- What information we collect
- How we use information
- How we share information
- Your rights as a user
- Other important aspects of privacy and security-related matters
This policy is created in accordance with General Data Protection Regulation. Please take some time to read through this policy, and keep an eye out for updates. Whenever we make important changes to the policy, we’ll let you know through notifications or other contact methods such as email.
Information we might collect and process
- Your name, address and contact details
- Messages you send us through email or live chat
- Phone conversations
- Documents you send us to verify your account
- Details from payment providers
- Traffic information, location data, and other communication data such as your IP-address and browser type which is collected by the services you use
- Device information, including unique device identifier
- Your gaming activities
- Information about deposits, payment methods you use, and other account transactions. We frequently analyse this information to give you a better service
- Information about your engagement with marketing campaigns from us or third parties, such as opening of emails or click-through rates
- Details from your profiles on social media. This might include name, profile picture, and any other information you share when you connect with us through your social media account
- Information derived from profiling activity. See more below
- Information from third-party databases which is needed for us to adhere to our legal and regulatory obligations
- Social media profiles and data used to prevent fraud and money laundering
- Analyse site traffic
- Gain knowledge of user trends
- Identify your preferred language
- Give you personally tailored content
- Maintain user sessions
- Verify your identity on our servers
- For us to adhere to the settings on your user account
Information we collect from third parties
The personal information we have about you might not always come directly from you. Sometimes, we might collect information from third parties, such as:
- Business partners
- Service providers
- Publicly available websites, such as social media platforms
Why do we collect this information?
We collect information from third parties when:
- It’s needed for us to adhere to our legal and regulatory obligations
- To provide services we think might interest you
- To maintain data accuracy
- To enhance our services
How we use data for account setup, verification, and management
To set up and administer your account we use the following data:
- Email address
- Mobile number
- Device information
We also use the information mentioned above to:
- Verify your identity and age
- Process payment and service information
- Provide you with technical support and customer care
- To ensure compliance with our Terms and Conditions
We also use your personal data to make sure your registration details are accurate. At times, we’re required to share this information with third parties, such as financial institutions and third-party reference agencies, in order for us to adhere to our legal obligations.
How we use data for personalisation
We use your personal information to give you personally tailored content and customise the user experience. It’s always a way for us to make sure you get the bonuses and services you want.
How we use data for marketing purposes
We use the information you give us to send you marketing communication through email, text messages, push notifications, or other mediums. We do this to inform you about offers, services, and other things we think you might find interesting. We’ll keep sending you these kinds of messages until you no longer have an account with us, or actively choose to stop receiving messages from us.
We might send you emails or text messages with instructions on how to opt out from receiving marketing communication in the future. You can opt out at any time by clicking the “Personal Settings” tab in your account (https://twin.com/user/profile/settings).
We might also publish your username when we present winners on the site. For instance, this might occur when you partake in raffles and tournaments.
How we use data for risk management
To provide you with services, and for legal purposes, we process personal data to evaluate and manage risks to our business.
How we use data for legal and regulatory obligations
We might have to use and hold on to personal information for legal reasons. Mainly, we hold on to data to prevent, detect, or investigate a crime or fraudulent behaviour. We might also use information for internal and external audit purposes, or for information security purposes. Finally, we might use this data when we think it’s necessary or appropriate, such as when:
It’s applicable under law, including laws outside your country of residence
To respond to requests from courts, law enforcement agencies, regulatory bodies, or any other public or governmental authorities. This includes authorities outside your country of residence.
How we use data for profiling
In accordance with our legal obligations and other interests mentioned below, we carry out profiling and analysis based on
- Location data
- Gameplay activity
- Interests and behaviours
The data is analysed for the following purposes:
- Licensing and legal obligations
- Responsible gaming purposes
- Anti Money Laundering purposes
- Age verification
- Fraud prevention
We might use and hold on to information for other purposes, such as:
- Loss prevention
- To protect our rights, privacy, safety, property or those of other persons in accordance with our legitimate interests
How the information we have is shared
We might share your personal data for several reasons, such as:
- For Customer Support purposes
- For Payment purposes
- For marketing purposes
- Data analysis
- For research and in surveys
- Identity verification
We may also be required to share your information when calculating fees and benefits that are owed.
For legal reasons
If we believe it’s needed, we’ll share personal information. This can happen when:
- To adhere to our legal obligations and respond to request from government agencies. This includes law enforcement and other public authorities, both inside and outside of your country of residence
- In the event of a merger or the sale, restructure, acquisition, joint venture, assignment, transfer or any other disposition of all, or a part of the business, assets or stock. This includes connections with any bankruptcy.
- To protect our rights, users, systems, and services
When we hold on to information
Sometimes we might have to hold on to your information indefinitely. This mainly happens in situations related to responsible gaming, self-exclusion, and investigation of money laundering. When this happens we’ll always make sure that your information is kept private.
Third party agreements
How you can stop us from using your personal information
As a user, you have the right to ask us to delete, remove or stop using personal information we have about you. This is known as “the right to object”, or the “right to be forgotten”.
However, there might be legal, or other reasons for us to keep your data. Sometimes we have to restrict the usage of your data. This means that the data can only be used for certain things, such as legal claims or to exercise legal rights. When your data is restricted we don’t use it in any other way. You can ask us to restrict your data when:
- When the data isn't accurate
- When the data has been used unlawfully but you don’t want us to delete it
- When data is not relevant anymore but you want to keep it for legal claims
- When you’ve already asked us to stop using your data and you’re waiting for us let you know if we’re allowed to keep using it
Your rights to data portability
You have the right to data portability. This means you’re allowed to obtain the personal data you’ve given us, as well as any other data we’ve collected about you. You have the right to obtain the data in a format that lets you transfer it to another organisation. You might also have the right to ask us to transfer the data to the other organisation directly when it’s technically feasible.
If you'd like to give some feedback on our data processing practices, follow this link
Your safety first
We can ensure the safety of your personal data and player funds as follows:
- All data that you pass on to us is encrypted by means of Secure Socket Layer (SSL) technology so that it is kept private. SSL is an industry standard used by all trustworthy entities to secure their online transactions with their customers. You can tell that a website is authentic and secure if you see the padlock symbol and HTTPS before the URL as against HTTP, which is not encrypted.
- All your monetary transactions are secured via our payment methods, which are PDI DSS compliant. This is the Payment Card Industry Data Security Standard that safeguards your data and funds when using credit cards.
Licenced and regulated
We run our casino under with a PAGCOR license, which is the leading and only regulatory board in The Filipino market
This means we follow the most rigorous practices when it comes to player protection and responsible gaming, and that our Players are protected by Filipino local law.