Section 01
Who We Are
WOMO is a performance affiliate and influencer marketing platform operated by Make Things Happen, Inc., an SEC-registered company with principal offices at Pasay, Metro Manila, Philippines (collectively referred to as "WOMO," "we," "our," or "us").
WOMO provides software and services that connect iGaming operators, affiliate partners, and influencer creators — enabling performance tracking, commission management, campaign management, and local payout processing across Southeast Asia.
This Privacy Policy explains how we collect, use, store, and share personal data when you use our platform at womonow.com and related services (collectively, the "Platform"). It applies to operators, affiliate partners, influencers, and visitors to our website.
By accessing or using the WOMO Platform, you agree to the collection and use of information as described in this Policy. If you do not agree, please do not use our services.
Section 02
Information We Collect
We collect information you provide directly, information generated through your use of the Platform, and information from third-party sources.
Information you provide directly:
- Account registration: Full name, email address, username, password, and account type (operator, affiliate, or influencer)
- Business information: Company or brand name, business address, website URL, and industry vertical
- Identity verification: Government-issued ID, tax identification number, and business registration documents (where required for compliance)
- Payment and payout details: Bank account information, GCash or Maya wallet numbers, billing address, and payout preferences
- Communications: Messages you send us via email, support tickets, or contact forms
- Marketing inquiries: Name, email, and information you submit through demo request or campaign brief forms
Information generated automatically:
- Usage data: Pages visited, features used, time spent, clicks, and navigation paths within the Platform
- Performance data: Tracking links clicked, conversions, impressions, commission events, and campaign metrics attributed to your account
- Device and technical data: IP address, browser type and version, operating system, device identifiers, and referring URLs
- Log data: Server logs recording your interactions with the Platform, including timestamps and error events
Information from third parties:
- Operator platforms and tracking systems that integrate with WOMO via API to pass conversion and FTD (First Time Deposit) data
- Social media platforms (with your permission) to verify influencer account metrics and audience data
- Payment processors and e-wallet providers to confirm transaction status
Section 03
How We Use Your Information
| Purpose |
Description |
| Account management |
Creating, maintaining, and securing your WOMO account and providing access to the Platform |
| Service delivery |
Processing affiliate tracking, calculating commissions, managing campaign delivery, and generating performance reports |
| Payments and payouts |
Processing commissions and campaign payments to partners via bank transfer, GCash, Maya, or other supported payout methods |
| Compliance and verification |
Verifying identity, screening for regulatory compliance, enforcing platform terms, and maintaining audit trails as required by applicable law |
| Communication |
Sending account notifications, payout confirmations, product updates, and responding to your support requests |
| Platform improvement |
Analysing usage patterns to improve features, fix bugs, and develop new capabilities |
| Marketing |
Sending promotional communications about WOMO features and relevant offers, where you have provided consent or we have a legitimate interest to do so |
| Security and fraud prevention |
Detecting, investigating, and preventing fraudulent clicks, fake conversions, unauthorized access, and other abuse of the Platform |
Section 04
Legal Bases for Processing
We process your personal data on the following legal bases under the Philippine Data Privacy Act (Republic Act No. 10173) and applicable data protection law:
- Contract performance: Processing necessary to provide the services you have signed up for, including account management, tracking, and payouts
- Legitimate interests: Processing necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement — provided those interests do not override your rights
- Legal obligation: Processing required to comply with applicable law, regulatory requirements, and lawful requests from government authorities
- Consent: Where we rely on your explicit consent, such as for certain marketing communications or optional data integrations — you may withdraw consent at any time without affecting prior processing
Section 05
Sharing Your Information
We do not sell your personal data. We share information only in the following circumstances:
- With operators and partners on the Platform: Aggregated and attributed performance data (e.g., clicks, conversions, commission amounts) is shared between operators and the affiliate or influencer partners they work with, as necessary to fulfil the partnership
- With service providers: Trusted third-party providers who process data on our behalf — including cloud hosting, payment processors, analytics tools, email delivery, and customer support platforms — under contractual data protection obligations
- With Digirockstars: WOMO is operated in connection with Digirockstars (Make Things Happen, Inc's agency arm). Data may be shared internally to coordinate service delivery, billing, and account management
- For legal and compliance purposes: Where required by law, court order, or lawful request from a government or regulatory authority, including PAGCOR, the National Privacy Commission, or law enforcement
- In a business transaction: In the event of a merger, acquisition, or sale of all or part of our business, your data may be transferred to the successor entity, with appropriate notice provided
- With your consent: In any other circumstances where you have given us explicit permission to share your information
We require all third-party service providers to handle personal data in accordance with applicable privacy law and to implement appropriate technical and organisational security measures.
