hqwin Privacy Policy

1Introduction

hqwin ("we," "us," or "our") operates the online gaming platform accessible at hqwin.cam. We are committed to protecting the privacy and personal data of every player who interacts with the hqwin platform. This Privacy Policy applies to all personal information collected through the hqwin website, account registration process, gaming activity, payment transactions, customer support channels, and any other interaction you have with hqwin.

This Policy is designed to be consistent with the requirements of the Republic of the Philippines Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, which govern the collection, processing, and protection of personal information in the Philippines.

This Policy should be read in conjunction with the hqwin Terms & Conditions. In the event of any conflict between this Policy and the Terms & Conditions, the Terms & Conditions shall prevail.

2Personal Data We Collect

hqwin collects personal data only to the extent necessary for the purposes set out in this Policy. The categories of personal data we collect include the following:

hqwin does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where disclosure of such information is incidental to another data category (for example, certain government IDs may indicate religious affiliation on their face). Where such data is received incidentally, it is not used for any purpose other than identity verification.

3How hqwin Uses Your Personal Data

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

• Account Management: To create, maintain, verify, and administer your hqwin player account, including processing your registration, verifying your identity, and maintaining your account profile.
• Service Delivery: To provide you with access to the hqwin gaming platform, process deposits and withdrawals, credit bonuses, and deliver all services associated with your account.
• Identity Verification (KYC): To comply with our regulatory obligations to verify the identity and age of all players before processing withdrawals, as required under applicable Philippine laws governing online gaming.
• Payment Processing: To process financial transactions, verify payment methods, prevent payment fraud, and maintain financial records as required by law.
• Responsible Gaming: To monitor gaming behaviour for indicators of problem gambling and to administer responsible gaming tools such as deposit limits, session limits, and self-exclusion requests.
• Anti-Fraud and Security: To detect, investigate, and prevent fraudulent transactions, collusion, money laundering, and other security threats to the hqwin platform and its players.
• Customer Support: To respond to your queries, complaints, and requests submitted through hqwin's live chat, email, or other support channels.
• Legal Compliance: To comply with applicable laws, regulatory requirements, court orders, and the lawful requests of government authorities, including the Anti-Money Laundering Council (AMLC) of the Philippines.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates by SMS and email, where you have provided your consent or where such communications are permitted by applicable law.
• Platform Improvement: To analyse aggregated, anonymised usage data to understand how players interact with the hqwin platform and to improve its features, performance, and user experience.

4Legal Bases for Processing

hqwin processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and hqwin (your account registration and use of the platform), including account management, payment processing, and service delivery.
• Legal Obligation: Processing is necessary for hqwin to comply with applicable legal and regulatory obligations, including KYC requirements, anti-money laundering obligations, and reporting requirements to government authorities.
• Legitimate Interests: Processing is necessary for the legitimate interests pursued by hqwin, including fraud prevention, platform security, responsible gaming monitoring, and business analytics — provided that such interests are not overridden by your privacy rights.
• Consent: For marketing communications and certain non-essential data processing activities, hqwin relies on your freely given, specific, informed, and unambiguous consent, which you may withdraw at any time.

5Sharing Your Personal Data

hqwin does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection obligations:

• Payment Service Providers: GCash, PayMaya, BDO, BPI, Metrobank, UnionBank, and other payment processors, for the purpose of processing deposits, withdrawals, and fraud prevention.
• Identity Verification Services: Third-party KYC and age verification providers engaged by hqwin to assist with the verification of player identity documents.
• Game Software Providers: Game developers and live dealer software providers whose games are offered on the hqwin platform, to the limited extent necessary for game operation and fairness certification.
• Technology and Infrastructure Providers: Cloud hosting, platform software, and cybersecurity service providers engaged by hqwin to operate and secure the platform.
• Customer Support Platforms: Third-party live chat and support ticket system providers used to facilitate hqwin's customer support operations.
• Regulatory and Law Enforcement Authorities: The Anti-Money Laundering Council (AMLC), PAGCOR, the National Privacy Commission (NPC), courts, and other government authorities, where disclosure is required by law or regulatory obligation.
• Professional Advisers: Legal counsel, auditors, and compliance consultants, where disclosure is necessary for the provision of professional services to hqwin.

All third-party service providers engaged by hqwin are contractually required to implement appropriate technical and organisational measures to protect any personal data shared with them and to process such data only for the purposes for which it was shared.

6Cookies & Tracking Technologies

The hqwin platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and collect technical data about how you interact with the platform. The categories of cookies used by hqwin include:

• Strictly Necessary Cookies: Essential for the operation of the hqwin platform, including maintaining your login session and enabling core platform functionality. These cookies cannot be disabled without affecting your ability to use the platform.
• Functional Cookies: Enable personalisation features such as remembering your language preferences, game history display settings, and responsible gaming tool configurations.
• Analytical Cookies: Used to collect anonymised data about how players navigate the hqwin platform, which pages are visited most frequently, and where users encounter difficulties. This data is used solely to improve the platform.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorised access attempts, and bot traffic on the hqwin platform.

hqwin does not deploy third-party advertising cookies or cross-site tracking technologies. You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use the platform.

