Your privacy matters to alowin. This Privacy Policy explains what personal data we collect from Filipino players, how we use it, who we share it with, and how we keep it safe. Please read it carefully before using the alowin platform.
1Introduction
alowin ("we," "us," or "our") is committed to protecting the privacy and personal data of every Filipino player who uses the alowin platform. This Privacy Policy has been prepared in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations issued by the National Privacy Commission (NPC).
This Policy describes how alowin collects, processes, stores, shares, and protects personal data provided by players and visitors of the Platform. It also explains the rights available to you as a data subject under Philippine law and how you may exercise those rights.
alowin acts as the Personal Information Controller (PIC) with respect to the personal data you provide when registering for and using the alowin Platform. Where alowin engages third-party service providers to process data on its behalf, those providers act as Personal Information Processors (PIPs) and are bound by data processing agreements that require them to handle your data securely and in accordance with this Policy.
2Personal Data We Collect
alowin collects only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we collect include the following:
2.1 Identity & Contact Data
- Full legal name as it appears on your government-issued ID;
- Date of birth (to verify that you meet the 21-year minimum age requirement);
- Nationality and country of residence;
- Residential address (barangay, city or municipality, province, and postal code);
- Valid email address and Philippine mobile number.
2.2 Identity Verification (KYC) Data
- Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys national ID, driver's license, UMID);
- Proof of residential address (e.g., utility bill, barangay certificate);
- Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account showing your registered name);
- Source-of-funds documentation where required under our anti-money laundering (AML) compliance obligations.
2.3 Financial & Transaction Data
- Deposit and withdrawal transaction records, including amounts, dates, and payment methods used;
- GCash or PayMaya account reference numbers (we do not store full card numbers or mobile wallet PINs);
- Account balance history and bonus transaction records.
2.4 Gaming Activity Data
- Game session records including games played, bets placed, and outcomes;
- Bonus claims and wagering activity;
- Responsible gaming tool usage (e.g., deposit limits set, self-exclusion requests).
2.5 Technical & Device Data
- IP address and approximate geolocation;
- Device type, operating system, and browser information;
- Session timestamps and Platform usage logs;
- Cookies and similar tracking technology data (see Section 7).
2.6 Communications Data
- Records of your interactions with alowin customer support, including live chat transcripts and support ticket content;
- Feedback, survey responses, and promotional opt-in records;
- Email correspondence between you and alowin.
3How We Collect Your Data
alowin collects personal data through the following channels:
- Direct submission — data you provide when registering an alowin account, completing identity verification, making a deposit or withdrawal, contacting support, or participating in a promotion;
- Automated collection — technical and device data collected automatically when you access or use the Platform, including through cookies and similar technologies;
- Third-party sources — identity verification data from KYC service providers, fraud-screening data from payment processors, and regulatory watchlist data from compliance service providers;
- Publicly available sources — where necessary for AML compliance, alowin may cross-reference your information against publicly available sanctions lists or adverse media databases.
4How We Use Your Personal Data
alowin uses your personal data only for legitimate purposes directly related to providing and improving our services. The table below summarizes our main processing activities:
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Account registration and authentication | Identity, contact, and device data | Contract performance |
| Age and identity verification (KYC) | Identity, KYC, and financial data | Legal obligation (AML / DPA) |
| Processing deposits and withdrawals | Financial and transaction data | Contract performance |
| Providing games and platform services | Gaming activity and technical data | Contract performance |
| Fraud prevention and security monitoring | Technical, transaction, and identity data | Legitimate interest / Legal obligation |
| AML and regulatory compliance | Identity, KYC, and financial data | Legal obligation |
| Responsible gaming management | Gaming activity and communications data | Legitimate interest / Legal obligation |
| Customer support | Identity, contact, and communications data | Contract performance |
| Marketing and promotional communications | Contact and gaming activity data | Consent |
| Platform analytics and improvement | Technical and gaming activity data | Legitimate interest |
5Legal Basis for Processing
Under the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules, alowin relies on the following legal bases for processing your personal data:
- Contract performance — processing necessary to register your account, provide gaming services, and process financial transactions;
- Legal obligation — processing required to comply with anti-money laundering laws, regulatory reporting requirements, and age verification obligations under applicable Philippine gaming regulations;
- Legitimate interest — processing for fraud prevention, security monitoring, responsible gaming supervision, and platform analytics, where these interests are not overridden by your privacy rights;
- Consent — processing for marketing and promotional communications, where we have obtained your explicit, freely-given, and informed consent.
