cowins188 Privacy Policy

This Privacy Policy is issued by cowins188 (referred to in this document as "cowins188," "we," "us," or "our"), the operator of the online gaming platform accessible at cowins188.app. cowins188 acts as the personal information controller in respect of all personal data collected through the platform and processed in connection with the services provided to registered players.

cowins188 is operated for and directed at players physically located in the Philippines. This Privacy Policy is designed to comply with the requirements of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission (NPC).

For privacy-related enquiries, data subject access requests, or complaints regarding cowins188's handling of your personal data, you may contact us at any time via:

• Email: [email protected] — please include "Privacy Request" in the subject line;
• Live Chat: Available 24/7 on the cowins188.app website. Average response time is under two minutes.

cowins188 collects personal data in two broad categories: data you provide directly to us, and data we collect automatically during your use of the platform. The table below summarises the categories of personal data we process.

cowins188 collects personal data through the following means:

• Direct provision by you: When you complete the registration form, submit KYC documentation, make a deposit or withdrawal request, update your account settings, or contact our support team, you directly provide personal data to cowins188;
• Automated collection: When you access and use the cowins188 platform, our servers and analytics tools automatically collect Technical Data including your IP address, device information, browser type, and session activity. This data is collected through server logs, session cookies, and similar technologies (described further in Section 7);
• Third-party sources: cowins188 may receive identity and verification data from third-party KYC service providers engaged to assist with identity verification processes. We may also receive fraud-prevention signals from payment processors in connection with deposit and withdrawal transactions;
• Regulatory and legal sources: In limited circumstances, cowins188 may receive data from PAGCOR or other regulatory authorities in connection with compliance obligations, including problem gambling self-exclusion databases where applicable.

cowins188 uses the personal data it collects for the following specific purposes:

• Account creation and management: To register your cowins188 account, verify your identity, maintain your account profile, and provide access to the platform's games and services;
• Payment processing: To process deposits and withdrawals via GCash, Maya, bank transfer, Coins.ph, and USDT TRC20, and to maintain accurate transaction records in Philippine Peso;
• Identity verification (KYC): To verify that you are who you say you are, that you meet the age requirement of 21 years, and that your account is not being used for money laundering or fraud;
• Regulatory compliance: To meet cowins188's obligations under applicable Philippine gaming regulations, anti-money laundering legislation, and the Data Privacy Act of 2012;
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, account takeover attempts, multi-accounting, and other conduct prohibited under cowins188's Terms and Conditions;
• Responsible gaming: To implement and monitor deposit limits, self-exclusion periods, and other responsible gaming tools configured by you or applied by cowins188 in accordance with its responsible gaming obligations;
• Customer support: To respond to enquiries, resolve disputes, and provide assistance across cowins188's 24/7 live chat and email support channels;
• Platform improvement: To analyse aggregated, anonymised usage data for the purpose of improving platform performance, user experience, and game offering;
• Communications: To send you account-related notifications including transaction confirmations, security alerts, KYC status updates, and — where you have opted in — promotional communications about cowins188 offers and bonuses.

Under the Philippine Data Privacy Act of 2012, cowins188 relies on the following lawful criteria to process your personal data:

• Consent: For marketing communications, optional data collection beyond what is required for platform operation, and certain non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal;
• Contract performance: For all data processing that is necessary to perform the services you have contracted with cowins188 to receive, including account operation, deposit and withdrawal processing, and customer support;
• Legal obligation: For KYC identity verification, anti-money laundering record-keeping, and any processing required by PAGCOR, the NPC, or other competent Philippine regulatory authorities;
• Legitimate interests: For fraud prevention, platform security, and anonymised analytics, where such interests are not overridden by your fundamental rights and freedoms in relation to personal data protection.

cowins188 does not sell, rent, or trade your personal data. We share personal data with third parties only in the following circumstances and only to the minimum extent necessary:

• Game providers (WM Gaming, Playtech, and others): Limited technical data is shared with game platform providers to facilitate your game sessions and maintain game integrity. These providers process data only in accordance with their own regulatory obligations and our data processing agreements with them;
• Payment processors: Financial data necessary to execute your deposit and withdrawal transactions is shared with the relevant payment service providers (including GCash, Maya, BPI, BDO, Metrobank, Coins.ph, and applicable blockchain networks). These providers are independently regulated and have their own privacy policies that govern their handling of your payment data;
• KYC and fraud prevention services: Identity verification data submitted during the KYC process may be shared with third-party identity verification service providers engaged by cowins188. These providers are bound by strict data processing agreements and are not permitted to use your data for any purpose other than verification;
• Regulatory authorities: cowins188 will disclose personal data to PAGCOR, the National Privacy Commission, law enforcement agencies, or other government bodies when required to do so by applicable Philippine law, court order, or regulatory direction;
• Professional advisers: In the context of legal proceedings, insurance claims, or regulatory investigations, cowins188 may share limited personal data with its legal, audit, or insurance advisers under binding professional confidentiality obligations.