7Data Retention

hqwin retains your personal data for no longer than is necessary for the purposes for which it was collected, subject to any longer retention periods required by applicable law. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with hqwin, plus a minimum of 5 years following account closure, in accordance with anti-money laundering record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of 5 years from the date of the transaction, as required by applicable Philippine financial regulations.
• KYC Verification Documents: Retained for a minimum of 5 years from the date of verification or from the date of account closure, whichever is later.
• Customer Support Records: Retained for 2 years from the date of the support interaction, unless a longer retention period is required for ongoing dispute resolution.
• Marketing Consent Records: Retained for the duration of your consent, plus 1 year after consent is withdrawn, to demonstrate compliance with consent requirements.
• Technical Log Data: Typically retained for 90 days, unless extended retention is required for security investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be linked to an identifiable individual.

8Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the hqwin platform;
• Encryption of sensitive data at rest within hqwin's database infrastructure;
• Strict internal access controls limiting access to personal data to authorised hqwin personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the hqwin platform;
• Multi-factor authentication requirements for administrative access to hqwin's internal systems;
• Incident response procedures to address data breaches promptly and in accordance with notification obligations.

9Cross-Border Data Transfers

hqwin may transfer your personal data to service providers and infrastructure providers located outside the Republic of the Philippines, including game software developers and cloud hosting providers operating in other jurisdictions. Any such transfers are conducted only where:

• The recipient country provides an adequate level of data protection as determined by the National Privacy Commission of the Philippines;
• Appropriate safeguards are in place, such as contractual data protection clauses that impose obligations equivalent to those required under the Data Privacy Act of 2012; or
• The transfer is necessary for the performance of the contract between you and hqwin (for example, to operate a game provided by an overseas software developer).

You may request further information about the specific safeguards in place for any cross-border data transfer affecting your personal data by contacting hqwin's support team.

10Minors & Age Restrictions

The hqwin platform is strictly intended for individuals who are 21 years of age or older, in accordance with applicable Philippine gaming regulations. hqwin does not knowingly collect personal data from individuals under the age of 21.

Where hqwin becomes aware that personal data has been collected from an individual under the age of 21, such data will be deleted promptly, the associated account will be suspended, and any funds held in the account will be handled in accordance with applicable regulatory requirements.

Parents and guardians who believe that hqwin may have inadvertently collected data from a minor are encouraged to contact hqwin support immediately so that corrective action can be taken.

11Exercising Your Privacy Rights

To exercise any of your privacy rights described in this Policy — including the right to access, rectification, erasure, objection, restriction of processing, or data portability — please submit a request through any of the following channels:

• Live Chat: Available 24/7 through your hqwin account;
• Email: [email protected] (plain text — not a clickable link) with subject line "Privacy Rights Request."

To protect your privacy and security, hqwin will require you to verify your identity before processing any privacy rights request. This typically involves confirming details associated with your registered hqwin account. hqwin will respond to verified requests within 30 days of receipt.

If you are not satisfied with hqwin's response to a privacy rights request, or if you believe that hqwin is processing your personal data in violation of the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

12Marketing Communications

hqwin may send you promotional offers, bonus notifications, and platform news via SMS and email, subject to the following conditions:

• hqwin will only send marketing communications where you have provided your consent during registration, or where you have opted in to receive such communications through your account settings;
• You may withdraw your consent to receive marketing communications at any time by updating your notification preferences in your hqwin account settings, or by contacting hqwin support;
• Opting out of marketing communications will not affect your receipt of transactional communications, such as deposit confirmations, withdrawal notifications, account security alerts, or support responses;
• hqwin does not share your contact details with third parties for their own marketing purposes.

13Amendments to This Policy

hqwin reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable laws, regulatory requirements, or our data processing practices. The current version of this Policy is always available at hqwin.cam/privacy-policy, with the effective date indicated at the top of the document.

Where a material change is made to this Policy, hqwin will provide reasonable notice to registered players through a notification within the platform or via the contact details associated with your account. Continued use of the hqwin platform after the effective date of any amended Policy constitutes your acceptance of the updated terms.

14Contact & Data Protection Enquiries

If you have any questions, concerns, or complaints regarding this Privacy Policy or hqwin's handling of your personal data, please contact our team through the following channels:

• Email: [email protected] — plain text, not a clickable link
• Live Chat: 24/7 support available through the hqwin platform
• Coverage: hqwin serves players across all regions of the Philippines including Metro Manila, Cebu, Davao, Quezon City, Makati, and nationwide

For formal data protection complaints unresolved by hqwin's internal process, you may contact the National Privacy Commission of the Philippines, which is the independent regulatory body responsible for enforcing the Data Privacy Act of 2012.

This Privacy Policy was last reviewed and updated on January 1, 2026. All previous versions are superseded by this document.