cudwin Privacy Policy

cudwin ("we," "us," "our," or "cudwin") is committed to protecting the privacy and personal data of all users of the cudwin online gaming platform. This Privacy Policy ("Policy") describes how cudwin collects, uses, stores, shares, and protects personal data in connection with the operation of cudwin.cam and all related services, features, and communications.

This Policy is prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Republic of the Philippines, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). It applies to all natural persons — whether residents of Metro Manila, Cebu, Davao, or any other part of the Philippines — who interact with the cudwin platform in any capacity.

This Policy should be read alongside cudwin's Terms & Conditions and Responsible Gaming Policy, both of which are available on this website and are incorporated by reference into the overall contractual relationship between you and cudwin.

For the purposes of the Data Privacy Act of 2012, cudwin is the personal information controller in respect of all personal data collected and processed through the cudwin.cam platform. As personal information controller, cudwin determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

If you have questions or concerns about how your personal data is handled, or if you wish to exercise any of your data subject rights under Philippine law, you may contact cudwin's designated Data Privacy Officer at:

Email: [email protected] (plain text — not a clickable link)

cudwin collects personal data in the following categories, depending on your interaction with the platform:

a) Registration & Account Data — Information you provide when creating a cudwin account, including your full legal name, date of birth, gender, nationality, residential address in the Philippines, email address, and Philippine mobile number (in +63 format).

b) Identity Verification (KYC) Data — Documents and information submitted during the identity verification process, including scans or photographs of Philippine government-issued identification documents (passport, driver's license, SSS ID, PhilHealth ID, UMID, or postal ID), selfie photographs, and proof of address documents.

c) Financial Data — Information relating to your deposits, withdrawals, and transaction history on the cudwin platform, including payment method details (e-wallet account references, bank account numbers where applicable), transaction amounts in Philippine Peso (₱), and timestamps. cudwin does not store full card numbers or full GCash PINs.

d) Gaming Activity Data — Records of your gameplay on the cudwin platform, including games played, bets placed, outcomes, session durations, and bonus usage. This data is used for account management, fraud detection, and responsible gaming monitoring.

e) Technical & Device Data — Information automatically collected when you access the cudwin platform, including your IP address, device type and model, operating system and version, browser type, screen resolution, unique device identifiers, and mobile network information.

f) Communications Data — Records of your communications with cudwin's customer support team via live chat, email, or any other channel, including the content of messages and timestamps.

g) Marketing Preferences Data — Your opt-in or opt-out status for cudwin marketing communications, and records of your interactions with promotional emails or notifications.

cudwin uses the personal data it collects for the following purposes:

• Account creation and management — to register, maintain, and administer your cudwin player account.
• Identity verification — to verify your identity and age (21+) in compliance with PAGCOR and AML requirements before processing withdrawals.
• Payment processing — to process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other supported Philippine payment methods.
• Fraud and money laundering prevention — to detect, investigate, and prevent fraudulent activity, bonus abuse, and financial crimes as required by Philippine AML legislation.
• Platform operation and improvement — to provide, maintain, and improve cudwin's services, games, and user interface based on usage patterns and player feedback.
• Responsible gaming — to monitor gameplay patterns, enforce self-exclusion requests, manage deposit and loss limits, and identify players who may be showing signs of problem gambling.
• Customer support — to respond to your enquiries, resolve disputes, and provide assistance with your cudwin account.
• Legal compliance — to comply with applicable Philippine laws, regulations, court orders, and lawful requests from regulatory authorities including PAGCOR, AMLC, and the NPC.
• Marketing communications — to send promotional offers, bonus notifications, and platform updates where you have opted in to receive such communications from cudwin.
• Security — to protect the security and integrity of the cudwin platform, detect unauthorised access, and safeguard player data.

cudwin processes your personal data on one or more of the following lawful bases as recognised under the Data Privacy Act of 2012:

Contractual necessity — Processing is necessary for the performance of the contract between you and cudwin, i.e., to operate your account, process financial transactions, and provide the gaming services you have requested.

Legal obligation — Processing is required to comply with cudwin's legal obligations under Philippine law, including anti-money laundering obligations, identity verification requirements, and reporting obligations to regulatory bodies such as PAGCOR and AMLC.

Legitimate interests — Processing is necessary for cudwin's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and the improvement of our services, provided that such interests do not override your own rights and interests.

Consent — Where required by law, cudwin will obtain your explicit consent before processing your data for specific purposes, such as direct marketing communications. You may withdraw consent at any time by contacting cudwin support or adjusting your account notification preferences.

cudwin does not sell, rent, lease, or trade your personal data to third parties for their own commercial purposes. Your data may be shared with third parties only in the following circumstances:

a) Service Providers: cudwin engages trusted third-party service providers who process data on our behalf for specific operational purposes, including payment processing partners (GCash, Maya, BPI, BDO, Metrobank), identity verification and KYC platforms, cloud infrastructure providers, fraud detection services, customer support tools, and analytics services. These providers are bound by contractual obligations to process your data only as instructed by cudwin and to maintain appropriate security standards.

b) Game Providers: Certain game content on the cudwin platform is supplied by licensed third-party game providers. Minimal technical data (such as session tokens and bet amounts) may be shared with game providers solely to facilitate gameplay. These providers do not receive personally identifiable information beyond what is technically required to operate the game session.

c) Regulatory and Law Enforcement Authorities: cudwin may disclose personal data to PAGCOR, AMLC, the National Privacy Commission, the Philippine National Police, or any other competent Philippine authority where required by law, court order, or regulatory directive.

d) Business Transfers: In the event of a merger, acquisition, restructuring, or sale of cudwin's business or assets, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and the applicable privacy terms.

