larowin Privacy Policy

01 Who We Are

larowin ("larowin," "we," "us," or "our") is a Philippines-focused online casino and sports betting platform operating at larowin.org under PAGCOR regulatory oversight. For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173), larowin acts as the personal information controller in respect of the personal data it collects from registered players and visitors to the larowin platform.

This Privacy Policy applies to all personal data collected and processed by larowin in connection with the operation of the larowin platform, including the website at larowin.org, any associated mobile-optimized interfaces, customer support interactions, and promotional communications. By registering a larowin account or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy.

02 Personal Data We Collect

larowin collects personal data that falls into several categories depending on the stage of your relationship with the platform. The following table outlines the categories of personal data larowin collects and the primary reason each category is needed:

larowin does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive personal information is collected — such as a copy of a government-issued ID — it is handled with additional safeguards as described in the Data Security section of this Policy.

03 How We Collect Your Data

larowin collects personal data through several channels depending on how you interact with the platform:

• Direct Collection at Registration: When you create a larowin account, you provide identity data, contact data, and other information directly through the registration form. This is the primary source of your core account data.
• KYC Document Submission: When you submit identity verification documents in compliance with our KYC requirements, larowin collects the identity data contained in those documents including your photograph, ID number, and date of birth.
• Payment Transactions: When you make a deposit or withdrawal using GCash, Maya, BPI, BDO, UnionBank, Metrobank, 7-Eleven CLiQQ, USDT TRC20, or Coins.ph, larowin collects financial transaction data necessary to process and record the transaction.
• Automated Technical Collection: When you visit and use the larowin platform, our systems automatically collect technical data including your IP address, browser type, device identifiers, and session information through standard web server logs and first-party tracking technologies.
• Customer Support Interactions: When you contact larowin support via live chat or email, the content of those communications is collected and retained as part of larowin's customer service and compliance records.
• Gameplay and Betting Activity: All bets placed, games launched, and gaming sessions conducted on the larowin platform generate gaming activity data that is automatically recorded by the platform's systems.

04 How We Use Your Personal Data

larowin uses your personal data only for the purposes for which it was collected and as described in this Policy. The primary purposes for which larowin processes your personal data are as follows:

• Account Management: Creating, maintaining, and operating your larowin player account, including processing your registration, verifying your identity, and managing your account settings and preferences.
• Gaming Services Delivery: Enabling you to access and participate in larowin's gaming products including slots, live casino, sports betting on PBA, NBA, boxing, UFC and other events, bingo, and sabong.
• Payment Processing: Processing your deposits and withdrawals through your chosen payment method, reconciling transactions, and maintaining accurate financial records of your account activity.
• Regulatory Compliance: Meeting larowin's obligations under PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 and amendments), the Data Privacy Act of 2012 (RA 10173), and other applicable Philippine law.
• Responsible Gaming: Monitoring gaming activity patterns to identify potential problem gambling behaviors, administering deposit limits, cool-off periods, and self-exclusion requests, and fulfilling larowin's duty of care to players under PAGCOR responsible gaming standards.
• Security and Fraud Prevention: Detecting, investigating, and preventing fraudulent activity, money laundering, account takeover attempts, and other security threats using technical and behavioral data analysis.
• Customer Support: Responding to your inquiries, resolving disputes, handling complaints, and maintaining records of support interactions for quality assurance and compliance purposes.
• Platform Improvement: Analyzing aggregated and anonymized usage data to improve larowin's platform features, user experience, and gaming product offerings.
• Marketing Communications: Where you have given consent, sending you information about larowin promotions, bonuses, new game launches, and other offers relevant to your interests. You may withdraw marketing consent at any time.

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, larowin must have a lawful basis for processing your personal data. Depending on the specific processing activity, larowin relies on the following legal bases:

• Contractual Necessity: Processing that is necessary to perform the contract between you and larowin — i.e., the Terms and Conditions you agreed to when registering your account. This covers account management, game delivery, and payment processing.
• Legal Obligation: Processing that is required to comply with larowin's obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable legislation. KYC verification and AML monitoring fall under this basis.
• Legitimate Interests: Processing that is necessary for larowin's legitimate business interests, provided those interests are not overridden by your rights and interests. This includes fraud prevention, platform security, and service improvement activities.
• Consent: Processing activities where larowin has specifically requested and received your freely given, informed consent. Marketing communications are processed on this basis. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Sharing Your Personal Data

larowin does not sell your personal data. larowin may share your personal data with third parties only in the circumstances described below, and only to the extent necessary for the stated purpose:

• Payment Service Providers: larowin shares transaction data with payment processors including GCash, Maya, BPI, BDO, UnionBank, Metrobank, and other payment partners solely for the purpose of processing your deposits and withdrawals. These providers are bound by their own data protection obligations under Philippine law.
• Game Content Providers: larowin shares the minimum necessary player data with licensed third-party casino game providers to enable game sessions, resolve disputes, and fulfill auditing requirements. All game providers used by larowin are independently certified operators.
• Identity Verification Services: larowin may share identity data with specialist KYC verification service providers to conduct document verification and sanctions screening as part of our regulatory onboarding process.
• Regulatory Authorities: larowin is required by law to disclose certain player data to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities upon lawful request or as required by regulation. larowin will notify affected players of such disclosures where it is legally permissible to do so.
• Professional Advisers: larowin may share data with lawyers, auditors, accountants, and insurers on a confidential basis where necessary for the operation and protection of larowin's business.
• Business Transfers: In the event of a merger, acquisition, or sale of larowin's business, player data may be transferred to the relevant successor entity. Affected players will be notified of any such transfer and their rights in connection with it.

