Privacy Policy – ComboWin: Your Data, Protected Always

1. Who We Are

ComboWin is an online gaming platform that operates at combowin.best, offering online casino games, sports betting (including boxing betting and virtual sports), slots, and related entertainment services to players in the Philippines. When this Privacy Policy mentions "ComboWin", "we", "our", or "us", it refers to the operator of this platform.

We are committed to protecting your personal data in compliance with the Republic Act 10173, also known as the Data Privacy Act of 2012, along with its Implementing Rules and Regulations as enforced by the National Privacy Commission (NPC).

2. What Personal Data We Collect

When you register and use ComboWin, we collect several types of personal information to provide a safe, secure, and personalised gaming experience. The categories of data we process include:

2.1 Registration and Identity Data

• Full legal name (as it appears on a government-issued ID)
• Date of birth (to verify you are at least 21 years old, in compliance with Philippine gaming regulations)
• Email address and mobile number
• Username and encrypted password

2.2 KYC and Verification Documents

To comply with Anti-Money Laundering (AML) regulations and PAGCOR licensing requirements, we may request:

• A valid government-issued ID (e.g., PhilSys ID, driver's licence, passport, SSS/GSIS card, Voter's ID, or PRC ID)
• Proof of billing or address (e.g., utility bill or bank statement)
• A selfie with your ID for identity matching purposes

2.3 Financial and Transaction Data

• Deposit and withdrawal records, including amounts and timestamps
• Payment method details (e.g., GCash mobile number, Maya account, bank account details for BDO, BPI, or UnionBank transfers, or masked Visa/Mastercard card numbers)
• Transaction history and betting activity

2.4 Technical and Usage Data

• IP address, browser type, and device information
• Session logs, login times, and geographic location (country/region level)
• Cookie identifiers and similar tracking technologies
• Pages visited, games played, and feature usage patterns

3. Why We Collect Your Data (Legal Basis)

We only process your personal data when we have a lawful basis to do so. Here's why we collect each category of data:

• To fulfil our contract with you: Processing your registration, managing your account, enabling deposits and withdrawals, and delivering the games and services you signed up for.
• Legal and regulatory compliance: KYC verification, AML checks, responsible gaming monitoring, age verification, and reporting obligations to PAGCOR or other relevant authorities.
• Legitimate interests: Fraud detection, security monitoring, platform analytics to improve our services, and personalising your experience on ComboWin.
• Your consent: Sending you promotional emails, SMS updates, or push notifications about bonuses, new games, or VIP Club offers. You can withdraw consent at any time.

4. How We Use Your Personal Data

Your data is used strictly for the following purposes at ComboWin:

• Creating and maintaining your ComboWin account
• Processing your GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet transfers, BDO/BPI/UnionBank payments, or Visa/Mastercard transactions
• Verifying your identity to prevent underage gambling and fraud
• Calculating and crediting bonuses, VIP rewards, and referral commissions from our Refer a Friend programme
• Providing customer support and responding to your queries
• Detecting suspicious activity and protecting our platform from abuse
• Complying with applicable Philippine laws and gaming regulations
• Improving our slots, casino games, boxing betting, and virtual sports products
• Sending you personalised offers (only if you've opted in)

5. How We Share Your Data

We respect your privacy. ComboWin does not sell, rent, or trade your personal information. However, we may share your data with trusted third parties in the following limited circumstances:

5.1 Service Providers

We work with carefully selected vendors who help us operate ComboWin — including payment processors (e.g., GCash partners, Maya Business, card acquirers), cloud hosting providers, KYC verification platforms, and customer support tools. These vendors are contractually bound to process your data only on our instructions and in compliance with data privacy requirements.

5.2 Regulatory Authorities

We may be legally required to share your information with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or law enforcement agencies when mandated by law, court order, or legal process.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets involving ComboWin, your personal data may be transferred as part of that transaction. You will be notified before your data becomes subject to a different privacy policy.

6. Cookies and Tracking Technologies

ComboWin uses cookies and similar tracking technologies to enhance your experience on our platform. Here's a quick breakdown:

• Essential cookies: Required for the site to function — things like keeping you logged in and remembering your session preferences.
• Analytics cookies: Help us understand how members use ComboWin so we can improve our games and platform layout.
• Preference cookies: Remember your settings, like your preferred language or display options.
• Marketing cookies: Used to show you relevant promotions if you've opted into personalised marketing.

You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect some functionality of the ComboWin platform. Most modern browsers let you block or delete cookies — check your browser's help section for instructions.

7. Data Retention

We keep your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or as required by Philippine law. In general:

• Account data: Retained for the duration of your active membership, plus a minimum of five (5) years after account closure to comply with AML and regulatory record-keeping requirements.
• Transaction records: Maintained for at least five (5) years as required by the AMLC and PAGCOR guidelines.
• KYC documents: Stored securely for the period required by law, then securely disposed of.
• Marketing data: Retained until you withdraw consent or request deletion.

8. Data Security

Protecting your personal data is a top priority at ComboWin. We implement industry-standard technical and organisational measures to prevent unauthorised access, disclosure, alteration, or loss, including:

• TLS 1.3 encryption for all data in transit between your browser/app and our servers
• AES-256 encryption for sensitive data stored in our databases
• Multi-factor authentication options for account access
• Regular vulnerability assessments and penetration testing
• Strict internal access controls — only authorised personnel can access personal data, and only on a need-to-know basis
• 24/7 security monitoring and automated anomaly detection

While we do everything we can to protect your data, no system is 100% impenetrable. We encourage you to use a strong, unique password for your ComboWin account and to enable any two-factor authentication options we offer.

9. Your Rights Under the Data Privacy Act

As a data subject under Republic Act 10173, you have the following rights regarding your personal data held by ComboWin:

• Right to be informed: You have the right to know what personal data we collect about you and how it's being used.
• Right to access: You may request a copy of the personal data we hold about you at any time.
• Right to rectification: If any of your information is inaccurate or outdated, you can ask us to correct it.
• Right to erasure: Subject to legal and regulatory obligations, you may request the deletion of your personal data when it's no longer necessary for the purposes for which it was collected.
• Right to object: You can object to the processing of your data for direct marketing purposes at any time.
• Right to data portability: You may request a structured, machine-readable copy of the data you've provided to us.
• Right to lodge a complaint: If you believe your data privacy rights have been violated, you may file a complaint with the National Privacy Commission at www.privacy.gov.ph.

To exercise any of these rights, please contact our Data Protection Officer at support@combowin.best. We aim to respond to all requests within fifteen (15) business days.

10. Children's Privacy

ComboWin is strictly for adults. Our platform is not intended for, nor do we knowingly collect personal data from, individuals under the age of 21 years. If we become aware that we have inadvertently collected data from a minor, we will delete that information immediately and close the associated account. If you believe a minor has registered on our platform, please contact us right away at support@combowin.best.

11. Third-Party Links

ComboWin's platform does not contain links to external third-party websites. Any promotional content or banners within our platform are for services provided by ComboWin directly. We are not responsible for the privacy practices of any other organisation or platform.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page
• Send you a notification via email or an in-platform alert
• For significant changes, request your explicit re-consent where required by law

We encourage you to review this Privacy Policy periodically so you stay informed about how ComboWin is protecting your information.

13. Contact Us

If you have any questions, concerns, or requests related to your privacy or this Privacy Policy, you can reach our Data Protection Officer here:

• Email: support@combowin.best
• Website: combowin.best

We take all privacy concerns seriously and will do our best to address your request promptly and transparently. Tara, if may concern ka — don't hesitate to reach out, kabayan.