fearwin Privacy Policy

1. Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings assigned below:

• "fearwin" — the online gaming platform accessible at fearwin.pro, including all associated subdomains, mobile interfaces, and related services.
• "Personal Data" — any information that relates to an identified or identifiable natural person, including but not limited to name, date of birth, address, contact details, government-issued identification numbers, financial account details, and IP address.
• "Player" / "you" — any individual who has registered an account on fearwin, is in the process of doing so, or otherwise accesses or uses fearwin's services.
• "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, and deletion.
• "KYC Documents" — identity verification materials submitted by a Player in connection with fearwin's Know Your Customer process, including government-issued IDs and proof of address documents.
• "DPA" — Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines.
• "NPC" — the National Privacy Commission of the Philippines, the regulatory authority responsible for data privacy enforcement.
• "Sensitive Personal Information" — personal data about a Player's government-issued identification numbers, financial details, and other categories defined as sensitive under the DPA.

2. Data Controller

fearwin acts as the Data Controller in respect of the personal data it collects and processes in connection with the operation of the fearwin online gaming platform. As Data Controller, fearwin determines the purposes for which, and the manner in which, personal data is processed.

For all data privacy enquiries, rights requests, and complaints, Players may contact fearwin's designated Data Protection contact through the support channels listed in Section 14 of this Policy. fearwin is committed to responding to all data-related communications within a reasonable timeframe and no later than fifteen (15) working days.

3. Personal Data We Collect

fearwin collects only the personal data that is necessary for the lawful and efficient operation of the Platform and the delivery of gaming services to Players. The categories of personal data fearwin collects are described in the table below:

4. How We Collect Personal Data

fearwin collects personal data through the following channels and methods:

4.1 Direct Collection

Personal data is collected directly from you when you: register a fearwin account; complete KYC verification; make a deposit or withdrawal request; contact fearwin's live chat or email support; respond to a promotional survey or feedback form; or update your account profile details.

4.2 Automated Technical Collection

When you access and navigate the fearwin platform, certain technical data is collected automatically through cookies, server logs, and similar tracking technologies. This includes your IP address, browser type, device identifiers, session duration, and pages visited. Please refer to Section 6 (Cookies & Tracking) for full details.

4.3 Third-Party Sources

fearwin may receive personal data about you from third-party sources in limited circumstances, including:

• Payment processors (transaction confirmation and status updates from GCash, Maya, BPI, BDO, Metrobank, and other payment partners)
• Identity verification service providers engaged by fearwin to assist with KYC document authentication
• Fraud prevention and anti-money laundering screening databases

In all cases, fearwin only receives the minimum data necessary from third-party sources and verifies that such data has been lawfully provided to fearwin for the stated purpose.

5. Purpose & Legal Basis for Processing

fearwin processes your personal data for the following specific purposes, each grounded in a lawful basis under the Data Privacy Act of 2012:

• Account creation and management — to register, maintain, and administer your fearwin player account. Legal basis: performance of a contract.
• Identity and age verification (KYC) — to confirm that you meet fearwin's eligibility requirements, including the 21+ age restriction, and to comply with PAGCOR and anti-money laundering obligations. Legal basis: compliance with a legal obligation.
• Payment processing — to facilitate deposits and withdrawals via your chosen payment method. Legal basis: performance of a contract.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent transactions, account abuse, collusion, and other prohibited activities. Legal basis: legitimate interests and compliance with legal obligations.
• Customer support — to respond to your enquiries, resolve account issues, and manage support tickets. Legal basis: performance of a contract.
• Responsible gaming — to monitor gameplay patterns, apply player-requested limits, and implement self-exclusion arrangements. Legal basis: compliance with legal obligations and legitimate interests.
• Marketing communications — to send you promotional offers, bonus notifications, and platform updates where you have provided consent. Legal basis: consent. You may withdraw consent at any time by contacting support.
• Platform improvement — to analyse gameplay data and technical logs for the purpose of improving fearwin's products, user interface, and service reliability. Legal basis: legitimate interests.
• Legal and regulatory compliance — to comply with applicable Philippine laws, PAGCOR requirements, court orders, and the instructions of competent regulatory authorities. Legal basis: compliance with a legal obligation.

6. Cookies & Tracking Technologies

fearwin uses cookies and similar tracking technologies on its platform. Cookies are small text files stored on your device that help fearwin deliver a better, more personalized experience. Below is a summary of the cookie types fearwin uses:

6.1 Strictly Necessary Cookies

These cookies are essential for the fearwin platform to function. They enable core features such as login session management, account security, and navigation. These cookies cannot be disabled without significantly impairing the functionality of the Platform.

6.2 Performance & Analytics Cookies

fearwin uses analytics cookies to collect aggregated, anonymized data about how Players use the Platform — which pages are visited most frequently, how long sessions last, and where technical errors occur. This data is used solely to improve fearwin's service quality and is not linked to individually identifiable Players.

6.3 Functional Cookies

Functional cookies remember your preferences — such as your preferred language settings, display configurations, and notification preferences — so that you do not need to reconfigure them on every visit.

6.4 Managing Cookies

You can manage or disable cookies through your browser settings at any time. However, please note that disabling strictly necessary cookies will affect your ability to use key features of the fearwin platform, including logging in and accessing your account balance. fearwin recommends keeping strictly necessary cookies enabled for the best experience.

7. Data Sharing & Disclosure

fearwin does not sell, rent, or trade your personal data. fearwin may share your personal data with the following categories of recipients, strictly on a need-to-know basis and for the purposes described in this Privacy Policy:

7.1 Payment Service Providers

fearwin shares the minimum necessary financial and identity data with its payment processing partners — including GCash, Maya, BPI, BDO, Metrobank, 7-Eleven Cliqq, and Coins.ph — to facilitate deposit and withdrawal transactions. These providers operate under their own privacy policies and are bound by contractual data protection obligations with fearwin.

