Privacy Policy

1Introduction

This Privacy Policy ("Policy") describes how bullwin ("bullwin," "we," "us," or "our"), the operator of the online gaming platform at https://bullwin.vip ("Platform"), collects, uses, stores, and discloses personal information relating to registered members and visitors ("you" or "User").

bullwin is committed to protecting the privacy and personal data of every Filipino player who trusts our platform. This Policy is drafted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission ("NPC") of the Philippines.

By registering an Account or using the bullwin Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, please discontinue use of the Platform.

2Data Controller

bullwin is the data controller responsible for your personal information collected through the Platform. As a PAGCOR-licensed operator, bullwin is also subject to PAGCOR's data governance requirements, which complement and operate alongside the DPA framework.

For all data privacy enquiries, data subject access requests, and complaints, you may contact bullwin's designated Data Protection Officer at the email address listed in the footer of this site. bullwin aims to respond to all privacy-related requests within fifteen (15) business days.

3Personal Data We Collect

bullwin collects personal data in the following categories:

3.1 Registration Data. When you create a bullwin Account, we collect your full legal name, date of birth, Philippine mobile number, email address, and residential address. This data is necessary to create and maintain your Account and to verify your age and identity as required by PAGCOR.

3.2 Identity Verification (KYC) Data. To enable withdrawals and comply with PAGCOR licensing requirements and anti-money laundering obligations, bullwin collects copies of government-issued Philippine identification documents (e.g., PhilSys ID, passport, driver's licence, UMID), and in some cases a selfie photograph or proof of address. KYC data is used solely for verification and regulatory compliance purposes.

3.3 Financial Data. bullwin collects transaction data relating to deposits and withdrawals, including GCash account numbers, PayMaya account details, and Philippine bank account numbers used for transfers (BPI, BDO, Metrobank, and others). Full card numbers are never stored by bullwin — payment processing is handled by certified payment service providers who maintain their own PCI-DSS compliance.

3.4 Gaming Activity Data. We collect records of your gaming activity on the Platform, including game sessions, bets placed, outcomes, and account balance history. This data is required for regulatory reporting to PAGCOR, dispute resolution, and responsible gaming monitoring.

3.5 Technical & Device Data. When you access the Platform, we automatically collect technical data including your IP address, device type, operating system, browser type, and session timestamps. This data is used for security monitoring, fraud detection, and platform performance optimization.

3.6 Communications Data. If you contact bullwin's support team, we retain records of that communication, including chat transcripts, email correspondence, and any information you provide during the support interaction.

3.7 Marketing Preferences. With your consent, we record your preferences regarding promotional communications. You may update your preferences at any time through your account settings.

4How We Use Your Personal Data

bullwin uses the personal data we collect for the following purposes:

• To create, manage, and maintain your bullwin Account.
• To verify your identity and age in compliance with PAGCOR KYC requirements.
• To process deposits and withdrawals in Philippine Pesos through your selected payment method.
• To provide access to all games and services on the bullwin Platform.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities.
• To comply with PAGCOR regulatory reporting obligations and respond to lawful requests from Philippine government authorities.
• To monitor gaming activity for responsible gaming purposes and enforce self-imposed limits and exclusions.
• To provide customer support and resolve disputes.
• To send transactional communications (deposit confirmations, withdrawal notifications, security alerts) to your registered mobile or email.
• To send promotional communications, where you have provided explicit consent.
• To improve Platform performance, security, and user experience through analysis of anonymized usage data.

5Legal Bases for Processing

Under the Philippine Data Privacy Act, bullwin processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil the Account Agreement and provide the services you have requested (e.g., account management, payment processing, game access).
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, anti-money laundering laws, and other applicable Philippine regulations.
• Legitimate interest: Processing for fraud prevention, security monitoring, and Platform improvement, where these interests do not override your fundamental rights.
• Consent: Processing of data for marketing communications, where you have given explicit, freely withdrawable consent.

6Data Sharing & Disclosure

bullwin does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only in the following circumstances:

6.1 Regulatory Authorities. bullwin shares data with PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies as required by law or regulatory directive. Such sharing is mandatory and not subject to your opt-out right.

6.2 Service Providers. bullwin engages trusted third-party service providers to operate certain functions of the Platform, including payment processing, KYC verification, fraud detection, cloud infrastructure, and customer support tools. All service providers are bound by data processing agreements that prohibit use of your data beyond the specific service purpose and require security measures equivalent to those maintained by bullwin.

6.3 Game Studios. Certain game studios providing games on the bullwin Platform may receive anonymized session data for game performance monitoring. No personally identifiable information is shared with game studios.

6.4 Legal Proceedings. bullwin may disclose personal data where required by a valid court order, subpoena, or other lawful legal process under Philippine law.

