w2j Privacy Policy

1. Introduction

w2j ("the Platform," "we," "us," "our") is committed to protecting the privacy and personal data of all individuals who use the w2j online gaming platform. This Privacy Policy describes how w2j collects, processes, stores, shares, and protects personal data in connection with the provision of our services to players in the Philippines and other jurisdictions where w2j operates.

This Privacy Policy is prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). w2j takes its obligations as a personal information controller seriously and has implemented appropriate technical and organizational measures to safeguard the personal data entrusted to us by our players.

This Privacy Policy should be read alongside the w2j Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your relationship with the w2j platform.

2. Personal Data We Collect

w2j collects personal data that is necessary for the provision of our gaming services, compliance with legal obligations, and the protection of our players and platform. The categories of personal data we collect include the following:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (for age verification purposes — w2j is strictly 21+ only)
• Residential address, including barangay, city, province, and postal code
• Email address and mobile phone number
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license)
• Selfie or photograph submitted for identity verification

2.2 Financial Data

• GCash account number or registered mobile number
• PayMaya account details
• Bank account details for BPI, BDO, or Metrobank transactions
• Transaction history, including deposit amounts, withdrawal amounts, and dates
• Source of funds declarations where required by AML regulations

2.3 Gaming Activity Data

• Game session history, including games played, wager amounts, and outcomes
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
• Account login history, including timestamps and IP addresses

2.4 Technical and Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser information
• Unique device identifiers
• Cookie identifiers and session tokens
• Platform usage data, including pages visited and features accessed

2.5 Communications Data

• Records of communications with w2j customer support
• Feedback, complaints, and dispute records
• Marketing preference settings and communication opt-in/opt-out records

3. How We Collect Your Data

w2j collects personal data through the following means:

• Direct submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Data collected automatically when you access the w2j platform, including technical and device data collected via cookies, log files, and similar tracking technologies.
• Third-party sources: Data received from payment processors (GCash, PayMaya, BPI, BDO, Metrobank) in connection with transaction processing, and from identity verification service providers in connection with KYC compliance.
• Regulatory sources: Data received from regulatory authorities, law enforcement agencies, or other competent bodies in connection with legal obligations or investigations.

4. How We Use Your Personal Data

w2j uses the personal data we collect for the following purposes:

5. Legal Basis for Processing

w2j processes your personal data on the following legal bases under the Data Privacy Act of 2012 (RA 10173):

• Contractual necessity: Processing required to perform our obligations under the w2j Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, age verification requirements, and regulatory reporting duties.
• Legitimate interests: Processing necessary for w2j's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

w2j does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

6.1 Service Providers

w2j engages trusted third-party service providers to assist in the delivery of our services. These include payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting providers, and customer support platform providers. All service providers are contractually bound to process your data only on w2j's instructions and in accordance with applicable data protection law.

6.2 Regulatory and Law Enforcement Authorities

w2j may disclose personal data to the Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other competent authorities where required by law, court order, or regulatory instruction. Such disclosures will be made only to the extent required and will be documented in accordance with w2j's internal compliance procedures.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of w2j's business, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and the privacy practices of the acquiring entity prior to your data being transferred.

7. Cookies and Tracking Technologies

The w2j platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and collect analytics data. The types of cookies used by w2j include the following:

• Essential cookies: Required for the platform to function correctly. These include session authentication cookies and security tokens. These cookies cannot be disabled without affecting platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the w2j platform, enabling us to identify areas for improvement. This data does not identify individual users.
• Marketing cookies: Used to deliver relevant promotional content within the w2j platform, based on your gaming activity and preferences. These cookies are only activated where you have consented to marketing communications.

You may manage your cookie preferences through your browser settings. Please note that disabling essential cookies may prevent you from accessing certain features of the w2j platform. For more information on managing cookies, refer to your browser's help documentation.

8. Data Retention

w2j retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements under Philippine law.
• Financial transaction data: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act (AMLA) and its amendments.
• Gaming activity data: Retained for a minimum of three (3) years following account closure, for dispute resolution and regulatory compliance purposes.
• Communications data: Retained for a minimum of two (2) years from the date of the communication, for customer service quality and dispute resolution purposes.
• Technical and device data: Retained for a maximum of twelve (12) months from collection, unless required for longer retention in connection with a security investigation or legal proceeding.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with w2j's data disposal procedures.

9. Data Security

w2j implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and the w2j platform is encrypted using TLS (Transport Layer Security) protocols. Sensitive data at rest, including financial information and identity documents, is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorized w2j personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular data protection training.
• Secure infrastructure: w2j's platform is hosted on secure, certified cloud infrastructure with regular security audits, penetration testing, and vulnerability assessments.
• Two-factor authentication: w2j supports and encourages the use of two-factor authentication (2FA) for all player accounts to reduce the risk of unauthorized access.
• Incident response: w2j maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, w2j will notify the National Privacy Commission (NPC) and affected players within the timeframes required by law.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by w2j:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and shared. This Privacy Policy fulfils that obligation.
• Right of access: You have the right to request a copy of the personal data w2j holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to w2j's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on w2j's legitimate interests.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that w2j has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact the w2j Data Privacy Officer at the contact details provided in Section 13. w2j will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11. Children's Privacy

If w2j discovers or is notified that personal data has been collected from an individual under the age of 21, we will immediately suspend the relevant account, delete all associated personal data, and reverse any financial transactions where possible. If you believe that a minor has registered on the w2j platform, please contact us immediately at the details provided in Section 13.

Parents and guardians are encouraged to monitor the online activities of minors in their care and to make use of parental control tools available on devices and internet service providers to prevent access to online gaming platforms.

12. Changes to This Privacy Policy

w2j reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, w2j will notify registered players via email or a prominent notice on the platform prior to the changes taking effect.

The effective date at the top of this Privacy Policy indicates when it was last updated. Your continued use of the w2j platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how w2j protects your data.

13. Contact Our Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by w2j, please contact our designated Data Privacy Officer (DPO) through the following channel:

For general support inquiries unrelated to data privacy, please contact our main support team at [email protected]. For responsible gaming concerns, please visit our Responsible Gaming page.