7.2 Identity Verification Providers

fearwin may engage third-party KYC and identity verification service providers to assist with the authentication of government-issued identification documents. These providers receive only the documents and data necessary for the verification task and are prohibited from using such data for any other purpose.

7.3 Regulatory and Law Enforcement Authorities

fearwin is required by Philippine law and PAGCOR regulations to disclose certain player data to regulatory authorities, law enforcement agencies, and anti-money laundering bodies upon lawful request. fearwin will comply with all such requests and, where permissible under law, will notify affected Players of any such disclosure.

7.4 Technology and Infrastructure Providers

fearwin uses third-party cloud infrastructure, software platforms, and IT service providers to operate its systems. These providers may process personal data in the course of delivering services to fearwin and are bound by strict data processing agreements prohibiting unauthorized use or disclosure of Player data.

7.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of fearwin's business or assets, Player personal data may be transferred to the acquiring entity. fearwin will notify affected Players of any such transfer and ensure that the receiving entity is bound by privacy obligations no less protective than those in this Policy.

8. Data Security

fearwin implements a multi-layered approach to data security, combining technical, organizational, and procedural safeguards to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Key security measures include:

• TLS/SSL encryption across all platform communications, ensuring that data transmitted between your device and fearwin's servers is encrypted in transit at all times
• Encryption at rest for sensitive personal data and KYC documents stored in fearwin's secure data infrastructure
• Access controls — fearwin staff access to Player personal data is restricted on a strict need-to-know basis, with role-based access permissions and audit logging of all data access events
• Two-factor authentication (2FA) available for Player accounts to provide an additional layer of login security
• Regular security assessments and vulnerability scanning of fearwin's platform infrastructure
• Secure KYC document storage with access restricted to the fearwin compliance team and authorized verification personnel only

While fearwin takes all reasonable precautions to protect your personal data, no online platform can guarantee absolute security. You are also responsible for maintaining the security of your own fearwin account credentials and should contact support immediately if you suspect unauthorized access to your account.

9. Data Retention

fearwin retains your personal data for as long as is necessary to fulfil the purposes set out in this Privacy Policy, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Active account data — retained for the duration of your fearwin account and for a period of five (5) years following permanent account closure, in compliance with anti-money laundering record-keeping requirements under Philippine law
• KYC documents — retained for a minimum of five (5) years following account closure or the completion of the transaction to which they relate, whichever is later
• Financial transaction records — retained for five (5) years in accordance with AMLC (Anti-Money Laundering Council) reporting requirements
• Communication records (support tickets, live chat transcripts, emails) — retained for two (2) years from the date of the last communication
• Technical logs (IP logs, session data) — retained for twelve (12) months from collection
• Marketing consent records — retained for three (3) years from the date consent was given or withdrawn

Upon expiry of the applicable retention period, fearwin will securely delete or anonymize your personal data in a manner that prevents reconstruction or identification.

10. Children & Minors

fearwin's gaming services are strictly intended for individuals who are 21 years of age or older, consistent with PAGCOR regulations governing online gambling in the Philippines. fearwin does not knowingly collect personal data from individuals under the age of 21.

If you believe that fearwin has inadvertently collected personal data from a person under 21 years of age, please contact fearwin's support team immediately at [email protected] so that the matter can be investigated and the data removed without delay.

11. Cross-Border Data Transfers

In the course of operating its platform and engaging technology and payment service providers, fearwin may transfer your personal data to servers or entities located outside the Philippines. When fearwin transfers personal data internationally, it ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections provided under the Philippine Data Privacy Act of 2012.

Safeguards employed by fearwin for cross-border transfers include contractual data processing agreements incorporating standard data protection clauses, ensuring that recipient entities are bound by obligations equivalent to those imposed by the DPA. fearwin will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without first putting in place appropriate contractual safeguards.

12. Exercising Your Privacy Rights

To exercise any of your data rights as described in this Privacy Policy and as provided for under the Philippine Data Privacy Act, please contact fearwin's support team using the channels listed in Section 14. When submitting a rights request, please provide:

• Your full registered name and fearwin account username
• A clear description of the right you wish to exercise and the specific data concerned
• A copy of a valid government-issued identification document to enable fearwin to verify your identity before processing the request

fearwin will acknowledge receipt of your request within three (3) working days and will complete the request within fifteen (15) working days of identity verification. In cases where a request is complex or involves a large volume of data, fearwin may extend this period by a further fifteen (15) working days with prior notice to you.

13. Amendments to This Policy

fearwin reserves the right to update or revise this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or fearwin's data processing practices. When material changes are made — meaning changes that significantly affect your rights or the way fearwin processes your personal data — fearwin will notify registered Players via email or an in-platform notification at least seven (7) days before the changes take effect.

The effective date at the top of this Privacy Policy indicates when the current version was last reviewed and updated. Your continued use of the fearwin platform following the publication of an updated Privacy Policy constitutes acceptance of the revised terms. If you do not agree with a revised Policy, you may request account closure in accordance with the account closure procedure described in fearwin's Terms & Conditions.

14. Contact Us

For all data privacy enquiries, rights requests, complaints, or questions relating to this Privacy Policy, please contact fearwin through the following channels:

• Live Chat: Available 24/7 directly within the fearwin platform — the fastest way to reach our support team
• Email: [email protected] — responses within 2 hours during operating hours

fearwin's support team is available 24 hours a day, 7 days a week, including Philippine public holidays. For data privacy matters specifically, please include "Data Privacy Request" in the subject line of your email to ensure your enquiry is routed to the appropriate team member.

If you are not satisfied with fearwin's response to a data privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC).