privacy Act of 2012. Your personal data is collected, processed, and stored in accordance with NPC guidelines and PAGCOR regulatory requirements.
All sensitive data stored on the 38winph platform — including KYC documents and financial records — is protected with AES-256 encryption at rest, and all data in transit is secured with TLS protocols.
38winph has appointed a dedicated Data Protection Officer responsible for overseeing all data privacy compliance. You can reach the DPO directly at [email protected] for any data-related concerns.
38winph does not sell, rent, or trade your personal information to third parties for their own marketing or commercial purposes — ever. Your data is used solely to operate your account and comply with Philippine law.
Under the DPA, you have the right to access, correct, delete, and port your personal data. Submit a verified request to the 38winph DPO and receive a response within 15 business days.
Marketing communications from 38winph are always opt-in. You can withdraw consent and unsubscribe from promotional emails or SMS at any time through your account settings — no questions asked.
Play With Confidence
Now that you know how 38winph handles your personal data, you can play with full confidence. Join thousands of Filipino players on a PAGCOR-regulated platform that takes data privacy as seriously as it takes your gaming experience. Must be 21 or older to register.
21+ Only · PAGCOR Regulated · Gambling is addictive. Know when to stop.