Where alowin relies on consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
6Data Sharing & Disclosure
alowin does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the limited circumstances described below:
6.1 Service Providers (Personal Information Processors)
alowin engages trusted third-party service providers to assist in operating the Platform. These include KYC and identity verification providers, payment processors (including GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard gateway operators), game software licensors, cloud hosting providers, and customer support platform operators. All such providers are contractually required to process your data only on alowin's instructions and to maintain appropriate security measures.
6.2 Regulatory & Law Enforcement Authorities
alowin may disclose your personal data to the Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and other competent Philippine authorities where disclosure is required by law, court order, or regulatory directive.
6.3 Business Transfers
In the event of a merger, acquisition, or sale of all or part of alowin's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the privacy commitments that apply to your data following the transaction.
6.4 With Your Consent
alowin may share your data with third parties in any other circumstance where you have given your explicit, specific, and informed consent to such sharing.
7Cookies & Tracking Technologies
alowin uses cookies and similar tracking technologies (such as web beacons and local storage) on the Platform to enhance your user experience, maintain your login session, remember your preferences, detect fraud, and analyze how the Platform is used.
7.1 Types of Cookies We Use
- Strictly necessary cookies — required for the Platform to function, including session management and security tokens. These cannot be disabled.
- Functional cookies — remember your language preferences, game display settings, and other personalization choices.
- Analytics cookies — collect anonymized data about how you use the Platform to help us improve performance and usability.
- Security & fraud-detection cookies — help alowin identify suspicious device behavior and protect your account from unauthorized access.
7.2 Managing Cookies
You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the alowin Platform, including your ability to maintain a login session or access certain games.
8Data Retention
alowin retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Our general retention periods are as follows:
- Account and identity data — retained for the duration of your account plus five (5) years after account closure, in compliance with AML recordkeeping requirements;
- Transaction and financial data — retained for five (5) years from the date of each transaction, in accordance with AMLC regulations;
- Gaming activity data — retained for three (3) years for responsible gaming and regulatory audit purposes;
- Customer support records — retained for two (2) years from the date of the last interaction;
- Marketing consent records — retained until consent is withdrawn, plus one (1) year for compliance record-keeping.
After the applicable retention period, your personal data will be securely deleted or anonymized so that it can no longer be associated with you as an individual.
9Data Security
alowin implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security practices include:
- 256-bit SSL/TLS encryption for all data transmitted between your device and the alowin Platform;
- Encryption of sensitive data at rest, including KYC documents and financial records;
- Role-based access controls ensuring that alowin staff can only access personal data that is necessary for their specific job function;
- Regular security assessments and penetration testing of Platform infrastructure;
- Multi-factor authentication (MFA) for internal systems used to process player data;
- Secure, redundant data storage within compliant hosting environments.
10Your Data Subject Rights
Under the Data Privacy Act of 2012, as a Philippine data subject, you have the following rights with respect to your personal data held by alowin:
Right to Be Informed
You have the right to be informed of how alowin collects and processes your personal data, including the purpose, legal basis, and retention period — which is what this Privacy Policy provides.
Right of Access
You may request a copy of the personal data alowin holds about you, along with information about how it is being processed. Requests will be fulfilled within a reasonable period and free of charge for standard requests.
Right to Correction
If any of your personal data held by alowin is inaccurate, incomplete, or outdated, you may request that it be corrected. Please contact support with supporting documentation where applicable.
