windreama Privacy Policy

1. Data Controller

windreama, operating windreama.club, is the data controller responsible for the personal data of players and visitors processed in connection with the windreama platform. For all data protection enquiries, players may contact windreama at the details provided in Section 10 of this policy.

2. Personal Data We Collect

windreama collects personal data in the following categories depending on how you interact with the platform:

2.1 Registration and Identity Data

When you create a windreama account, we collect: full legal name, date of birth, residential address in the Philippines, mobile number, email address, and Philippine government-issued identity document details (document type, document number, and document image). This data is required for identity verification (KYC) and to confirm eligibility to use windreama.

2.2 Financial Data

windreama collects data necessary to process deposits and withdrawals, including: GCash mobile number, Maya account reference, bank account details (for bank transfer withdrawals), and transaction history. windreama does not store full payment instrument credentials on its own servers — payment processing is handled by licensed payment service providers operating under Philippine BSP regulations.

2.3 Gameplay and Activity Data

windreama records all gameplay activity associated with your account, including: game sessions played, wagers placed, game outcomes, bonus usage, sports bets placed, and session timestamps. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory compliance.

2.4 Technical and Device Data

windreama automatically collects technical data when you access the platform, including: IP address, device type and operating system, browser type and version, session duration, pages visited, and referring URL. This data is used for security monitoring, fraud detection, and platform performance optimisation.

2.5 Communication Data

When you contact windreama support via live chat or email, we retain records of those communications, including the content of messages exchanged, for quality assurance, training, and dispute resolution purposes.

3. How windreama Uses Your Personal Data

windreama uses personal data collected from players for the following purposes:

• Account creation and management: Registering your windreama account, verifying your identity, and maintaining your player profile.
• Payment processing: Processing GCash deposits, bank transfers, and withdrawal requests to your registered payment instruments.
• Regulatory compliance: Meeting windreama's obligations under applicable Philippine gaming regulations, including age verification, anti-money laundering (AML), and counter-terrorism financing (CTF) requirements.
• Fraud and security: Detecting and preventing unauthorised access, account takeover, bonus abuse, collusion, and other fraudulent or prohibited conduct.
• Customer support: Responding to player enquiries, processing complaints, and resolving disputes.
• Responsible gaming: Monitoring gameplay patterns to identify players who may be at risk of problem gambling and proactively offering responsible gaming tools and support information.
• Platform improvement: Analysing aggregate, anonymised usage data to improve windreama's game offering, user interface, and technical performance.
• Marketing communications (opt-in only): Sending promotional offers, bonus notifications, and windreama news to players who have explicitly consented to receive such communications. Players may withdraw marketing consent at any time via account settings.

4. Sharing Your Personal Data

windreama does not sell, rent, or trade your personal data. windreama may share personal data with third parties only in the following limited circumstances:

• Payment service providers: GCash, Maya, and banking partners receive the minimum data necessary to process your transactions. All payment partners are subject to BSP regulations and maintain their own data protection obligations.
• Game software providers: Game suppliers may receive anonymised session data for technical integration purposes. windreama does not share personally identifiable information with game providers unless required for dispute resolution.
• Identity verification services: windreama uses licensed KYC verification providers to validate Philippine government identity documents. These providers process data under strict contractual data processing agreements.
• Regulatory and law enforcement authorities: windreama will disclose personal data to Philippine gaming regulators, the National Privacy Commission, law enforcement agencies, and courts where legally required to do so, including in connection with AML/CTF reporting obligations.
• Professional advisers: windreama's legal, accounting, and audit advisers may access personal data on a strictly confidential, need-to-know basis.

All third parties who receive personal data from windreama are required to handle such data in accordance with applicable Philippine data protection law and windreama's contractual data processing requirements.

5. Cookies and Tracking Technologies

windreama uses cookies and similar tracking technologies to operate and improve the platform. The categories of cookies windreama uses are:

• Strictly necessary cookies: Required for the windreama platform to function. These include session authentication cookies and security tokens. These cannot be disabled without breaking core platform functionality.
• Performance cookies: Anonymous analytics cookies that help windreama understand how players interact with the platform — which pages are visited most frequently, how long sessions last, and where technical errors occur. Data is aggregated and not linked to individual players.
• Functional cookies: Remember your preferences such as language setting, preferred game lobby view, and "Remember me" login status on trusted devices.
• Marketing cookies (opt-in): Used only with your consent to deliver relevant windreama promotional content. You may withdraw consent for marketing cookies at any time via your windreama account settings or browser preferences.

By continuing to use windreama, you consent to the placement of strictly necessary cookies. Consent for non-essential cookies is requested separately and is freely withdrawable at any time.

6. Data Retention

windreama retains personal data only for as long as necessary for the purposes set out in this Privacy Policy or as required by applicable Philippine law. Key retention periods are:

• Account data and KYC records: Retained for a minimum of 5 years following account closure, in accordance with Philippine AML regulations requiring retention of customer identification records.
• Transaction and gameplay records: Retained for 5 years from the date of each transaction, consistent with regulatory requirements applicable to Philippine gaming operators.
• Support communications: Retained for 2 years from the date of the last communication, to support dispute resolution and quality assurance.
• Marketing preferences: Retained until you withdraw consent or request deletion of this data, whichever occurs first.
• Technical and device data: Retained for 12 months from collection, unless required for longer periods in connection with an active fraud investigation or legal proceeding.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

7. Data Security

windreama implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS 1.3 encryption for all data in transit between your device and windreama servers.
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records.
• Multi-factor authentication required for all windreama staff accessing production systems containing player data.
• Role-based access controls limiting staff access to personal data strictly to their job function.
• Regular security audits, penetration testing, and vulnerability assessments conducted by qualified third-party specialists.
• Automated intrusion detection systems monitoring for unusual access patterns or data exfiltration attempts.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, windreama will notify the National Privacy Commission and affected players in accordance with the notification requirements of the Philippine Data Privacy Act and its implementing rules.

8. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, windreama players have the following rights with respect to their personal data:

To exercise any of the above rights, submit a written request to windreama support. windreama will respond within 15 business days of receiving a verified request. Identity verification may be required before requests are processed.

9. Minors and Age Restriction

windreama does not knowingly collect personal data from individuals under 21 years of age. The minimum age for online casino gambling in the Philippines is 21 years. windreama enforces this requirement through mandatory KYC identity verification at account registration. If windreama discovers that personal data has been collected from a person under 21, the account will be immediately suspended, all balances forfeited, and the personal data deleted in accordance with this policy. If you believe windreama has inadvertently collected data from a minor, please contact windreama support immediately.

10. Changes to This Privacy Policy

windreama may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or platform features. Material changes will be communicated to registered players via email notification or in-platform notice at least 7 days before the revised policy takes effect. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of windreama after the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

11. Contact and Data Protection Enquiries

For all privacy-related enquiries, data subject requests, or concerns regarding windreama's data processing practices, please contact windreama's Data Protection Officer:

• Email: [email protected] — please include "Privacy / Data Request" in the subject line
• Live Chat: Available 24/7 on windreama.club — ask to be connected to the Data Protection team
• Response Time: windreama aims to acknowledge all privacy requests within 2 business days and provide a substantive response within 15 business days

windreama is committed to resolving privacy concerns promptly and transparently. If you are not satisfied with windreama's response, you may escalate your complaint to the Philippines National Privacy Commission.