crazywingo Privacy Policy

crazywingo ("we," "us," "our," or the "Company") operates the online gaming platform accessible at https://crazywingo.app (the "Platform"). We are committed to protecting the privacy and personal data of all users ("you," "your," or "Player") who access or use our Platform.

This Privacy Policy ("Policy") describes how crazywingo collects, uses, stores, shares, and protects your personal data in connection with your use of the Platform. It also explains the rights you have under applicable data protection laws, including the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

By registering an account, accessing the Platform, or otherwise using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

crazywingo collects various categories of personal data depending on how you interact with the Platform. The categories of data we collect include:

We may also collect sensitive personal information as defined under Philippine law, including government-issued identification numbers and biometric data (if used for verification purposes). Collection of such data is strictly limited to what is necessary for regulatory compliance and is subject to heightened security measures.

crazywingo collects personal data through the following methods:

3.1 Direct Collection. When you register an account, complete KYC verification, make deposits or withdrawals, contact customer support, or participate in promotions, you provide personal data directly to us.

3.2 Automated Collection. When you access or use the Platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, browsing behavior, and gameplay patterns.

3.3 Third-Party Sources. We may receive data about you from third-party payment processors (e.g., GCash, PayMaya, banks), identity verification services, fraud prevention providers, and marketing partners. We only work with third parties who comply with applicable data protection laws.

3.4 Public Sources. In limited circumstances, we may collect publicly available information about you from government registries or public databases to verify your identity or comply with legal obligations.

crazywingo processes your personal data for the following purposes:

• Account Management: Creating and maintaining your player account, authenticating your identity, and managing your profile settings.
• Service Delivery: Providing access to games, processing bets, calculating winnings, and facilitating deposits and withdrawals.
• Regulatory Compliance: Verifying that you are at least 21 years of age, conducting KYC and AML checks, preventing fraud and money laundering, and complying with gaming regulations and licensing requirements.
• Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Security & Fraud Prevention: Detecting and preventing unauthorized access, fraudulent transactions, collusion, bonus abuse, and other prohibited conduct.
• Responsible Gaming: Monitoring gameplay patterns to identify potential problem gambling behavior, enforcing deposit limits and self-exclusion requests, and providing access to responsible gaming tools.
• Marketing & Communications: Sending promotional offers, bonuses, newsletters, and platform updates (only if you have opted in to receive such communications).
• Analytics & Improvement: Analyzing usage patterns, conducting A/B testing, improving game offerings, optimizing platform performance, and developing new features.
• Legal Obligations: Responding to legal requests, court orders, and regulatory inquiries; enforcing our Terms & Conditions; and protecting our legal rights.

Under the Philippine Data Privacy Act and other applicable laws, crazywingo processes your personal data based on one or more of the following legal grounds:

• Consent: You have given explicit consent for us to process your personal data for specific purposes (e.g., receiving marketing communications).
• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., the Terms & Conditions) and to provide the gaming services you have requested.
• Legal Obligation: Processing is required to comply with applicable laws, regulations, and licensing requirements, including age verification, KYC, AML, and responsible gaming obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, service improvement, and direct marketing, provided such interests do not override your fundamental rights and freedoms.

Where we rely on consent as the legal basis for processing, you have the right to withdraw your consent at any time. However, withdrawal of consent will not affect the lawfulness of processing conducted prior to withdrawal.

crazywingo does not sell your personal data. However, we may share your data with the following categories of third parties under strict confidentiality and data protection obligations:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other financial institutions that process your deposits and withdrawals.
• Identity Verification Providers: Third-party services that assist with KYC verification and age confirmation.
• Fraud Prevention & Security Services: Providers that help detect and prevent fraudulent activity, money laundering, and unauthorized access.
• Game Providers: Third-party game developers and suppliers whose games are offered on the Platform.
• Cloud Service Providers: Hosting and infrastructure providers that store and process data on our behalf.
• Marketing & Analytics Partners: Services that help us measure campaign effectiveness and understand user behavior (only aggregated or anonymized data is shared where possible).
• Legal & Regulatory Authorities: Government agencies, regulators, law enforcement, and courts when required by law or to protect our legal rights.
• Professional Advisors: Lawyers, auditors, and consultants who provide professional services to crazywingo.
• Business Successors: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity.

