Your Privacy Matters

Combo Win Privacy Policy – How We Protect Your Data

At Combo Win, we handle your personal information with the same care you put into every game. This policy explains exactly what we collect, why we collect it, and how we keep it safe — in plain language that every kabayan can understand.

Last updated: June 2025  |  English (en-PH)  |  Compliant with the Philippine Data Privacy Act of 2012

How Combo Win Keeps Your Information Safe

These are the core principles that guide how we handle your data on the Combo Win platform.

End-to-End Encryption

All data transmitted between your device and Combo Win is encrypted using industry-standard TLS (Transport Layer Security). Whether you are logging in, depositing via GCash, or checking your balance, your connection is always secure.

No Data Selling — Ever

Your personal information is yours. Combo Win will never sell, rent, or trade your data to third-party advertisers or marketing companies. We share data only when required by law or to operate essential platform services.

RA 10173 Compliance

Combo Win fully complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and the implementing rules set by the National Privacy Commission (NPC). Your rights as a Filipino data subject are protected here.

You Control Your Data

You have the right to access, correct, and request deletion of your personal data at any time. Contact our support team and we will process your request in accordance with applicable Philippine privacy law.

Minimal Data Collection

We only collect the information we genuinely need to operate your account, process payments, and comply with gaming regulations. We do not collect unnecessary data, and we do not retain data longer than required.

Opt-Out of Marketing Anytime

Receive a bonus promo SMS or email you did not want? You can unsubscribe from all Combo Win marketing communications at any time — simply update your notification preferences in your account settings or contact support.

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Combo Win protects your data across every game and bet.

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From VIP Club rewards to everyday play — your privacy is secured.

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Nationwide players trust Combo Win with their account information.

What Information Combo Win Collects and Why

A clear summary of the personal data categories we process, the reason we collect them, and how long we hold them.

Data Category Examples Purpose Retention Period
Identity Data Full name, date of birth, government ID number Account registration, age & identity verification as required by gaming regulations Duration of account + 5 years after closure
Contact Data Email address, mobile number Account communications, OTP verification, support responses, opt-in promotions Duration of account + 2 years after closure
Financial Data GCash / Maya account reference, bank account details, transaction history Processing deposits and withdrawals, anti-money laundering compliance 7 years (as required by Philippine financial regulations)
Technical Data IP address, device type, browser, operating system, session timestamps Platform security, fraud detection, session management 12 months rolling
Usage Data Games played, bet amounts, session duration, bonus usage Responsible gaming monitoring, product improvement, personalized promotions (if opted in) 3 years
Communications Data Support chat logs, email correspondence Customer service quality, dispute resolution, compliance records 3 years

1. Introduction

This Privacy Policy describes how Combo Win ("we", "us", "our") collects, processes, stores, and protects the personal information of players and visitors who use the Combo Win platform at combowin.click ("the Platform").

We take your privacy seriously — not just because Philippine law requires it, but because we believe every player on Combo Win deserves to know exactly what happens to their information. This policy is written in plain language to make that as easy as possible.

By registering a Combo Win account or using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with how we handle your data, please discontinue use of the Platform and contact our team to close your account.

Compliance note: This Privacy Policy is prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

2. Who We Are

Combo Win is an online gaming platform operated under a valid gaming license and serving players primarily in the Philippines. For the purposes of data privacy law, Combo Win is the Personal Information Controller (PIC) responsible for the personal data processed through the Platform.

Our Data Protection Officer (DPO) can be contacted at support@combowin.click for any privacy-related inquiries, requests, or complaints.

3. Personal Data We Collect

The table in the section above provides a quick overview. In full detail, Combo Win collects the following categories of personal data:

  • Identity information: Your full legal name, date of birth, nationality, and copies of government-issued identification (such as PhilSys ID, UMID, Driver's License, or Passport) required for account verification.
  • Contact information: Your email address and Philippine mobile number, used for account authentication, OTPs, and official communications.
  • Financial information: Payment account references for GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, and Visa/Mastercard — collected solely to process deposits and withdrawals and to comply with anti-money laundering (AML) obligations.
  • Technical and device information: IP address, device identifiers, browser type, and session data, collected automatically when you access the Platform.
  • Gameplay and transaction data: Records of bets placed, games played, bonuses used, and financial transactions — necessary for account management and regulatory reporting.
  • Communication records: Messages exchanged with our support team via live chat or email.

4. How We Collect Your Data

Combo Win collects personal data through the following channels:

  • Direct submission: Information you provide when registering an account, completing identity verification, making a deposit or withdrawal, or contacting support.
  • Automated collection: Technical data gathered automatically by our systems when you access the Platform, including through cookies, log files, and analytics tools.
  • Third-party payment providers: When you use GCash, Maya, or other payment gateways, those providers share transaction reference data with us to confirm payment status.
  • Verification service providers: We may use third-party identity verification services to validate government ID documents during the Know Your Customer (KYC) process.

5. How We Use Your Personal Data

We use the data we collect for the following specific purposes:

  • To create and manage your Combo Win account and verify your identity
  • To process deposits and withdrawals through your chosen Philippine payment method
  • To detect and prevent fraud, money laundering, and unauthorized account access
  • To monitor gameplay for responsible gaming purposes and enforce our terms
  • To send you transactional messages (deposit confirmations, withdrawal updates, OTPs)
  • To send promotional offers, bonus notifications, and platform updates — only if you have opted in to receive them
  • To comply with our legal obligations under Philippine gaming regulations and financial laws
  • To improve the Platform through anonymized analytics and user feedback

We will not use your personal data for any purpose that is incompatible with the above without obtaining your explicit consent first.

