pasawin Privacy Policy

1. Overview

This Privacy Policy ("Policy") applies to all personal data processed by pasawin ("we", "us", "our") in connection with your use of the pasawin website at pasawin.org and any related services, mobile interfaces, or applications operated by pasawin (collectively, the "Platform").

pasawin acts as the Personal Information Controller as defined under the Philippine Data Privacy Act of 2012 (RA 10173). This means we determine the purposes and means by which your personal data is processed. Where we engage third-party service providers to process data on our behalf, they act as Personal Information Processors and are bound by data processing agreements consistent with RA 10173.

By registering an account on pasawin or continuing to use the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, you should discontinue use of the Platform and may request account closure by contacting our support team.

2. Data We Collect

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Nationality and country of residence
• Registered email address and mobile number
• Residential address (for KYC and regulatory compliance)

2.2 Identity Verification Documents

• Copies of government-issued photo ID (e.g., Philippine passport, driver's license, SSS ID, PhilSys national ID, UMID)
• Proof of address documents (e.g., utility bill, bank statement dated within 90 days)
• Selfie or liveness check images where required for enhanced KYC

2.3 Financial Data

• GCash or PayMaya account reference numbers
• Bank account details (BPI, BDO, Metrobank, UnionBank, or other Philippine banks) used for deposits and withdrawals
• Transaction history: deposit amounts, withdrawal amounts, dates, and payment method used
• Account balance and bonus balance information

2.4 Gaming Activity Data

• Games played, bet amounts, win/loss records, and session durations
• Sports betting selections, odds accepted, and settlement outcomes
• Bonus claims, wagering progress, and promotional participation history

2.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, browser type and version
• Session timestamps, login history, and access logs
• Cookie identifiers and similar tracking technologies (see Section 10)

2.6 Communications Data

• Records of your communications with pasawin support, including live chat transcripts, email correspondence, and support ticket history
• Responses to surveys, feedback forms, or promotional communications where you have opted in

3. How We Collect Your Data

pasawin collects your personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion
• Automatically — through cookies, server logs, and analytics tools as you interact with the pasawin Platform
• From third parties — including identity verification service providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud detection services, and PAGCOR-mandated reporting systems

pasawin does not purchase personal data lists from data brokers or any third-party marketing databases.

4. Purpose of Processing

pasawin processes your personal data for the following purposes:

• Account management — creating, maintaining, and securing your pasawin account
• Identity verification (KYC) — verifying your age (21+), identity, and eligibility to use the Platform in compliance with PAGCOR requirements and Philippine anti-money laundering laws
• Payment processing — facilitating deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers
• Game delivery — providing access to slots, live dealer games, bingo, sabong, and sports betting services
• Fraud prevention and security — detecting and preventing fraudulent activity, money laundering, and unauthorized account access
• Regulatory compliance — meeting our obligations under RA 10173, PAGCOR regulations, and the Anti-Money Laundering Act (AMLA)
• Responsible gaming — monitoring gaming patterns to identify potential problem gambling behavior and administering self-exclusion, deposit limits, and cool-off periods
• Customer support — responding to your queries, complaints, and support requests
• Marketing communications — sending you promotional offers, bonuses, and platform updates where you have given consent or where permitted by law
• Platform improvement — analyzing usage patterns to improve the pasawin user experience

5. Legal Basis for Processing

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

• Contractual necessity — processing required to perform our contract with you (account registration, payment processing, game delivery)
• Legal obligation — processing required to comply with Philippine law, including PAGCOR regulations, AMLA obligations, and RA 10173 itself
• Legitimate interests — processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights
• Consent — processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

pasawin does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances:

6.1 Service Providers

We engage trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, and customer support platforms. These providers are contractually bound to process your data only on our instructions and in accordance with RA 10173.

6.2 Regulatory Authorities

pasawin is required by Philippine law to share certain data with PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent government authorities upon lawful request or as required by applicable regulations. We will notify you of such disclosures where legally permitted to do so.