6.5 Business Transfers. In the event of a merger, acquisition, or transfer of all or substantially all of bullwin's assets, personal data held by bullwin may be transferred to the successor entity, provided that the successor is bound by equivalent privacy obligations.

7Cookies & Tracking Technologies

The bullwin Platform uses cookies and similar tracking technologies to maintain your session, remember your preferences, and support Platform security. The following cookie categories are used:

• Essential cookies: Required for Platform functionality including maintaining your logged-in session and security tokens. These cannot be disabled without rendering the Platform non-functional.
• Performance cookies: Anonymized data on page load times and error rates used to improve Platform reliability. No personally identifiable data is collected through these cookies.
• Preference cookies: Store your language, display, and notification preferences to improve your experience on return visits.

bullwin does not use third-party advertising cookies or cross-site tracking technologies. You may manage cookie preferences through your browser settings; however, disabling essential cookies will impair Platform functionality including login.

8Data Retention

bullwin retains personal data for as long as necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods required by PAGCOR and applicable Philippine law:

• Account registration and KYC data: minimum five (5) years from account closure.
• Transaction and gaming activity records: minimum five (5) years from the date of each transaction, in accordance with AMLC requirements.
• Communications and support records: three (3) years from the date of the communication.
• Marketing consent records: retained for the duration of active consent and for one (1) year following withdrawal of consent for audit purposes.

Following expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized.

9Data Security

bullwin implements technical and organizational security measures appropriate to the nature and volume of personal data processed. These measures include TLS encryption for all data in transit, encryption of sensitive data at rest, access controls limiting personal data access to authorized personnel on a need-to-know basis, regular security assessments and penetration testing, and incident response procedures aligned with NPC notification requirements.

In the event of a personal data breach that poses a real risk of serious harm to data subjects, bullwin will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected Members without undue delay in accordance with DPA requirements.

10Your Data Subject Rights

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

• Right to be informed: The right to know how your personal data is collected, processed, and used — which this Policy fulfils.
• Right of access: The right to request a copy of the personal data bullwin 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 legal and regulatory retention obligations that may prevent full deletion.
• Right to data portability: The right to receive your personal data in a structured, commonly used format for transfer to another controller.
• Right to object: The right to object to processing of your personal data for direct marketing purposes. You may also object to other processing on grounds relating to your particular situation.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe bullwin has violated your data privacy rights.

To exercise any of the above rights, contact bullwin's Data Protection Officer at the email address listed in the footer. bullwin will respond within fifteen (15) business days of receiving a verified request. We may require identity verification before processing access or deletion requests to protect against unauthorized disclosure.

11Children and Minors

The bullwin Platform is strictly for persons aged twenty-one (21) years and above, as required by PAGCOR. bullwin does not knowingly collect personal data from persons under 21. Age is verified through the mandatory KYC process. If bullwin becomes aware that personal data has been collected from a person under 21, the relevant account will be immediately closed and all collected data will be deleted in accordance with PAGCOR protocol, except where retention is required for regulatory compliance.

If you are a parent or guardian and believe a minor has registered an account on the bullwin Platform, please contact our support team immediately for urgent account review and closure.

12Cross-Border Data Transfers

The bullwin Platform and its primary data storage infrastructure are based in the Philippines. Where bullwin engages service providers that process data outside the Philippines (for example, cloud infrastructure providers or international KYC verification services), such transfers are subject to data processing agreements that require equivalent privacy protections and comply with NPC guidelines on cross-border data transfers. bullwin does not transfer personal data internationally without appropriate safeguards in place.

13Third-Party Links

The bullwin Platform does not contain links to external third-party websites. Any links within the Platform navigate exclusively to other pages within the bullwin domain. This Policy applies only to the bullwin Platform. bullwin is not responsible for the privacy practices of any third-party services you may access independently.

14Policy Updates

bullwin may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or Platform features. Material changes will be communicated to registered Members via the mobile number or email address on file. The updated Policy will be published on this page with a revised effective date. Continued use of the Platform following the effective date of any update constitutes acceptance of the revised Policy. We encourage you to review this page periodically.

15Contact & Data Protection Officer

For all privacy-related enquiries, data subject rights requests, or complaints, please contact bullwin's Data Protection Officer. Contact details are available in the footer of this site. bullwin's support team is also available 24/7 through in-platform live chat for general account assistance.

You may also direct complaints to the National Privacy Commission of the Philippines through NPC's official complaint channels if you believe your data privacy rights have been violated and bullwin has not adequately addressed your concern.

Reminder: bullwin will never request your password, full payment card details, or OTP codes via email, chat, or phone. Any such request should be treated as a phishing attempt — please report it to us immediately.