Bwenas PH Privacy Policy —
How We Handle Your Personal Data

1 Data Controller

The data controller responsible for your personal information is Bwenas PH, operating the platform at bwenasph.best. As data controller, Bwenas PH determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out in accordance with the Data Privacy Act of 2012 and this policy.

For all privacy-related enquiries, data subject requests, or complaints, you may contact our Data Protection Officer (DPO) at privacy@bwenasph.best. Our DPO is your direct point of contact for any matter covered by this Privacy Policy.

2 Data We Collect

Bwenas PH collects the following categories of personal data from members and platform users:

Identity and Contact Data

• Full legal name, date of birth, and gender
• Mobile phone number and email address
• Government-issued ID details (for identity verification / KYC purposes)
• Residential address (collected during KYC verification for withdrawals)

Financial Data

• GCash or Maya account number or registered mobile number (for deposits and withdrawals)
• Bank account details where bank transfers are used (BDO, BPI, UnionBank, or InstaPay/PESONet)
• Partial card details where Visa or Mastercard is used (full card numbers are never stored by Bwenas PH)
• Transaction history, deposit records, and withdrawal history within your Bwenas PH account

Gaming Activity Data

• Betting history, game session records, and account activity logs
• Responsible gaming settings applied to your account (deposit limits, self-exclusion periods)
• Customer support interaction records

Technical Data

• IP address, device type, browser type and version, and operating system
• Cookie data and session identifiers (see Section 9 for cookie details)
• Platform usage patterns and navigation data (used in aggregate for product improvement)

3 How We Collect Your Data

Bwenas PH collects your personal data through the following channels:

• Directly from you when you register an account, complete identity verification, make deposits or withdrawals, contact support, or participate in promotions.
• Automatically through your use of the platform — including cookies, session logs, and device and browser data collected when you visit bwenasph.best.
• From payment service providers such as GCash, Maya, and partner banks, who may confirm transaction details as part of payment processing.
• From identity verification partners who assist with KYC document verification where required for regulatory compliance.

4 Why We Use Your Data

Every piece of data collected by Bwenas PH serves a specific, documented purpose. We do not collect data speculatively. The following table summarises our primary data uses:

Bwenas PH will never use your personal data for a purpose not listed above without first obtaining your explicit consent or updating this Privacy Policy with adequate notice.

5 Legal Basis for Processing

Under the Philippines Data Privacy Act of 2012, Bwenas PH processes your personal data on the following legal grounds:

• Contract performance: Processing necessary to fulfil your account agreement with Bwenas PH, including managing deposits, withdrawals, and game access.
• Legal obligation: Processing required to comply with Philippine gaming regulations, anti-money laundering laws, and tax reporting requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and product improvement — where these interests are balanced against your privacy rights.
• Consent: Marketing communications, optional personalisation features, and any processing not covered by the above. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing and Third Parties

Bwenas PH does not sell your personal data to any third party. We share data only in the following specific circumstances:

• Payment processors: GCash, Maya, GrabPay, Coins.ph, and partner banks receive the payment account details necessary to process your deposits and withdrawals. These providers are bound by their own privacy obligations and applicable Philippine financial regulations.
• Identity verification providers: Where KYC verification requires document authentication, we work with regulated identity verification partners who process only the data necessary for verification and are contractually prohibited from using it for any other purpose.
• Regulatory and law enforcement bodies: Bwenas PH is required by law to share certain data with the Philippine gaming regulatory authority, the Anti-Money Laundering Council (AMLC), and law enforcement agencies where legally compelled to do so.
• IT and infrastructure service providers: Cloud hosting and technical infrastructure providers who process data on our behalf under strict data processing agreements that prohibit independent use of your data.

7 Data Retention

Bwenas PH retains your personal data only for as long as necessary to fulfil the purposes described in this policy, or as required by law. The following retention periods apply:

• Account and identity data: Retained for the duration of your active account, plus a minimum of five years following account closure, as required by Philippine gaming and anti-money laundering regulations.
• Transaction records: Financial transaction records are retained for a minimum of five years from the date of the transaction, in compliance with AMLC requirements.
• Customer support records: Retained for three years from the date of the last interaction, unless a longer period is required for an open dispute or regulatory matter.
• Technical and usage data: Generally retained for up to 12 months and then anonymised or deleted. Anonymised aggregate data may be retained indefinitely for product analytics purposes.
• Marketing consent records: Retained for the duration of your consent and for two years following withdrawal of consent, to evidence the lawfulness of prior communications.