Right to Erasure
You may request the deletion of your personal data where it is no longer necessary for the purpose it was collected, or where you have withdrawn consent. Note that alowin may be required to retain certain data to comply with legal obligations even after an erasure request.
Right to Object
You may object to the processing of your personal data where alowin relies on legitimate interest as the legal basis, including profiling for marketing purposes. Where your objection relates to direct marketing, alowin will stop processing your data for that purpose immediately.
Right to Data Portability
Where technically feasible and where processing is based on consent or contract, you may request a copy of your personal data in a structured, commonly used, and machine-readable format.
Right to Lodge a Complaint
If you believe alowin has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.
To exercise any of the rights listed above, please contact alowin's Data Protection Officer via the support channel described in Section 14. We will respond to all data subject requests within thirty (30) calendar days of receipt.
11Children & Minors
The alowin Platform is strictly intended for individuals who are at least twenty-one (21) years of age. alowin does not knowingly collect, process, or store personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately suspend the associated account and delete all related personal data.
12Third-Party Links
The alowin Platform may contain links to third-party websites or services, such as game provider pages or payment gateway interfaces. These third-party sites operate under their own privacy policies, which alowin does not control and for which alowin bears no responsibility. We encourage you to review the privacy policy of any third-party site you visit before submitting personal information to it.
13Changes to This Privacy Policy
alowin may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or the features of the Platform. When material changes are made, alowin will notify registered players via email or through an in-platform notification at least seven (7) days before the updated Policy takes effect.
The updated Privacy Policy will be published on this page with a revised "Last Updated" date. Your continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not accept the updated Policy, please stop using the Platform and contact support to close your account.
14Contact Us & Data Protection Officer
If you have any questions, concerns, or requests regarding this Privacy Policy, or if you wish to exercise any of your data subject rights, please contact alowin through the following channel:
Available 24/7 via Live Chat on the Platform
Support Email: [email protected]
For formal data subject requests (access, correction, erasure, portability, objection), please submit your request via live chat and include your full registered name, account email, and a description of your request. We will acknowledge receipt within three (3) business days and respond fully within thirty (30) calendar days.
For unresolved complaints or concerns about how alowin handles your personal data, you also have the right to contact the National Privacy Commission of the Philippines directly.
Our Privacy Commitments
At alowin, protecting your personal data is not just a legal obligation — it is a core part of how we build trust with every Filipino player on our platform.
256-Bit SSL Encryption
Every piece of data that travels between your device and the alowin Platform is protected by industry-standard 256-bit SSL encryption. Your login credentials, financial data, and personal details are never transmitted in plain text — ever.
Strict KYC Protocols
alowin's identity verification process ensures that only legitimate, age-verified Filipino players hold accounts on the Platform. Your KYC documents are handled with the highest level of confidentiality and stored in encrypted form with restricted staff access.
DPA 2012 Compliance
alowin is fully committed to compliance with Republic Act No. 10173, the Data Privacy Act of 2012. We have appointed a Data Protection Officer, maintain a privacy management program, and register our data processing systems with the National Privacy Commission as required.
No Data Selling
alowin will never sell, rent, or trade your personal data to third-party advertisers or data brokers. Your data is used exclusively for the purposes described in this Privacy Policy — to provide you with a secure, fair, and enjoyable gaming experience on the Platform.
Breach Notification
In the unlikely event of a personal data breach, alowin will notify the National Privacy Commission within 72 hours and will inform affected players promptly and transparently. We take our responsibility to keep you informed seriously at every step.
You Stay in Control
alowin gives you meaningful control over your personal data. You can access, correct, or request deletion of your data, withdraw marketing consent, and exercise all your rights under the Data Privacy Act of 2012 at any time by contacting our support team.
Play With Confidence
Now that you know exactly how alowin handles your personal data, play with the confidence that your information is protected at every step. Join thousands of Filipino players from Manila, Cebu, Davao, and beyond who trust alowin every day. For players aged 21 and above only.
For players aged 21 and above only. Gambling involves risk. Please play responsibly and within your means.