6.3 Legal Proceedings

We may disclose your personal data where required by a court order, subpoena, or other lawful legal process issued by a Philippine court or competent authority.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of pasawin's business, 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.

7. Data Retention

pasawin retains your personal data for as long as your account is active and for a period thereafter as required by applicable Philippine law. Specifically:

• Account and KYC data — retained for a minimum of five (5) years after account closure, as required by AMLA and PAGCOR regulations
• Transaction records — retained for a minimum of five (5) years from the date of each transaction
• Gaming activity logs — retained for three (3) years from the date of activity
• Support communications — retained for two (2) years from the date of the last interaction
• Marketing consent records — retained until consent is withdrawn, plus one (1) year thereafter for compliance documentation

Upon expiry of the applicable retention period, pasawin will securely delete or anonymize your personal data in accordance with our data disposal procedures.

8. Data Security

pasawin implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the pasawin Platform
• Encryption of sensitive data at rest, including financial information and identity documents
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Regular security audits, penetration testing, and vulnerability assessments
• Multi-factor authentication (MFA) options for player accounts
• Incident response procedures for detecting, reporting, and managing personal data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pasawin will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, as required by RA 10173.

While pasawin takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your pasawin Login credentials and for notifying us immediately if you suspect unauthorized access to your account.

9. Your Data Privacy Rights

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

• Right to be informed — the right to know what personal data we collect and how we use it (this Policy fulfills that obligation)
• Right of access — the right to request a copy of the personal data we hold about you
• Right to rectification — the right to request correction of inaccurate or incomplete personal data
• Right to erasure or blocking — the right to request deletion or blocking of your personal data where processing is no longer necessary or lawful, subject to our legal retention obligations
• Right to object — the right to object to processing based on legitimate interests, including direct marketing
• Right to data portability — the right to receive your personal data in a structured, commonly used format where technically feasible
• Right to damages — the right to claim compensation for damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data
• Right to file a complaint — the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. pasawin will respond to all verified data privacy requests within fifteen (15) calendar days of receipt, as required by RA 10173. We may request proof of identity before processing your request.

10. Cookies & Tracking Technologies

pasawin uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the pasawin website. We use the following categories of cookies:

• Strictly necessary cookies — essential for the Platform to function, including session management, login authentication, and security. These cannot be disabled.
• Functional cookies — remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics cookies — collect anonymized data about how players use the Platform, helping us identify areas for improvement. Used only with your consent.
• Marketing cookies — used to deliver relevant promotional content within the pasawin Platform. Used only with your consent.

You may manage your cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies may affect the functionality of the pasawin Platform. Withdrawing consent for analytics or marketing cookies will not affect your ability to play games or access your account.

11. Minors

The pasawin Platform is strictly intended for adults aged 21 years and older, in accordance with PAGCOR regulations governing casino-style gambling in the Philippines. pasawin does not knowingly collect personal data from individuals under the age of 21.

If pasawin becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data, and report the matter to the appropriate authorities where required. If you believe a minor has registered on the pasawin Platform, please notify us immediately at [email protected].

12. Changes to This Policy

pasawin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made, we will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect.

The updated Policy will be published on this page with a revised "Last updated" date. Your continued use of the pasawin Platform after the effective date of any revised Policy constitutes your acknowledgment of the changes. We encourage you to review this page periodically to stay informed about how pasawin protects your personal data.

13. Contact & Data Protection Officer

pasawin has appointed a Data Protection Officer (DPO) in accordance with the requirements of RA 10173 and the National Privacy Commission's guidelines. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO:

Data Protection Officer — pasawin
Email: [email protected]

Please include your registered account username, a clear description of your request or concern, and a copy of a valid ID for identity verification purposes. pasawin aims to acknowledge all data privacy enquiries within three (3) business days and to resolve them within fifteen (15) calendar days.

If you are not satisfied with pasawin's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through official Philippine government channels.