07 Cookies & Tracking Technologies

The larowin website uses cookies and similar tracking technologies to ensure the platform functions correctly and to improve your experience. A cookie is a small text file stored on your device when you visit a website. larowin uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the larowin platform to function. They enable core features such as session management, login authentication, and security token validation. These cookies cannot be disabled without impairing platform functionality.
• Functional Cookies: These cookies remember your preferences and settings — such as your language preference and display settings — to provide a more personalized experience on larowin. Disabling these cookies may affect personalization features.
• Analytics Cookies: larowin uses first-party analytics to understand how players navigate and interact with the platform. This data is collected in aggregated, anonymized form and is used solely to improve larowin's platform features and user experience.
• Security Cookies: These cookies support fraud detection and account security systems by allowing larowin to identify unusual patterns of access or device behavior that may indicate unauthorized account access attempts.

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or be notified when a new cookie is set. Please note that disabling certain cookies may affect the functionality of the larowin platform, particularly session management and login features. larowin does not use third-party advertising cookies or behavioral advertising tracking technologies.

08 Data Retention

larowin retains personal data for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements imposed on larowin as a PAGCOR-regulated operator. The following general retention periods apply:

• Active Account Data: Personal data associated with your active larowin account is retained for the duration of your account's active status plus a post-closure retention period as detailed below.
• Identity and KYC Documents: Retained for a minimum of five (5) years following account closure, in accordance with PAGCOR regulatory requirements and Philippine AML obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years following each transaction, in compliance with the Anti-Money Laundering Act and associated PAGCOR record-keeping requirements.
• Gaming Activity Logs: Retained for a minimum of three (3) years following the gaming session, or longer where required by applicable PAGCOR regulations or in connection with an unresolved dispute.
• Customer Support Records: Retained for a minimum of three (3) years following resolution of the relevant support interaction.
• Marketing Data: Retained until you withdraw your consent or for a maximum of two (2) years from your last marketing interaction, whichever is earlier.

When personal data is no longer required under larowin's retention schedule, it is securely deleted from larowin's systems or rendered permanently anonymous so that it can no longer be associated with you as an individual.

09 Data Security

larowin implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and larowin's servers is protected by 256-bit SSL/TLS encryption, preventing interception during transmission.
• Encryption at Rest: Sensitive personal data including identity documents and financial information stored in larowin's databases is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data within larowin's systems is restricted on a strict need-to-know basis. Staff are granted only the minimum level of access necessary to perform their specific role.
• Two-Factor Authentication: larowin supports and encourages the use of two-factor authentication (2FA) via SMS to your registered Philippine mobile number to protect your account against unauthorized access.
• Penetration Testing & Security Audits: larowin's platform and data infrastructure are subject to periodic security assessments and penetration testing by qualified security professionals.
• Staff Training: All larowin personnel who handle personal data receive regular training on data protection obligations and security best practices.

10 Your Data Subject Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by larowin. You may exercise any of these rights by contacting larowin's Data Privacy Officer as described in Section 14:

larowin will respond to all valid data subject requests within thirty (30) days of receipt. In complex cases, this period may be extended by an additional thirty (30) days, in which case larowin will notify you of the extension and the reason for it. larowin will not charge a fee for handling data subject requests unless a request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

If you are not satisfied with larowin's response to your data subject request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

11 Children & Minors

The larowin platform is strictly intended for adults who are at least 21 years of age — the minimum legal age for casino-style gambling in the Philippines as mandated by PAGCOR. larowin does not knowingly collect or process personal data from individuals under 21 years of age.

larowin uses mandatory age verification as part of its KYC process to confirm that all registered players meet the 21+ age requirement before they are permitted to deposit or play. Where larowin discovers or has reasonable grounds to believe that a player account has been registered by or on behalf of a person under 21 years of age, the account will be immediately suspended, any balance will be withheld pending investigation, and any personal data collected from that underage individual will be deleted in accordance with larowin's data deletion procedures.

12 Cross-Border Data Transfers

larowin primarily stores and processes personal data within servers located in the Philippines or in data centers that meet applicable Philippine data protection standards. In some circumstances, personal data may be transferred to and processed in countries outside the Philippines — for example, where larowin's third-party game providers or technical infrastructure partners maintain operations in other jurisdictions.

Where personal data is transferred outside the Philippines, larowin ensures that such transfers are subject to appropriate safeguards consistent with the requirements of the Data Privacy Act of 2012, including contractual data processing agreements that impose equivalent data protection obligations on the receiving party. larowin will not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate safeguards.

13 Updates to This Privacy Policy

laro win reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, larowin will notify active players via the platform interface or by sending a notification to your registered email address or Philippine mobile number.

The effective date at the top of this Privacy Policy indicates when it was last reviewed and updated. Your continued use of the larowin platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the updated Policy. larowin recommends that you review this Privacy Policy periodically to stay informed about how your personal data is being protected. The current version of this Privacy Policy is always available at larowin.org/privacy-policy.

14 Contact & Data Privacy Officer

larowin has designated a Data Privacy Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to this Privacy Policy or the way larowin processes your personal data, you may contact the larowin DPO through the following channels:

• Live Chat: Available 24/7 via the larowin platform. For data privacy matters, please state "Data Privacy Request" at the start of your chat to be routed to the appropriate team. Average response time: 3–5 minutes.
• Email: support at larowin.org — please use the subject line "Data Privacy Request" for all data subject rights inquiries. Allow up to 5 business days for an initial response to email privacy requests.
• Response Commitment: larowin will acknowledge all data privacy requests within three (3) business days and will provide a substantive response within thirty (30) days as required under the Data Privacy Act.

If you are not satisfied with larowin's handling of your personal data or your data subject rights request, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC is the competent supervisory authority for data protection matters under Philippine law and can be contacted through the NPC's official government channels.