The cudwin platform uses cookies and similar tracking technologies to enhance your browsing and gaming experience, maintain your login session, analyse platform usage, and serve relevant content. The following categories of cookies are used:

Strictly Necessary Cookies: Essential for the operation of the cudwin platform. These include session cookies that keep you logged in during a single browser session and security cookies that help protect against cross-site request forgery. These cookies cannot be disabled without affecting core platform functionality.

Performance and Analytics Cookies: Used to collect anonymised data about how visitors use the cudwin platform — such as which pages are visited most frequently and how players navigate between game categories. This data helps cudwin improve the platform experience. These cookies do not identify you personally.

Functional Cookies: Allow the cudwin platform to remember your preferences, such as language settings, display preferences, and previously viewed game categories, so that your experience is personalised across sessions.

Marketing Cookies: Where you have consented to marketing communications, these cookies help cudwin understand your engagement with promotional content and optimise the relevance of offers presented to you. You may opt out of marketing cookies at any time via your browser settings or by contacting cudwin support.

You can manage or disable non-essential cookies through your browser settings. Note that disabling cookies may affect the functionality of certain parts of the cudwin platform.

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

Active Account Data: Personal data associated with an active cudwin account is retained for the duration of the account relationship and for a period of at least five (5) years following the closure of the account, in compliance with AML record-keeping requirements under the AMLA of the Philippines.

Financial Transaction Records: Records of all financial transactions (deposits, withdrawals, bets) are retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML legislation.

KYC Documents: Identity verification documents are retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later.

Support Communications: Customer support interaction records are retained for two (2) years from the date of each interaction, unless related to an ongoing dispute or legal matter, in which case records are retained until the matter is fully resolved.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with cudwin's data disposal procedures, unless continued retention is required by a court order or regulatory directive.

cudwin implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption on all data transmissions between your device and the cudwin platform;
• Encryption of sensitive data at rest on cudwin's servers;
• Strict role-based access controls, limiting access to personal data to authorised personnel only;
• Comprehensive audit logging of all access to personal data systems;
• Regular security vulnerability assessments and penetration testing;
• Mandatory security training for all cudwin staff who handle personal data;
• Incident response procedures to contain and remediate data security breaches promptly.

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, cudwin will notify the National Privacy Commission and, where required, affected data subjects within the timeframes mandated by the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

While cudwin takes all reasonable steps to protect your data, no system is completely immune from security risks. You also bear responsibility for maintaining the confidentiality of your cudwin login credentials and for using the platform on secure, trusted devices and networks.

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by cudwin:

To exercise any of the rights above, please contact cudwin's Data Privacy Officer via live chat or email at [email protected]. cudwin will respond to all data subject requests within thirty (30) days of receipt, or within such extended period as may be permitted by applicable law where the request is complex or where cudwin has received a high volume of requests concurrently.

The cudwin platform is strictly intended for individuals aged 21 years and above in accordance with PAGCOR regulations governing online gambling in the Philippines. cudwin does not knowingly collect, process, or retain the personal data of any individual under the age of 21.

Where cudwin discovers or reasonably suspects that personal data belonging to an individual under 21 has been collected — whether through misrepresentation during registration or any other means — cudwin will immediately close the associated account, delete all personal data relating to the underage individual, and forfeit any associated balances.

If you are a parent or guardian and believe that a minor has registered an account with cudwin, please contact us immediately at [email protected] so that we can take prompt remedial action.

cudwin may send you promotional emails, SMS messages, and in-platform notifications about new games, bonuses, reload offers, and other cudwin promotions — but only if you have opted in to receive such communications at the time of registration or through your account settings.

You may opt out of marketing communications from cudwin at any time by:

• Clicking the "Unsubscribe" link at the bottom of any cudwin promotional email;
• Adjusting your notification preferences in your cudwin account settings; or
• Contacting cudwin support via live chat or at [email protected].

Please note that opting out of marketing communications does not affect your receipt of transactional and service communications from cudwin — such as deposit confirmations, withdrawal notifications, account security alerts, and KYC verification updates. These communications are necessary for the operation of your account and cannot be disabled.

Some of cudwin's service providers — including cloud infrastructure, game software providers, and security analytics platforms — may process data on servers located outside the Philippines. Where personal data is transferred outside the Philippines, cudwin ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012.

Such safeguards may include contractual clauses that impose data protection obligations on the receiving party, processing agreements that incorporate the NPC's standard contractual provisions, or transfers to jurisdictions that the NPC has recognised as providing an adequate level of data protection.

cudwin does not transfer personal data internationally without first conducting a documented assessment of the receiving party's data protection practices and ensuring appropriate contractual protections are in place.

cudwin reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, business practices, or the services we offer. The effective date at the top of this Policy will be updated whenever material changes are made.

Where changes are material — meaning they significantly affect how your data is processed or your rights as a data subject — cudwin will notify you via your registered email address or by displaying a prominent notice on the cudwin platform prior to the changes taking effect.

Your continued use of the cudwin platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you may request account closure in accordance with the Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or cudwin's handling of your personal data, please contact cudwin's Data Privacy Officer via any of the following channels:

Live Chat: Available 24/7 directly on the cudwin platform — the fastest way to reach our team for urgent account or data matters.
Email: [email protected] (plain text — not a clickable link). We aim to respond within 48 hours on business days.

If you are not satisfied with cudwin's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC), which is the competent supervisory authority for data protection matters in the Philippines. Information about filing a complaint with the NPC is publicly available through the NPC's official government channels.