windrem Privacy Policy

01 Introduction

windrem ("windrem", "we", "us", or "our") operates the online gaming platform accessible at windrem.net and is the data controller responsible for your personal information collected through that platform. windrem takes your privacy seriously and is committed to handling your personal data transparently, lawfully, and securely.

This Privacy Policy applies to all personal data collected when you visit windrem.net, register a windrem Account, use any windrem game or service, contact windrem customer support, or interact with windrem through any other channel. It should be read together with windrem's Terms & Conditions and Responsible Gaming Policy.

windrem operates within the PAGCOR licensing framework and complies with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission ("NPC"). Where you access windrem from outside the Philippines, windrem will also endeavor to comply with applicable data protection laws of your jurisdiction.

02 Data We Collect

windrem collects the following categories of personal data in connection with your use of the windrem platform:

2.1 Identity & Registration Data

• Full legal name as it appears on your government-issued Philippine ID;
• Date of birth (used to verify the 21+ age requirement);
• Gender;
• Residential address in the Philippines (city, province, barangay, postal code);
• Philippine mobile number;
• Email address;
• Username and hashed password credential.

2.2 KYC & Verification Data

• Scanned or photographed copies of government-issued photo ID (e.g., UMID, National ID, Passport, Driver's License, Voter's ID, SSS ID, or PhilHealth ID);
• Selfie photograph for facial liveness verification;
• Proof of address documents (e.g., utility bill, bank statement, or barangay certification) where requested;
• Source-of-funds declarations where required under AML compliance obligations.

2.3 Financial & Transaction Data

• GCash mobile number, Maya account reference, BPI/BDO/Metrobank account details (last four digits only — windrem does not store full bank account numbers or card numbers);
• Deposit and withdrawal transaction records including amounts, timestamps, and payment method used;
• Wallet balance history;
• Bonus and promotion redemption records.

2.4 Gaming & Activity Data

• Game session logs including game type, bet amounts, outcomes, and session duration;
• Responsible gaming tool settings (deposit limits, session reminders, self-exclusion status);
• Customer support interaction records, including live chat transcripts and support ticket history;
• Bonus wagering progress and promotional participation records.

2.5 Technical & Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser or app version;
• Session timestamps, login history, and authentication logs;
• Cookie identifiers and similar tracking technology data (see Section 7).

03 How We Collect Your Data

windrem collects personal data through the following channels and methods:

• Directly from you: When you complete the windrem registration form, submit KYC documents, make a deposit or withdrawal, contact customer support, or participate in a promotion;
• Automatically through platform use: Via server logs, session tracking systems, and cookies when you browse windrem.net or use the windrem gaming interface;
• From payment processors: windrem receives transaction confirmation data (not full payment credentials) from GCash, Maya, BPI, BDO, Metrobank, Coins.ph, 7-Eleven, and USDT TRC20 processors when you make deposits or withdrawals;
• From identity verification providers: windrem may use accredited third-party KYC technology providers to assist with document verification and facial recognition checks. These providers process your KYC data on windrem's behalf under data processing agreements;
• From fraud detection and AML systems: windrem may receive risk signals or alerts from third-party compliance and fraud prevention services in connection with your account activity.

04 How We Use Your Data

windrem uses the personal data it collects for the following specific purposes:

• Account creation and management: To register your windrem Account, verify your identity and age (21+ requirement), and manage your account settings and preferences;
• Gaming services delivery: To provide access to slots, live casino games, bingo, sabong, Nine, Bird Catcher, and all other games in the windrem library;
• Payment processing: To process your GCash, Maya, and bank transfer deposits and withdrawals securely and accurately;
• KYC and regulatory compliance: To verify your identity in accordance with PAGCOR requirements and the Anti-Money Laundering Act (AMLA) of the Philippines;
• Fraud prevention and security: To detect, investigate, and prevent unauthorized access, account fraud, bonus abuse, money laundering, and other prohibited activities;
• Responsible gaming: To administer deposit limits, loss limits, cooling-off periods, and self-exclusion tools; and to identify and reach out to players showing signs of problem gambling;
• Customer support: To respond to your inquiries, resolve disputes, and manage your support tickets through windrem's 24/7 live chat system;
• Promotions and bonuses: To administer welcome bonuses, reload promotions, and other offers for which you are eligible;
• Marketing communications: To send you relevant windrem promotions, game updates, and platform news via email or SMS, subject to your marketing preferences and opt-out rights;
• Platform improvement: To analyze aggregated usage data, improve windrem's game offerings, optimize the user interface, and develop new features;
• Legal obligations: To comply with PAGCOR reporting requirements, NPC obligations, court orders, and other applicable Philippine legal obligations.

