combowin Privacy Policy – How We Handle Your Personal Data

1 Introduction

combowin ("we", "us", "the Platform") is committed to protecting the personal information of every Filipino player who uses the platform. This Privacy Policy explains the types of data we collect, the reasons we collect them, how they are stored and secured, who may access them, and what rights you hold as the data subject.

This policy applies to all personal data collected through the combowin website at combowin.vu, the combowin mobile applications, and any interaction you have with our support team. It applies regardless of which device you use to access the platform — whether desktop, Android, or iOS.

If you have questions about this policy or how your data is handled, contact us at [email protected].

2 Data We Collect

combowin collects the following categories of personal information:

3 How We Collect Your Data

combowin collects personal data through the following means:

• Account registration: You provide identity and contact details when creating your combowin account.
• KYC submission: You upload a valid Philippine government-issued ID for identity verification before your first withdrawal.
• Payment transactions: Your bank or e-wallet account details are recorded when you make a deposit or request a withdrawal in PHP.
• Platform use: Technical and usage data is collected automatically as you navigate the platform, play games, and place bets.
• Support interactions: When you contact our team by email or chat, the content of that communication is recorded.
• Cookies and similar technologies: We use cookies and session tracking tools to maintain your login session and understand platform usage patterns. See Section 8 for more detail.

4 How We Use Your Data

Your personal data is used for the following purposes:

• Account management: To create, maintain, and secure your combowin account.
• Identity verification: To confirm you meet the 21+ age requirement and that your identity is genuine, as required for KYC compliance.
• Payment processing: To receive your PHP deposits and process your withdrawal requests to your verified Philippine bank account or e-wallet.
• Security and fraud prevention: To detect and prevent unauthorised account access, duplicate accounts, and fraudulent transactions.
• Responsible gaming: To monitor activity patterns that may indicate problematic gaming behaviour and to apply self-exclusion or limits at your request.
• Platform improvement: To understand how Filipino players use combowin and to improve game availability, interface design, and support quality.
• VIP program: To calculate your activity level, determine your VIP tier, and administer tier benefits including PHP cashback and withdrawal priority.
• Customer support: To respond to your queries and resolve account, payment, or game-related issues.
• Legal compliance: To meet any reporting or record-keeping obligations required by applicable law.

combowin does not use your personal data for any purpose that is inconsistent with those listed above without first notifying you and obtaining any required consent.

5 Sharing Your Data

combowin does not sell, rent, or trade your personal data. We may share your data only in the following limited circumstances:

• Payment processors: Your bank account or e-wallet details are shared with the relevant Philippine financial service provider solely to execute your deposit or withdrawal in PHP.
• Identity verification providers: KYC documents may be processed by a third-party identity verification service to confirm authenticity. These providers are bound by confidentiality obligations.
• Technology and hosting providers: Our platform infrastructure involves third-party hosting and software services that process data on our behalf under strict data processing agreements.
• Legal and regulatory authorities: We may disclose data where required by applicable law, court order, or regulatory authority, including anti-money-laundering reporting obligations.
• Fraud prevention: We may share data with other platforms or industry bodies solely for the purpose of identifying and preventing fraud, cheating, or money laundering.

All third parties who process data on behalf of combowin are required to handle it securely and only for the specific purposes for which it was shared.

6 Data Security

combowin implements multiple layers of security to protect your personal information:

• SSL encryption: All data transmitted between your device and the combowin platform is encrypted using SSL/TLS to prevent interception.
• OTP verification: Login from unrecognised devices triggers a one-time password verification step sent to your registered mobile number.
• Access controls: Internal access to personal data is restricted to personnel who need it to perform their role. Access is logged and monitored.
• Secure storage: Sensitive data including KYC documents and financial records are stored in secured, access-controlled environments.

While combowin takes reasonable steps to protect your data, no internet-based platform can guarantee absolute security. You are responsible for keeping your login credentials private. If you suspect unauthorised access to your account, contact support immediately at [email protected].

7 Data Retention

combowin retains your personal data for as long as your account is active and for a period after account closure, as required to meet legal, compliance, and dispute resolution obligations.

Specific retention periods vary depending on the type of data:

• Identity and KYC documents are retained for the period required under applicable anti-money-laundering regulations.
• Transaction records in PHP are retained for the period required by applicable financial record-keeping obligations.
• Support communications are retained for a reasonable period to support quality management and dispute resolution.

When data is no longer required for any of the above purposes, it is securely deleted or anonymised.

8 Cookies and Tracking Technologies

combowin uses cookies — small text files stored on your device — and similar session-tracking technologies for the following purposes:

• Session management: To keep you logged in during your combowin session without requiring you to re-enter credentials on every page.
• Security: To detect unusual access patterns and protect your account from session hijacking.
• Platform analytics: To understand how players navigate the platform, which game categories are most visited, and where interface improvements can be made.
• Performance: To ensure pages load efficiently on the devices used by Filipino players, including mobile browsers and the combowin app.

combowin does not use cookies to serve third-party advertising on the platform. Most browsers allow you to manage or block cookies through their settings, though disabling session cookies may affect your ability to log in and use the platform normally.

9 Your Rights Over Your Personal Data

As a combowin account holder, you have the following rights regarding your personal data:

To exercise any of these rights, contact us at [email protected] with your registered email address and a description of your request. We will respond as promptly as possible. Note that some requests may be subject to identity verification before we can act on them.

10 Minors

combowin is strictly for users aged 21 and above. We do not knowingly collect personal data from individuals under 21 years of age. Age is confirmed during the KYC verification process using a valid Philippine government-issued ID.

If we become aware that personal data has been collected from a person under 21, that account will be immediately closed and any associated data will be deleted in accordance with our retention policy, except where retention is required for legal or compliance purposes.

If you believe a minor has registered an account on combowin, please contact [email protected] immediately.

11 Changes to This Privacy Policy

combowin may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable legal requirements. When material changes are made, the updated policy will be posted on this page with a revised "Last updated" date.

We recommend reviewing this page periodically. Continued use of the combowin platform after an updated Privacy Policy is posted constitutes your acceptance of the revised terms. If you have concerns about any update, contact us at [email protected] or review your options under the Terms and Conditions.

12 Contact for Privacy Matters

For all privacy-related enquiries — including data access, correction, deletion, and objection requests — contact our support team:

[email protected]

Related documents that form part of the overall combowin data and conduct framework: