borgwin Privacy Policy

1. Introduction

borgwin ("we", "us", "our") is committed to protecting the privacy and personal data of every player who registers and uses the borgwin platform at borgwin.net. This Privacy Policy has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as applicable international data protection standards.

This Privacy Policy applies to all personal data collected by borgwin through the borgwin website, the borgwin Login portal, customer support channels, and any other borgwin service or communication. By registering a borgwin account or using any borgwin service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

If you do not agree with any part of this Privacy Policy, you must not register an account or use the borgwin platform.

2. Data Controller

borgwin is the data controller responsible for the personal data collected through the borgwin platform. As data controller, borgwin determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable data protection laws in the Philippines.

For all data privacy inquiries, requests, or complaints, you may contact borgwin's designated Data Protection Officer (DPO) at the contact details provided in Section 16 of this Privacy Policy.

3. Data We Collect

borgwin collects the following categories of personal data from players:

Identity and Contact Data

• Full legal name
• Date of birth (for age verification — borgwin requires players to be 21 years of age or older)
• Government-issued identification number (e.g., Philippine National ID, passport, driver's licence)
• Email address
• Mobile phone number
• Residential address (including city, province, and postal code)

Financial Data

• GCash or PayMaya (Maya) account details used for deposits and withdrawals
• Philippine bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) where applicable
• Debit card details (card number, expiry date — stored in tokenised form only)
• Transaction history, including deposit amounts, withdrawal amounts, and dates

Gaming Activity Data

• Game history, including games played, wagers placed, and outcomes
• Bonus and promotion usage history
• Session duration and login timestamps
• Responsible gaming tool settings (deposit limits, self-exclusion status)

Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Platform interaction logs

Communications Data

• Records of communications with borgwin customer support, including live chat transcripts and email correspondence
• Survey responses and feedback submitted to borgwin

4. How We Collect Your Data

borgwin collects personal data through the following means:

• Direct collection: Data you provide when registering a borgwin account, completing identity verification, making deposits or withdrawals, contacting borgwin support, or participating in borgwin promotions.
• Automated collection: Technical data collected automatically when you access the borgwin platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from third-party KYC (Know Your Customer) service providers; fraud prevention data from anti-fraud screening services; payment confirmation data from GCash, Maya, and Philippine banking partners.

5. How We Use Your Data

borgwin uses your personal data for the following purposes:

6. Legal Basis for Processing

borgwin processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfil borgwin's obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering laws, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for borgwin's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, and informed consent — for example, sending borgwin marketing communications. You may withdraw consent at any time by contacting borgwin support or updating your account preferences.

7. Sharing Your Data

borgwin does not sell your personal data. borgwin may share your personal data with the following categories of recipients only where necessary and lawful:

• Payment processors: GCash, PayMaya, and Philippine banking partners, solely for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers engaged by borgwin to verify player identity and age in compliance with regulatory requirements.
• Fraud prevention services: Anti-fraud and AML screening providers used by borgwin to detect and prevent financial crime.
• Game software providers: borgwin's licensed game content providers may receive limited technical and gaming activity data necessary to deliver game services.
• Regulatory authorities: PAGCOR and other Philippine government agencies where borgwin is legally required to disclose player data.
• Law enforcement: Philippine law enforcement agencies where borgwin is required by law or court order to disclose personal data.
• Professional advisers: Lawyers, auditors, and accountants engaged by borgwin, subject to professional confidentiality obligations.

All third parties with whom borgwin shares personal data are required to handle such data in accordance with applicable data protection laws and borgwin's data processing agreements.

8. Cookies & Tracking Technologies

borgwin uses cookies and similar tracking technologies on the borgwin platform to enhance your experience, maintain your borgwin Login session, and analyse platform usage. The following types of cookies are used:

• Essential cookies: Required for the borgwin platform to function correctly, including session management and borgwin Login authentication. These cannot be disabled.
• Analytics cookies: Used by borgwin to understand how players interact with the platform, which pages are most visited, and where technical issues occur. This data is aggregated and anonymised.
• Preference cookies: Used to remember your borgwin platform settings and preferences across sessions.
• Security cookies: Used by borgwin to detect and prevent fraudulent activity and unauthorised access attempts.

You may manage cookie preferences through your browser settings. Please note that disabling essential cookies may prevent you from accessing certain borgwin features, including the borgwin Login portal.

9. Data Retention

borgwin retains your personal data for the following periods:

• Active account data: Retained for the duration of your borgwin account and for a minimum of five (5) years following account closure, in compliance with Philippine AML and gaming regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter for compliance documentation purposes.
• Technical logs: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, borgwin will securely delete or anonymise your personal data in accordance with its data disposal procedures.

10. Data Security

borgwin implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the borgwin platform.
• One-way cryptographic hashing of borgwin Login passwords — borgwin staff cannot view your password in plain text.
• Tokenisation of payment instrument details — full card or account numbers are never stored on borgwin servers.
• Role-based access controls limiting borgwin staff access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing of the borgwin platform.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

11. Your Rights

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

• Right to be informed: The right to be informed of how borgwin collects and processes your personal data — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data borgwin holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data in your borgwin account.
• Right to erasure: The right to request deletion of your personal data, subject to borgwin's legal retention obligations.
• Right to object: The right to object to borgwin's processing of your personal data for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe borgwin has violated your data privacy rights.

To exercise any of these rights, please contact borgwin's Data Protection Officer using the contact details in Section 16. borgwin will respond to all verified data rights requests within thirty (30) days.

12. Children & Minors

The borgwin platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. borgwin does not knowingly collect personal data from individuals under the age of 21. If borgwin discovers that personal data has been collected from a minor, such data will be deleted immediately and the associated account will be permanently closed.

If you believe a minor has registered a borgwin account, please contact borgwin support immediately so that appropriate action can be taken.

13. International Data Transfers

borgwin primarily stores and processes personal data within the Philippines. Where borgwin engages third-party service providers located outside the Philippines — for example, cloud infrastructure providers or game software licensors — borgwin ensures that appropriate safeguards are in place to protect your personal data in accordance with the Philippine Data Privacy Act, including data processing agreements that impose equivalent data protection standards on such providers.

14. Third-Party Links

The borgwin platform may contain links to other borgwin pages and internal resources. borgwin does not include links to external third-party websites. This Privacy Policy applies solely to data collected and processed by borgwin through the borgwin platform and does not cover any third-party services accessed independently by players outside of borgwin.

15. Policy Updates

borgwin reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, borgwin will notify registered players via email and display a prominent notice on the borgwin platform for a minimum of thirty (30) days following the update.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent revision was made. Continued use of the borgwin platform following notification of changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically.

16. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or borgwin's data processing practices, please contact borgwin's Data Protection Officer:

• Data Protection Officer
• Platform: borgwin.net
• Email: [email protected]
• Support: Available 24/7 via live chat on the borgwin platform

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.