Privacy Policy – mlwn Casino

1 Introduction

1.1 mlwn Casino is committed to protecting the privacy and personal data of all players and visitors to the mlwn platform. We recognize that your personal information is important to you, and we take our responsibilities as a data controller seriously.

1.2 This Policy has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

1.3 This Policy applies to all personal data collected through the mlwn website, mobile platform, customer support channels, and any other services operated by mlwn. It should be read together with our Terms & Conditions.

1.4 If you have any questions about this Policy or how mlwn handles your personal data, please contact us using the details provided in Section 13 of this Policy.

2 Personal Data We Collect

2.1 mlwn collects personal data that is necessary for the provision of our services, compliance with legal obligations, and the improvement of the player experience. The categories of personal data we collect include:

2.2 mlwn does not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for legal compliance purposes, such as anti-money laundering verification.

3 How We Collect Your Data

3.1 mlwn collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Data collected automatically when you use the mlwn platform, including cookies, web beacons, log files, and similar tracking technologies (see Section 9);
• Third-party sources: Data received from payment processors (such as GCash and Maya), identity verification providers, fraud prevention services, and analytics partners, where permitted by law;
• Publicly available sources: Information from public databases or government records used for identity verification or fraud prevention purposes.

3.2 mlwn will always collect personal data through fair and lawful means, and only to the extent necessary for the purposes described in this Policy.

4 How We Use Your Personal Data

4.1 mlwn uses your personal data for the following purposes:

• Account management: To create, verify, and maintain your mlwn player account;
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of mlwn platform features;
• Identity and age verification: To confirm that you are at least 21 years of age and to comply with KYC requirements under Philippine law;
• Legal and regulatory compliance: To meet our obligations under the Anti-Money Laundering Act (AMLA), PAGCOR regulations, the Data Privacy Act, and other applicable Philippine laws;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other illegal activities;
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Responsible gaming: To monitor gameplay patterns and implement responsible gaming measures where appropriate;
• Marketing and promotions: To send you relevant offers, bonuses, and platform updates, where you have provided consent to receive such communications;
• Platform improvement: To analyze usage patterns, conduct research, and improve the mlwn platform and user experience.

4.2 mlwn will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by law.

5 Legal Basis for Processing

5.1 mlwn processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary for the performance of the contract between you and mlwn (i.e., the Terms & Conditions), including account creation, game access, and payment processing;
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including AMLA, PAGCOR requirements, and tax obligations;
• Legitimate interests: Processing is necessary for mlwn's legitimate interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights;
• Consent: For marketing communications and non-essential cookies, mlwn relies on your freely given, specific, and informed consent. You may withdraw consent at any time.

6 Data Sharing & Disclosure

6.1 mlwn does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary and permitted by law:

• Payment processors: GCash, Maya, and banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals;
• Identity verification providers: Third-party KYC and age verification services used to confirm player identity and age;
• Fraud prevention and security services: Providers that assist mlwn in detecting and preventing fraudulent activity;
• Analytics providers: Services that help mlwn understand platform usage and improve the player experience, using aggregated or anonymized data where possible;
• Regulatory authorities: The Anti-Money Laundering Council (AMLC), PAGCOR, the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or court order;
• Professional advisers: Lawyers, auditors, and other professional advisers bound by confidentiality obligations.

6.2 All third parties with whom mlwn shares personal data are required to handle such data in accordance with applicable data privacy laws and mlwn's data processing standards.

6.3 mlwn does not transfer personal data outside the Philippines except where required by law or where adequate data protection safeguards are in place.

7 Data Retention

7.1 mlwn retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AMLA and PAGCOR record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations;
• KYC documents: Retained for a minimum of five (5) years after the end of the business relationship;
• Customer support records: Retained for up to three (3) years from the date of the interaction;
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.

7.2 When personal data is no longer required, mlwn will securely delete or anonymize it in accordance with our data disposal procedures.

8 Data Security

8.1 mlwn implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the mlwn platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Access controls limiting personal data access to authorized mlwn personnel on a need-to-know basis;
• Regular security audits and vulnerability assessments of the mlwn platform;
• Two-factor authentication options for player accounts;
• Secure data centers with physical access controls and environmental safeguards.

8.2 While mlwn takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. mlwn cannot guarantee absolute security of your data.

8.3 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, mlwn will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act.

9 Cookies & Tracking Technologies

9.1 mlwn uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and deliver relevant content. The types of cookies we use include:

• Essential cookies: Necessary for the platform to function correctly, including session management and security features. These cannot be disabled;
• Analytics cookies: Used to collect anonymized information about how players use the mlwn platform, helping us improve performance and user experience;
• Preference cookies: Used to remember your settings and preferences, such as language and display options;
• Marketing cookies: Used to deliver relevant promotions and offers based on your activity on the mlwn platform. These are only set with your consent.

9.2 You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the mlwn platform.

9.3 mlwn does not use cookies to collect sensitive personal information or to track your activity on third-party websites.

10 Your Data Privacy Rights

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by mlwn:

• Right to be informed: The right to know what personal data mlwn collects about you and how it is used;
• Right of access: The right to request a copy of the personal data mlwn holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to mlwn's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another data controller;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

10.2 To exercise any of the above rights, please contact mlwn's Data Protection Officer using the contact details in Section 13. mlwn will respond to your request within a reasonable timeframe and in accordance with applicable law.

11 Children's Privacy & Age Restriction

11.1 The mlwn platform is strictly intended for persons aged 21 years and above, in accordance with Philippine law and PAGCOR regulations. mlwn does not knowingly collect personal data from persons under the age of 21.

11.2 If mlwn becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete such data and close the associated account. Any winnings associated with an underage account will be forfeited.

11.3 If you are a parent or guardian and believe that your child has provided personal data to mlwn, please contact us immediately using the details in Section 13 so that we can take appropriate action.

12 Updates to This Privacy Policy

12.1 mlwn reserves the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page with an updated effective date. Where changes are material, mlwn will notify registered players via email or a prominent notice on the platform.

12.2 Your continued use of the mlwn platform following the posting of any changes to this Policy constitutes your acceptance of those changes. We encourage you to review this Policy periodically to stay informed about how mlwn protects your personal data.

12.3 This Privacy Policy was last updated in May 2026 and supersedes all prior versions.

13 Contact & Data Protection Officer

13.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by mlwn, please contact our Data Protection Officer:

mlwn Casino – Data Protection Officer
Email: [email protected]
Support Hours: Daily, 8:00 AM – 12:00 MN Philippine Standard Time (PST)

13.2 If you are not satisfied with mlwn's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.