cow88 Privacy Policy

This Privacy Policy ("Policy") describes how cow88 ("cow88," "we," "us," or "our") collects, uses, processes, discloses, and safeguards the personal information of individuals ("Data Subject," "Player," "User," or "you") who access or use the cow88 online casino platform available at cow88.cam and all associated services, features, and content.

cow88 operates as a PAGCOR-regulated gaming platform and is committed to protecting the personal information of all Filipino players in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission (NPC). This Policy applies to all personal information collected through the cow88 website, mobile browser interface, live chat, and any other channel through which you interact with cow88.

By registering an account on cow88 or otherwise providing your personal information to us, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal information as described herein. If you do not agree with any part of this Policy, please do not register an account or continue using the platform.

1. Data Controller Identity

For purposes of the Data Privacy Act of 2012 and its implementing rules, cow88 acts as the Personal Information Controller (PIC) with respect to the personal information it collects from players and website visitors. As PIC, cow88 determines the purposes for which, and the means by which, personal information is processed.

cow88 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy laws. The DPO may be contacted as described in Section 15 of this Policy. Where cow88 engages third-party service providers to process personal information on its behalf, such processors are bound by data processing agreements that impose obligations at least equivalent to those in this Policy.

2. Personal Information We Collect

cow88 collects the following categories of personal information from players and website visitors:

2.1 Registration & Identity Data

• Full legal name as it appears on a government-issued Philippine ID
• Date of birth (to verify 21+ age eligibility)
• Philippine mobile number
• Email address
• Username and encrypted password credentials
• Gender (optional, for player experience personalisation)
• Preferred language

2.2 Identity Verification (KYC) Data

• Government-issued photo ID: Philippine System ID (PhilSys), UMID, passport, driver's license, or SSS card
• Proof of address documents where required by PAGCOR compliance
• Selfie photographs submitted for liveness verification where applicable

2.3 Financial & Transaction Data

• GCash account number or PayMaya wallet identifier
• Bank account name, number, and bank name (BDO, BPI, Metrobank, or other BSP-licensed banks)
• Deposit amounts, dates, and payment method used
• Withdrawal requests, amounts, and processing status
• Account balance history and transaction logs

2.4 Gaming & Behavioural Data

• Game sessions played, including game type, duration, bet amounts, and outcomes
• Bonus claims, wagering activity, and promotion participation history
• Responsible gaming tool usage (deposit limits set, cooling-off periods activated)

2.5 Technical & Device Data

• IP address and approximate geolocation derived therefrom
• Device type, operating system version, and browser type
• Session tokens and login timestamps
• Cookie identifiers and similar tracking technologies (see Section 10)

2.6 Communications Data

• Live chat transcripts between you and cow88 support agents
• Emails and support ticket correspondence
• Feedback forms and survey responses

3. How We Collect Your Personal Information

cow88 collects personal information through the following means:

• Directly from you when you complete the registration form, submit KYC documents, make a deposit or withdrawal, contact support, or participate in a promotion.
• Automatically through cookies, session logs, server logs, and analytics tools when you browse or interact with the cow88 platform.
• From third-party payment processors such as GCash, PayMaya, and partner banks, who transmit transaction confirmation data to cow88 for payment matching and fraud prevention purposes.
• From identity verification services engaged by cow88 to perform KYC and age verification checks as required by PAGCOR regulations.
• From anti-fraud and AML screening providers that check player profiles against watchlists and risk databases in compliance with Philippine AMLA obligations.

4. Purposes of Processing

cow88 processes your personal information for the following specific, explicit, and legitimate purposes:

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its implementing rules, cow88 relies on the following legal bases for the processing of your personal information:

• Consent: Where you have given freely-given, specific, informed, and unambiguous consent prior to processing — particularly for marketing communications and optional features.
• Contractual Necessity: Where processing is necessary to perform the contract between you and cow88 (i.e., delivering gaming services, processing payments, and managing your account).
• Legal Obligation: Where processing is required to comply with applicable Philippine laws, including PAGCOR licensing conditions, the AMLA, and NPC issuances.
• Legitimate Interests: Where processing is necessary for cow88's legitimate interests — such as fraud prevention, platform security, and responsible gaming monitoring — provided those interests are not overridden by your rights and freedoms.

Where cow88 relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent may affect your ability to use certain optional features of the platform.

6. Sharing of Personal Information

cow88 does not sell, rent, or trade your personal information to any third party. We may share your personal information with the following categories of recipients under the circumstances described below:

6.1 Regulatory & Law Enforcement Authorities

cow88 is legally required to disclose player information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities when required by law, court order, or PAGCOR licensing conditions. This includes reporting obligations under the AMLA and its implementing rules.

6.2 Payment Processors

To process deposits and withdrawals, cow88 shares the minimum necessary financial information with payment service providers including GCash (G-Xchange Inc.), PayMaya (Maya Philippines Inc.), and partner banks. These providers process data as sub-processors under contracts that include data protection obligations consistent with this Policy.

6.3 KYC & Fraud Prevention Providers

cow88 engages third-party identity verification and fraud screening providers to perform KYC checks and AML screening as required by PAGCOR. These providers act as sub-processors and are contractually prohibited from using player data for any purpose other than the specific verification service they provide to cow88.

6.4 Technology & Infrastructure Providers

cow88 uses third-party cloud infrastructure, software, and analytics providers to operate the platform. These providers have access to personal data only to the extent necessary to provide their services and are bound by confidentiality and data processing obligations.

6.5 Game Software Providers

Where game software providers require session data to deliver their games on the cow88 platform, limited technical data (such as session tokens and game stake amounts) may be passed to those providers. No personally identifiable information beyond what is strictly necessary for game delivery is shared.

7. Data Retention

cow88 retains personal information for the period necessary to fulfil the purposes described in this Policy, subject to longer retention periods required by applicable Philippine law, PAGCOR licensing conditions, and AMLA record-keeping obligations.

Upon expiry of the applicable retention period, cow88 will securely delete or anonymise personal information in accordance with its data disposal procedures. Data that has been anonymised such that it can no longer be linked to an identifiable individual may be retained for analytical purposes beyond these periods.

8. Security Measures

cow88 implements appropriate technical, organisational, and physical security measures to protect your personal information against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your browser and the cow88 platform is encrypted using industry-standard TLS encryption.
• Password Hashing: Account passwords are stored using one-way cryptographic hashing algorithms. cow88 never stores passwords in plain text.
• Two-Factor Authentication: SMS OTP verification is available for all accounts and required for sensitive account actions.
• Access Controls: Personal data is accessible to cow88 staff only on a strict need-to-know basis. All staff with access to personal data are bound by confidentiality obligations.
• Regular Security Audits: cow88 conducts regular security assessments and penetration tests to identify and remediate vulnerabilities.
• Incident Response: cow88 maintains a data breach response plan and will notify affected players and the NPC in accordance with the timelines required by the Data Privacy Act in the event of a notifiable personal data breach.

9. Cookies & Tracking Technologies

cow88 uses cookies and similar tracking technologies to operate the platform, maintain session security, remember your preferences, and analyse platform usage. A "cookie" is a small text file placed on your device by a website server.

9.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function — including session authentication, security tokens, and load balancing. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences such as language settings and responsible gaming tool configurations across sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate the cow88 platform to help us improve the user experience. cow88 uses privacy-compliant analytics tools for this purpose.
• Security Cookies: Help cow88 detect and prevent fraudulent activity, multiple account creation, and other security risks.

9.2 Cookie Control

You can manage non-essential cookies through your browser settings. Most browsers allow you to block or delete cookies. Please be aware that blocking strictly necessary cookies will impair your ability to log in to and use the cow88 platform. Detailed instructions for managing cookies are available in your browser's help documentation.

9.3 Session Storage & Local Storage

cow88 may also use browser session storage and local storage for performance optimisation purposes, such as caching game assets. Data stored in session storage is automatically cleared when you close your browser tab. Local storage data persists until cleared manually or through your browser settings.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal information held by cow88. To exercise any of these rights, please contact the cow88 Data Protection Officer as described in Section 15.

cow88 will respond to data subject requests within thirty (30) days of receipt. Where a request is complex or numerous, cow88 may extend this period by a further thirty (30) days, with notification to you of the extension and the reasons therefor.

11. Minors & Age Policy

The cow88 platform is strictly intended for individuals aged 21 years or older, in accordance with PAGCOR regulations and applicable Philippine law. cow88 does not knowingly collect personal information from individuals under the age of 21.

Age verification is performed during account registration and may be repeated through documentary KYC verification at any time during the account's lifecycle. Where cow88 discovers or has reasonable grounds to believe that personal information has been collected from an individual under 21, such information will be deleted promptly and the associated account will be suspended pending investigation.

If you are a parent or guardian and believe that your child under the age of 21 has registered an account on cow88 or submitted personal information to the platform, please contact our Data Protection Officer immediately using the contact details in Section 15.

12. Cross-Border Data Transfers

Where cow88 engages service providers or game software vendors whose servers or operations are located outside the Philippines, personal information may be transferred across borders. cow88 ensures that any such transfers are carried out in compliance with the requirements of the Data Privacy Act of 2012 and relevant NPC regulations, including through the use of contractual safeguards, adequacy assessments, and processing agreements that impose data protection obligations on the receiving party equivalent to those required under Philippine law.

cow88 will not transfer personal information to a country or territory that does not provide adequate protection for personal information unless appropriate safeguards are in place as approved by the NPC.

13. Amendments to This Policy

cow88 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR requirements, NPC issuances, or cow88's data processing practices. Updated versions will be published on this page with a revised "Last Updated" date.

Material changes to this Policy — those that significantly affect the rights of players or how personal information is processed — will be communicated to registered players via their registered email address or through a platform notification prior to the change taking effect. Your continued use of the cow88 platform after a material change constitutes your acceptance of the revised Policy.

14. Contact & Data Protection Officer

For any privacy-related enquiries, data subject rights requests, or concerns about how cow88 handles your personal information, please contact the cow88 Data Protection Officer through the following channels:

• Email: [email protected] (subject line: "Data Privacy Request")
• Live Chat: Available 24/7 through the cow88 platform — request to speak with the Data Protection team.

If you are not satisfied with cow88's response to your privacy concern or data subject rights request, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines, the independent government authority responsible for enforcing the Data Privacy Act. The NPC's contact details and complaint procedure are publicly available on the official NPC website.