wen1wen Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") applies to all personal data collected and processed by wen1wen ("we," "us," or "our") in connection with your use of the wen1wen website located at wen1wen.app and all associated services, features, and content (collectively, the "Platform").

wen1wen is committed to protecting the privacy and personal data of all users, particularly Filipino players whose data is processed in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations. By accessing or using the wen1wen 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.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which form part of your agreement with wen1wen.

2. Data Controller Information

wen1wen acts as the data controller for all personal data collected through the Platform. As data controller, wen1wen determines the purposes and means of processing your personal data. If you have any questions, concerns, or requests relating to your personal data, you may contact our Data Protection Officer (DPO) at the following address:

3. Personal Data We Collect

wen1wen collects personal data that is necessary for the provision of our services, compliance with legal obligations, and the improvement of the Platform experience. The categories of personal data we collect include:

3.1 Data You Provide Directly

• Identity Data: Full name, date of birth, nationality, and government-issued identification details (e.g., Philippine National ID, passport, driver's license) collected for age verification and Know Your Customer (KYC) compliance;
• Contact Data: Email address, mobile number, and residential address (city/province, e.g., Manila, Cebu, Davao, Quezon City, Makati);
• Account Data: Username, password (stored in hashed form), account preferences, and communication settings;
• Financial Data: GCash account number, PayMaya account details, BPI, BDO, or Metrobank account information used for deposits and withdrawals. We do not store full bank account credentials on our servers;
• Verification Documents: Copies of government-issued IDs, selfies, or proof of address submitted during KYC verification.

3.2 Data Collected Automatically

• Technical Data: IP address, browser type and version, device type, operating system, and screen resolution;
• Usage Data: Pages visited, games played, session duration, bet history, and in-platform navigation patterns;
• Cookie Data: Session cookies, preference cookies, and analytics cookies as described in Section 8 of this Policy.

3.3 Data from Third Parties

• Identity verification data from third-party KYC service providers;
• Payment confirmation data from GCash, PayMaya, and banking partners;
• Fraud detection signals from our security and anti-money laundering (AML) compliance partners.

4. How We Use Your Personal Data

wen1wen processes your personal data only for lawful purposes and on the basis of one or more of the following legal grounds: your consent, the performance of a contract, compliance with a legal obligation, or our legitimate interests where these do not override your fundamental rights.

Purpose	Data Used	Legal Basis
Account registration and management	Identity, Contact, Account Data	Contract performance
Age and identity verification (KYC)	Identity Data, Verification Documents	Legal obligation
Processing deposits and withdrawals	Financial Data, Identity Data	Contract performance
Fraud prevention and AML compliance	Financial Data, Technical Data, Usage Data	Legal obligation, Legitimate interest
Customer support and dispute resolution	Identity, Contact, Account, Usage Data	Contract performance, Legitimate interest
Responsible gaming monitoring	Usage Data, Account Data	Legal obligation, Legitimate interest
Platform analytics and improvement	Technical Data, Usage Data, Cookie Data	Legitimate interest
Marketing communications (opt-in only)	Contact Data, Usage Data	Consent

5. Data Sharing and Disclosure

wen1wen does not sell, rent, or trade your personal data to third parties for their own marketing 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:

• Payment Processors: GCash (GXI), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank, for the purpose of processing financial transactions;
• KYC and Identity Verification Providers: Third-party services engaged to verify player identity and age in compliance with applicable regulations;
• AML and Fraud Detection Partners: Service providers that assist wen1wen in detecting and preventing fraudulent activity and money laundering;
• IT and Infrastructure Providers: Cloud hosting, database, and security service providers who process data on our behalf under strict data processing agreements;
• Regulatory Authorities: Government agencies and regulators, including but not limited to the National Privacy Commission (NPC) of the Philippines, where disclosure is required by law or court order;
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

Any third party with whom wen1wen shares personal data is required to implement appropriate technical and organizational security measures and to process such data only in accordance with our instructions and applicable law.

6. Data Retention

wen1wen retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and transaction records: Retained for a minimum of five (5) years following account closure, in compliance with AML and financial record-keeping requirements;
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later;
• Customer support communications: Retained for three (3) years from the date of the last interaction;
• Marketing preferences and consent records: Retained until you withdraw consent or for three (3) years of inactivity, whichever comes first;
• Technical and usage logs: Retained for up to twelve (12) months for security and analytics purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

7. Data Security

wen1wen implements a comprehensive set of technical and organizational security 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 wen1wen Platform;
• AES-256 encryption for sensitive data stored at rest, including financial information and identity documents;
• Password hashing using industry-standard algorithms; plaintext passwords are never stored;
• Two-factor authentication (2FA) available for all player accounts;
• Regular security audits, penetration testing, and vulnerability assessments;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

8. Cookies and Tracking Technologies

wen1wen uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management and security tokens. These cannot be disabled;
• Functional Cookies: Remember your preferences such as language settings and game display options;
• Analytics Cookies: Collect aggregated, anonymized data about how players use the Platform to help us improve performance and user experience;
• Security Cookies: Used to detect and prevent fraudulent activity and unauthorized access attempts.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

9. Your Data Rights Under Philippine Law

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by wen1wen:

1. Right to be Informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Policy;
2. Right to Access: You may request a copy of the personal data we hold about you at any time;
3. Right to Rectification: You may request correction of any inaccurate or incomplete personal data;
4. Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
5. Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time;
6. Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format;
7. Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days.

10. Children's Privacy

The wen1wen Platform is strictly intended for individuals aged 21 years and above in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from an underage individual, we will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the wen1wen Platform, please contact us immediately at [email protected].

11. Changes to This Policy

wen1wen reserves the right to update or amend this Privacy Policy at any time. When we make material changes, we will notify registered players via email or through a prominent notice on the Platform prior to the changes taking effect. The "Last Updated" date at the top of this Policy will always reflect the most recent revision. Your continued use of the Platform following the posting of any amendments constitutes your acceptance of the revised Policy.

12. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer:

Email: [email protected]
General Support: [email protected]

All emails are plain text contact addresses and are not clickable links. Our support team is available 24/7 and our DPO will respond to privacy-specific inquiries within five (5) business days.