All third parties with whom we share your data are contractually obligated to protect your personal data and use it only for the purposes for which it was disclosed.

crazywingo uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that allow us to recognize you, remember your preferences, and analyze how you use the Platform.

Types of Cookies We Use:

• Essential Cookies: Required for the Platform to function properly. These cannot be disabled.
• Performance Cookies: Collect anonymous data about how you use the Platform to help us improve performance.
• Functional Cookies: Remember your preferences and settings to provide a personalized experience.
• Marketing Cookies: Track your activity across websites to deliver targeted advertising and measure campaign effectiveness.

You can manage your cookie preferences through your browser settings. However, disabling certain cookies may limit your ability to use some features of the Platform. For more information, please refer to your browser's help documentation.

crazywingo retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

Retention Periods:

• Active Accounts: Data is retained for the duration of your account's active status.
• Closed Accounts: After account closure, we retain certain data for up to seven (7) years to comply with AML, tax, and gaming regulations.
• Marketing Data: Retained until you withdraw consent or for up to two (2) years of inactivity, whichever comes first.
• Technical & Usage Data: Typically retained for up to two (2) years for security and analytics purposes.

Once the retention period expires, we will securely delete or anonymize your personal data in accordance with our data retention and disposal policies.

crazywingo implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• 256-bit SSL Encryption: All data transmitted between your device and our servers is encrypted using Secure Socket Layer (SSL) technology.
• Secure Data Storage: Personal data is stored on secure servers with restricted access controls and regular security audits.
• Access Controls: Only authorized personnel with a legitimate business need have access to your personal data.
• Regular Security Testing: We conduct penetration testing, vulnerability assessments, and security reviews to identify and address potential risks.
• Incident Response: We maintain an incident response plan to quickly detect, contain, and remediate any data breaches.

While we take all reasonable precautions to protect your data, no method of transmission over the internet or electronic storage is completely secure. crazywingo cannot guarantee absolute security, and you acknowledge that you provide your personal data at your own risk.

Under the Philippine Data Privacy Act and other applicable laws, you have the following rights with respect to your personal data:

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: You have the right to request deletion of your personal data, subject to legal retention requirements.
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes or based on legitimate interests.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time.
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission of the Philippines if you believe your privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within thirty (30) days.

The crazywingo Platform is intended solely for individuals who are at least twenty-one (21) years of age. We do not knowingly collect personal data from individuals under 21 years of age.

If we become aware that we have inadvertently collected personal data from a person under 21, we will take immediate steps to delete such data from our systems and terminate the associated account. Any funds in such accounts may be forfeited in accordance with applicable regulations.

If you are a parent or guardian and believe that your child has provided personal data to crazywingo, please contact us immediately at [email protected].

Your personal data may be transferred to, stored, and processed in jurisdictions outside the Philippines where our service providers, payment processors, or cloud infrastructure are located. These jurisdictions may have data protection laws that differ from those of the Philippines.

When we transfer your personal data internationally, we ensure that appropriate safeguards are in place, including:

• Standard contractual clauses approved by relevant data protection authorities
• Adequacy decisions recognizing equivalent data protection standards
• Binding corporate rules for intra-group transfers
• Certification under recognized data protection frameworks

By using the crazywingo Platform, you consent to the transfer of your personal data to jurisdictions outside the Philippines under the safeguards described above.

The crazywingo Platform may contain links to third-party websites, services, or applications that are not operated or controlled by crazywingo. This Privacy Policy applies only to the crazywingo Platform and does not cover the privacy practices of third parties.

We are not responsible for the privacy practices or content of third-party websites or services. We encourage you to review the privacy policies of any third-party services you access through the Platform.

When you use third-party payment methods such as GCash, PayMaya, BPI, BDO, or Metrobank, your interactions with those services are governed by their respective privacy policies and terms of service.

crazywingo reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this Policy, we will notify you by:

• Posting the updated Policy on the Platform with a revised "Last Updated" date
• Sending an email notification to your registered email address
• Displaying an in-platform notification upon your next login

Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you must discontinue use of the Platform and may request account closure.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us:

• General Inquiries: [email protected]
• Data Protection Officer: [email protected]
• Website: https://crazywingo.app

Our Data Protection Officer is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. You may contact the DPO directly for any privacy-related matters, including exercising your data subject rights or filing a complaint.

We aim to respond to all privacy inquiries within thirty (30) days. For urgent matters related to data breaches or unauthorized access, please mark your message as urgent.