The cowins188 platform uses cookies and similar tracking technologies to support essential platform functionality and to improve the user experience. The following types of cookies are used:

• Strictly necessary cookies: These cookies are required for the platform to function correctly, including maintaining your login session, remembering your account preferences, and enabling secure access to your account. These cookies cannot be disabled without affecting core platform functionality;
• Functional cookies: These cookies remember your settings and preferences (such as your preferred language or the last game category you visited) to provide a more personalised experience. They are not strictly required for basic platform operation;
• Analytics cookies: cowins188 uses anonymised analytics data to understand how players navigate and use the platform. This helps us identify areas for improvement. Analytics data is aggregated and does not identify individual users;
• Security cookies: These cookies assist in identifying and preventing fraud, detecting suspicious login activity, and implementing session timeout protections.

You may configure your browser to block or delete cookies. Please note that disabling strictly necessary cookies will impair your ability to use core cowins188 features, including logging in and completing transactions.

cowins188 retains personal data only for as long as is necessary for the purposes for which it was collected, or for longer periods where required by applicable law or regulation. The general retention periods applied by cowins188 are as follows:

• Account data and KYC documentation: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements under Philippine law;
• Transaction records: Retained for a minimum of five (5) years following the date of the relevant transaction, for regulatory compliance and dispute resolution purposes;
• Customer support communications: Retained for three (3) years from the date of the last communication, unless the content is relevant to an active dispute or investigation;
• Technical and server log data: Retained for up to twelve (12) months in active form and may be archived for a further period for security analysis purposes;
• Marketing consent records: Retained until you withdraw consent, and for a reasonable period thereafter to demonstrate that consent was obtained.

When personal data is no longer required for the stated purpose and the applicable retention period has expired, cowins188 will securely delete or anonymise the data in accordance with its data disposal procedures.

cowins188 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the cowins188 platform is encrypted using TLS. The presence of a padlock icon in your browser address bar confirms that the connection is secured;
• Password hashing: Account passwords are never stored in plain text. cowins188 uses industry-standard hashing algorithms with salting to store password credentials;
• OTP two-factor authentication: Login attempts from unrecognised devices trigger an OTP verification step via SMS or email, adding an additional layer of protection against unauthorised account access;
• Role-based access controls: Internal access to personal data is restricted on a need-to-know basis. Staff members can only access the categories of personal data required to perform their specific job functions;
• Security monitoring: cowins188 monitors platform activity for indicators of fraud, account takeover attempts, and data security incidents on a continuous basis;
• Vendor due diligence: Third-party service providers with access to personal data are subject to security due diligence assessments and contractual data protection obligations prior to engagement.

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you hold the following rights in relation to your personal data held by cowins188. To exercise any of these rights, contact us at [email protected] with the subject line "Privacy Request" or via the 24/7 live chat.

cowins188 will respond to data subject requests within the timeframes prescribed by the Data Privacy Act. In most cases, we aim to respond within fifteen (15) business days of receiving a valid request. We may need to verify your identity before processing a request to ensure we are not disclosing data to the wrong person.

Please note that certain rights are subject to limitations under applicable law. For example, we cannot delete data that we are legally obliged to retain for anti-money laundering compliance purposes, even if you request its deletion.

If you are a parent or guardian and believe that a minor under your care has created an account on cowins188 or submitted personal data to the platform, please contact us immediately at [email protected]. We will investigate and take appropriate action, including account closure and data deletion, within the shortest practicable timeframe.

cowins188 primarily processes personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed in other countries — for example, when data is processed by a game provider or payment processor whose servers are located outside the Philippines.

Where personal data is transferred outside the Philippines, cowins188 ensures that such transfers are carried out in compliance with the Data Privacy Act of 2012, including by:

• Transferring data only to countries that the NPC has recognised as providing an adequate level of data protection, or;
• Implementing appropriate contractual safeguards, such as data processing agreements incorporating standard data protection clauses, with the receiving party before the transfer takes place.

You may request information about the specific safeguards applied to cross-border data transfers involving your personal data by contacting us at [email protected].

cowins188 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the services we offer. The updated policy will always be published at cowins188.app/privacy-policy with a revised "Last updated" date at the top of the document.

Where changes are material — meaning they significantly affect how we collect or use your personal data, or your rights in relation to that data — cowins188 will notify registered users via their registered email address at least 14 days before the changes take effect.

Your continued use of the cowins188 platform after the effective date of any policy update constitutes your acknowledgement of the revised Privacy Policy. If you do not agree with the updated policy, you should discontinue use of the platform and request account closure.

For any questions about this Privacy Policy, to exercise your data subject rights, or to raise a privacy concern, please contact cowins188 through either of the following channels:

• Email: [email protected] — please use "Privacy Request" or "Privacy Complaint" as the subject line to ensure your message reaches the appropriate team promptly;
• Live Chat: Available 24/7 on the cowins188.app platform. Live chat is the fastest channel for urgent data security concerns such as suspected account compromise. Average response time is under two minutes.

If you are not satisfied with cowins188's response to a privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory body responsible for enforcing the Data Privacy Act of 2012 in the Philippines.