8 Data Security

Bwenas PH implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data in transit between your device and our servers
• Encryption of sensitive data at rest, including payment account references and identity document images
• Access controls limiting internal access to personal data on a strict need-to-know basis
• Regular security audits and penetration testing by qualified third-party security professionals
• Staff training on data protection obligations and security best practices
• Incident response procedures that include timely notification to affected players and the National Privacy Commission in the event of a breach

While Bwenas PH takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You also have a role to play: use a strong, unique password for your Bwenas PH account and never share your login credentials with anyone.

9 Cookies and Tracking Technologies

Bwenas PH uses cookies and similar technologies on the platform. A cookie is a small text file stored on your device that helps the platform function correctly and improves your experience. We use the following types of cookies:

• Essential cookies: Required for the platform to function. These include session authentication cookies that keep you logged in. These cannot be disabled without breaking core functionality.
• Functional cookies: Remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies: Help us understand how the platform is used in aggregate — which pages are most visited, where players encounter difficulty. We use anonymised analytics data only. Bwenas PH does not use third-party advertising cookies.
• Security cookies: Help detect and prevent fraudulent activity on the platform.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may prevent you from using certain parts of the Bwenas PH platform.

10 Your Data Rights

As a data subject under the Philippines Data Privacy Act of 2012, you have the following rights with respect to your personal data held by Bwenas PH:

• Right to be informed: The right to know what data we hold about you, why we hold it, and how it is used — which is the purpose of this Privacy Policy.
• Right of access: You may request a copy of the personal data Bwenas PH holds about you. We will respond within 30 days of receiving a verified request.
• Right to rectification: You have the right to correct inaccurate personal data. You can update most account information directly through your profile settings; for identity data, contact our support team.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes collected, subject to legal retention requirements.
• Right to object: You may object to processing based on legitimate interests. Where you object to marketing communications, we will action your request immediately.
• Right to data portability: You may request your data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, email our DPO at privacy@bwenasph.best. We may need to verify your identity before processing the request.

11 Minors and Age Verification

Bwenas PH is strictly for adults aged 18 and above. We do not knowingly collect personal data from minors. Age verification is a mandatory part of the account registration process, and identity verification (KYC) further confirms player age before withdrawals are permitted.

If Bwenas PH becomes aware that personal data has been collected from a person under the age of 18 — whether through fraudulent age declaration or any other means — we will immediately suspend the relevant account, delete the associated personal data, and refund any deposited funds less any regulatory withholding requirements.

12 Cross-Border Data Transfers

Bwenas PH primarily stores and processes data within infrastructure located in the Philippines or in countries that provide an adequate level of data protection as recognised by the National Privacy Commission. Where data is transferred to a third country for processing (for example, by a cloud service provider with global infrastructure), we ensure that appropriate safeguards are in place, including contractual data processing agreements that impose obligations equivalent to those required under the Data Privacy Act of 2012.

We will never transfer your personal data to a country or jurisdiction that does not provide an adequate level of protection without first obtaining your explicit consent or putting in place enforceable contractual protections.

13 Changes to This Privacy Policy

Bwenas PH may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. When we make material changes, we will notify you via email to your registered address and/or through a prominent notice on the platform.

The "Last updated" date at the top of this page indicates when the most recent version took effect. We encourage you to review this policy periodically. Continued use of the Bwenas PH platform after any update constitutes acceptance of the revised policy.

14 Contact Us and Data Protection Officer

For all privacy-related enquiries, data subject requests, or complaints, please contact the Bwenas PH Data Protection Officer (DPO):

• Email: privacy@bwenasph.best
• General Support: support@bwenasph.best
• Platform Chat: Available 24/7 through your logged-in Bwenas PH account
• Response Time: DPO responses within 72 hours; data subject requests fulfilled within 30 days

If you are not satisfied with our response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent government authority responsible for protecting the data privacy rights of Filipino citizens.