05 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, windrem processes your personal data on the following legal bases:

• Contractual necessity: Processing your identity, payment, and gaming data is necessary for windrem to perform its obligations under the Terms & Conditions you accepted when registering your windrem Account;
• Legal obligation: KYC verification, AML transaction monitoring, PAGCOR reporting, and age verification processing are required by Philippine law and PAGCOR regulations;
• Legitimate interests: Fraud prevention, security monitoring, platform analytics, and responsible gaming monitoring are carried out on the basis of windrem's legitimate interest in operating a safe, fair, and compliant gaming platform;
• Consent: Marketing communications are sent on the basis of your explicit consent provided during registration or subsequently through your account settings. You may withdraw this consent at any time.

06 Data Sharing & Disclosure

windrem does not sell, rent, or trade your personal data to third parties for their own marketing purposes. windrem may share your personal data with the following categories of recipients, strictly as necessary and subject to appropriate data protection safeguards:

6.1 Regulatory & Law Enforcement Authorities

windrem will disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts where required to do so by applicable Philippine law, regulatory obligation, legal process, or court order.

6.2 KYC & Compliance Providers

windrem engages accredited third-party providers to assist with identity document verification, facial recognition liveness checks, and AML screening. These providers act as data processors under written data processing agreements and may not use your data for any purpose other than providing services to windrem.

6.3 Payment Processors

windrem shares necessary transaction data with GCash, Maya, BPI, BDO, Metrobank, Coins.ph, 7-Eleven, and USDT TRC20 processing partners to facilitate deposits and withdrawals. Each payment processor operates under its own privacy policy and is subject to applicable Philippine financial regulations.

6.4 Technology & Infrastructure Providers

windrem uses cloud hosting, analytics, and security service providers to operate and protect the platform. These providers process data strictly on windrem's instructions and are bound by confidentiality and data protection obligations.

6.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of windrem's business, your personal data may be transferred to the successor entity as part of the transaction, subject to equivalent privacy protections being maintained.

07 Cookies & Tracking Technologies

windrem uses cookies and similar tracking technologies on windrem.net to operate the platform, remember your session, analyze usage patterns, and prevent fraud. The types of cookies used by windrem include:

• Strictly necessary cookies: Required for the windrem platform to function. These include session authentication cookies and security tokens. These cannot be disabled without affecting your ability to use windrem;
• Functional cookies: Used to remember your windrem Login preferences, language settings, and responsible gaming tool configurations;
• Analytics cookies: Used to collect aggregated, anonymized data about how players navigate windrem.net, which pages are visited most frequently, and how platform performance can be improved. No personally identifiable information is included in analytics reports;
• Fraud prevention cookies: Used to detect unusual patterns of device use, multiple account registration attempts, and other security threats.

You can manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to access windrem. Disabling analytics or functional cookies will not prevent you from using windrem but may affect your experience.

08 Data Retention

windrem retains your personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal obligations. The following retention periods apply:

• Account and identity data: Retained for the duration of your windrem Account plus a minimum of five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and the AMLA;
• KYC documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later, as required under Philippine AML regulations;
• Transaction and payment records: Retained for a minimum of five (5) years from the date of the transaction;
• Gaming session logs: Retained for a minimum of two (2) years from the date of the gaming session, or longer where required for dispute resolution or regulatory audit purposes;
• Customer support records: Retained for two (2) years from the date of the most recent interaction in a support case;
• Marketing consent records: Retained for three (3) years from the date of consent, or until withdrawn, whichever is earlier.