6. Sharing Your Personal Data

Combo Win does not sell your data. We share personal information only in these limited, necessary circumstances:

  • Payment processors: GCash, Maya, GrabPay, and our banking partners receive only the reference data needed to complete your transactions.
  • Identity verification providers: Third-party KYC partners who assist us in verifying government IDs are contractually bound to data confidentiality and may not use your data for any other purpose.
  • Regulatory bodies: We may be required by law to disclose certain information to the relevant Philippine gaming regulatory authority, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or law enforcement agencies acting under lawful authority.
  • Platform service providers: Hosting, security, and analytics providers who support the technical operation of the Platform — all operating under data processing agreements that limit how they may use your information.

Any third party who receives your data is required to protect it to the same standard that Combo Win does and to use it only for the specific purpose for which it was shared.

7. Cookies and Tracking Technologies

Combo Win uses cookies and similar technologies to make the Platform work properly and to improve your experience. Here is a quick breakdown of what we use:

  • Essential cookies: Required for login sessions, security tokens, and core Platform functionality. These cannot be disabled without breaking the Platform.
  • Analytics cookies: Help us understand how players navigate the Platform so we can improve it. Data collected is aggregated and anonymized.
  • Preference cookies: Remember your language, region, and display settings between sessions.
  • Marketing cookies: Used only if you have opted in to personalized promotions. You can manage these through your account settings.

Most browsers allow you to control cookies through their settings. Blocking essential cookies will affect your ability to use the Platform. For analytics and marketing cookies, you can opt out at any time through your Combo Win account preferences.

8. Data Security Measures

Combo Win takes the security of your personal information seriously. We implement a combination of technical and organizational measures to protect your data from unauthorized access, disclosure, alteration, or destruction:

  • TLS encryption on all data in transit between your device and our servers
  • Encryption at rest for sensitive account and financial data
  • Multi-factor authentication (MFA) available for all player accounts
  • Automated intrusion detection and account anomaly monitoring
  • Regular security audits and penetration testing by third-party specialists
  • Access controls limiting employee access to personal data on a need-to-know basis
  • Staff training on data privacy obligations under Philippine law

While no system is completely immune to risk, Combo Win is committed to maintaining security standards that match or exceed industry best practices for online gaming platforms operating in the Philippines.

In the unlikely event of a personal data breach that may affect your rights and freedoms, Combo Win will notify you and the National Privacy Commission (NPC) within the timeframes required under Philippine law.

9. Your Rights as a Data Subject

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

Right to Be Informed
Right of Access
Right to Correction
Right to Erasure
Right to Object
Right to Data Portability
Right to Block Processing
Right to Lodge a Complaint

To exercise any of these rights, send a written request to support@combowin.click with the subject line "Data Privacy Request". We will acknowledge your request within 3 business days and resolve it within 30 days, in line with NPC guidelines.

If you are not satisfied with our response, you have the right to file a complaint with the National Privacy Commission of the Philippines through its official channels.

10. Minors and Age Verification

Combo Win is strictly an adults-only platform. We do not knowingly collect personal data from individuals below the age of 21. Age verification is a required step during account registration, and we reserve the right to request additional documentation at any time.

If we discover that an account belongs to a person under 21, it will be immediately closed and any funds in the account will be returned less any applicable processing costs. Any winnings generated on an account that used false age information will be forfeited.

11. How Long We Keep Your Data

We do not hold your data longer than necessary. Our retention periods are shaped by legal requirements, operational needs, and responsible data management:

  • Active account data is held for the full duration of your account.
  • After account closure, identity and contact data is retained for up to 5 years to comply with gaming licensing obligations.
  • Financial transaction records are retained for 7 years as required by Philippine financial regulations and AML laws.
  • Technical and session data is retained for a rolling 12-month period.
  • Support communications are kept for 3 years for dispute resolution and compliance purposes.

When data reaches the end of its retention period, it is securely deleted or anonymized in line with our data disposal procedures.

12. Changes to This Privacy Policy

Combo Win may update this Privacy Policy from time to time to reflect changes in our practices, platform features, or applicable Philippine law. When we make material changes, we will:

  • Update the "Last updated" date at the top of this page
  • Send a notification to your registered email address at least 7 days before the changes take effect
  • Post a prominent notice on the Platform

Continued use of Combo Win after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you have concerns about any proposed changes, contact our DPO before the effective date.

13. Contact Us and Filing a Complaint

If you have questions about this Privacy Policy, want to exercise your data rights, or need to report a privacy concern, please reach out to our Data Protection Officer:

  • Email: support@combowin.click (subject: "Data Privacy Request")
  • Live Chat: Available inside the Platform 24/7 after login
  • FAQ: Visit our FAQ page for quick answers on common privacy questions

We aim to respond to all data privacy requests within 3 business days and to resolve them fully within 30 days. For complaints that we are unable to resolve to your satisfaction, you may contact the National Privacy Commission of the Philippines directly.

Governing Law: This Privacy Policy is governed by the laws of the Republic of the Philippines, including the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations.

Your Data Is Safe. Now Let's Play!

Now you know exactly how Combo Win protects your information. Join thousands of Filipino players who trust us with their accounts — and their winnings.

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