whq111 Privacy Policy

whq111 ("whq111," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who access or use the whq111 online gaming platform at whq111.app (the "Platform"). This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information when you interact with the Platform.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read together with our Terms and Conditions, which govern your use of the Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms and Conditions.

whq111 collects personal data that you provide directly to us, data generated through your use of the Platform, and data obtained from third parties where permitted by law. The categories of personal data we collect include:

2.1 Registration Data. When you create a whq111 account, we collect your full legal name, date of birth, residential address, email address, mobile number, and username. This information is required to create and maintain your account.

2.2 Identity Verification Data (KYC). To comply with anti-money laundering regulations and PAGCOR requirements, we collect copies of government-issued identification documents (such as a Philippine passport, driver's license, SSS/UMID card, or PhilSys ID), proof of address, and proof of payment method ownership.

2.3 Financial Data. We collect information about your deposits, withdrawals, and transaction history on the Platform. We do not store full payment card numbers; payment processing is handled by our regulated payment partners.

2.4 Gaming Activity Data. We collect records of your gaming activity on the Platform, including games played, bets placed, outcomes, session durations, and bonus usage. This data is used for account management, responsible gaming monitoring, and regulatory reporting.

2.5 Technical Data. We automatically collect technical information when you access the Platform, including your IP address, device type, operating system, browser type, and session logs. This data is used for security monitoring, fraud prevention, and platform optimization.

2.6 Communications Data. We retain records of your communications with whq111 customer support, including live chat transcripts, emails, and support tickets.

2.7 Marketing Preferences. If you opt in to marketing communications, we collect your preferences regarding the types of promotions and updates you wish to receive.

whq111 uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your whq111 player account, including processing deposits and withdrawals.
• Identity Verification: To verify your identity and age (21+) in compliance with PAGCOR regulations and anti-money laundering requirements.
• Service Delivery: To provide you with access to the games, features, and services available on the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct.
• Regulatory Compliance: To comply with our obligations under PAGCOR regulations, the Data Privacy Act, anti-money laundering laws, and other applicable Philippine legislation.
• Marketing Communications: To send you promotional offers, bonuses, and platform updates, where you have provided your consent to receive such communications.
• Platform Improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the Platform.

whq111 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and whq111 (i.e., the Terms and Conditions), including account management, payment processing, and service delivery.
• Legal Obligation: Processing is necessary for compliance with our legal obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• Legitimate Interests: Processing is necessary for the legitimate interests of whq111, including fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your interests or fundamental rights.
• Consent: Where we rely on your consent as the legal basis for processing (such as for marketing communications), you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

whq111 does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

5.1 Regulatory Authorities. We are required to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities upon lawful request or as required by applicable regulations.

5.2 Payment Processors. We share financial data with our regulated payment partners (including GCash, PayMaya/Maya, and partner banks such as BPI, BDO, Metrobank, UnionBank, Landbank, PNB, and Security Bank) to process your deposits and withdrawals. These partners are bound by their own data protection obligations.

5.3 Identity Verification Providers. We share identity documents and related data with accredited KYC and identity verification service providers to fulfill our age verification and anti-money laundering obligations.

5.4 Game Providers. Certain technical data (such as session identifiers) may be shared with our licensed game providers to deliver game content and ensure fair play. Game providers do not receive your full personal profile.

5.5 IT and Security Service Providers. We engage third-party IT infrastructure, cloud hosting, and cybersecurity providers who process data on our behalf under strict data processing agreements that require them to maintain appropriate security measures.

whq111 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how you use the Platform.

6.1 Essential Cookies. These cookies are strictly necessary for the Platform to function. They enable core features such as account login, session management, and security. You cannot opt out of essential cookies without affecting Platform functionality.

6.2 Analytics Cookies. We use analytics cookies to understand how players interact with the Platform, which pages are most visited, and where technical issues occur. This data is aggregated and anonymized where possible.

6.3 Preference Cookies. These cookies remember your settings and preferences (such as language and display options) to provide a more personalized experience.

6.4 Managing Cookies. You can control and delete cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

whq111 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including financial records and identity documents.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While whq111 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

whq111 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by PAGCOR regulations and anti-money laundering laws.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with the Anti-Money Laundering Act.
• KYC Documents: Retained for a minimum of five (5) years after the end of the business relationship, or longer if required by a regulatory authority.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing Data: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention requirements.

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

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by whq111:

• Right to be Informed: The right to be informed about how your personal data is collected and processed, as set out in this Policy.
• Right of Access: The right to request a copy of the personal data whq111 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 our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13. whq111 will respond to all data rights requests within thirty (30) days of receipt, as required by Philippine law. We may need to verify your identity before processing your request.

The whq111 Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gaming regulations. whq111 does not knowingly collect personal data from individuals under the age of 21.

If whq111 becomes aware that personal data has been collected from a person under the age of 21, we will immediately close the associated account, void any balances, and delete the personal data in question. If you believe that a minor has registered on the Platform, please contact us immediately at the details provided in Section 13.

whq111 primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines (for example, cloud infrastructure providers or game technology partners).

Where such transfers occur, whq111 ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to maintain data protection standards equivalent to those required under the Data Privacy Act of 2012. By using the Platform, you consent to such transfers where they are necessary for the provision of our services.

whq111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform features. The date of the most recent revision is indicated at the top of this document.

Material changes to this Policy will be communicated to registered players via email or a prominent notice on the Platform prior to the changes taking effect. Your continued use of the Platform following the effective date of any amendments constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how whq111 protects your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the whq111 Data Protection Officer (DPO):

• Live Chat: Available 24/7 via the whq111 Platform
• Email (DPO): [email protected]
• General Support: [email protected]

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data rights have been violated. whq111 aims to resolve all privacy-related inquiries within thirty (30) days of receipt.