Following the expiry of the applicable retention period, windrem will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless further retention is required by a specific legal obligation or ongoing regulatory investigation.

09 Your Data Rights

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

• Right to be Informed: You have the right to be informed about how windrem collects and processes your personal data, which is fulfilled by this Privacy Policy;
• Right of Access: You have the right to request a copy of the personal data windrem holds about you, including information on how it has been used and with whom it has been shared;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data windrem holds about you. For basic profile corrections (name spelling, contact number, address), you may update these directly via your windrem Account dashboard after windrem Login;
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you withdraw consent, or where processing is unlawful — subject to windrem's legal retention obligations under PAGCOR and AMLA requirements which may prevent immediate deletion;
• 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 it to another controller where technically feasible;
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes at any time, without needing to provide justification;
• Right to Lodge a Complaint: If you believe windrem has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact windrem's Data Protection Officer via live chat or by email at the address listed in Section 14. windrem will respond to all verified data rights requests within fifteen (15) business days of receipt.

10 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and windrem.net;
• Encrypted storage of sensitive data fields, including hashed passwords and KYC document images;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Comprehensive audit logging of all internal access to player account data;
• Regular security assessments, penetration testing, and vulnerability scanning of the windrem platform;
• PCI-compliant payment processing with no storage of full card or bank account numbers on windrem servers;
• Two-factor authentication (2FA) options available for windrem Account Login to protect against unauthorized access.

Despite these measures, no system is entirely immune to security threats. In the event of a data breach that is likely to result in a risk to your rights and freedoms, windrem will notify the National Privacy Commission and affected players in accordance with the Data Privacy Act of 2012 and applicable NPC breach notification guidelines.

11 Children & Minors

windrem is strictly for players aged 21 years and above. windrem does not knowingly collect, process, or store personal data of individuals under the age of 21. Registration is blocked for any applicant who declares a date of birth indicating they are under 21 years of age.

If windrem discovers or has reasonable grounds to believe that a person under 21 has registered a windrem Account, windrem will immediately suspend the account, delete all associated personal data to the extent not required for regulatory reporting, and report the incident to PAGCOR if required. Any deposits made by an underage player will be returned to the originating payment method after identity verification of the rightful owner.

12 Third-Party Services & Links

The windrem platform integrates with third-party game providers, payment processors, and technology services. Each third party operates under its own privacy policy and data processing terms. windrem is not responsible for the privacy practices of third-party game providers or payment processors accessed through the windrem platform.

windrem does not embed third-party social media tracking pixels, advertising networks, or data broker SDKs on windrem.net. windrem's analytics are conducted using privacy-respecting, first-party data collection only.

Where windrem engages third-party data processors (such as KYC providers or cloud infrastructure providers), windrem ensures they are bound by written data processing agreements that require them to process your data only on windrem's documented instructions, maintain appropriate security measures, and not transfer your data outside agreed jurisdictions without windrem's written authorization.

13 Changes to This Privacy Policy

windrem may update this Privacy Policy from time to time to reflect changes in our data processing practices, new PAGCOR or NPC requirements, or improvements to our platform. The effective date at the top of this document will always reflect the date of the most recent version.

Where changes are material — meaning they significantly affect how windrem collects, uses, or shares your personal data — windrem will notify registered players by email and through an in-platform notification at least 14 days before the new version takes effect. For minor or clarificatory updates, windrem may update this page without advance notice.

Your continued use of the windrem platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree to the updated Privacy Policy, you should close your windrem Account before the effective date of the change.

14 Contact & Data Protection Officer

For any privacy-related inquiries, data rights requests, or concerns about windrem's handling of your personal data, you may contact windrem's Data Protection Officer through the following channels:

• Live Chat: Available 24/7 through the windrem platform after windrem Login — select "Privacy & Data" as your inquiry category;
• Email: [email protected] — use the subject line "Data Privacy Request" for faster routing to our DPO team.

windrem will acknowledge all privacy inquiries within 48 hours and will provide a substantive response within fifteen (15) business days. If you are not satisfied with windrem's response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.