Section 06
Cookies & Tracking Technologies
We use cookies and similar tracking technologies to operate the Platform, measure performance, and improve your experience. The types of cookies we use include:
- Strictly necessary cookies: Essential for the Platform to function — including authentication, session management, and security. These cannot be disabled.
- Performance cookies: Help us understand how visitors use the Platform (e.g., pages visited, time on site, errors encountered) so we can improve it. Data is aggregated and anonymised where possible.
- Affiliate tracking cookies: Used to attribute conversions, clicks, and FTD events to the correct affiliate partner. These are core to the Platform's functionality.
- Marketing cookies: Used to deliver relevant promotional content on our website and across third-party channels, where you have consented.
You can manage non-essential cookies through your browser settings. Note that disabling certain cookies may affect Platform functionality. Affiliate tracking cookies are necessary for the core service and cannot be disabled while using the Platform.
Section 07
Data Retention
We retain personal data for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods:
- Account data: Retained for the duration of your account and for up to 3 years after account closure, unless a longer period is required by law
- Transaction and payout records: Retained for a minimum of 5 years to comply with financial recordkeeping requirements
- Tracking and conversion data: Retained for up to 2 years for performance reporting and dispute resolution
- Communications and support records: Retained for up to 2 years after the last interaction
- Identity verification documents: Retained for the duration required by applicable regulations and deleted securely thereafter
When data is no longer needed, we securely delete or anonymise it in accordance with our data retention procedures.
Section 08
Your Rights
Under the Philippine Data Privacy Act (RA 10173) and other applicable law, you have the following rights regarding your personal data:
- Right to be informed: To know how your personal data is being collected and processed
- Right of access: To request a copy of the personal data we hold about you
- Right to rectification: To correct inaccurate or incomplete personal data
- Right to erasure: To request deletion of your personal data where we no longer have a lawful basis to retain it
- Right to object: To object to processing based on legitimate interests or for direct marketing purposes
- Right to data portability: To receive your personal data in a structured, commonly used format
- Right to withdraw consent: Where processing is based on consent, to withdraw it at any time without affecting prior processing
- Right to lodge a complaint: To file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated
To exercise any of these rights, please contact us using the details in Section 12. We will respond within 30 days of receiving your request. We may need to verify your identity before processing certain requests.
Section 09
Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:
- Encryption of data in transit using TLS/HTTPS
- Encryption of sensitive data at rest
- Access controls and role-based permissions limiting internal access to personal data
- Regular security assessments and monitoring
- Secure data processing agreements with all third-party service providers
No method of transmission over the internet is 100% secure. While we take your data security seriously, we cannot guarantee absolute security. In the event of a data breach that is likely to affect your rights and freedoms, we will notify you and the National Privacy Commission as required by law.
Section 10
Children's Privacy
WOMO is a business-to-business platform intended for use by adults operating or participating in licensed iGaming and digital marketing programs. We do not knowingly collect personal data from individuals under the age of 18.
If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that information. If you believe we may have collected data from a minor, please contact us immediately.
Section 11
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or Platform features. When we make material changes, we will:
- Update the "Last Updated" date at the top of this page
- Notify registered users via email or in-platform notification for significant changes
- Where required by law, seek your consent before applying changes that affect how we process your data
We encourage you to review this Policy periodically. Your continued use of the Platform after any changes constitutes acceptance of the updated Policy.
Section 12
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact our Data Privacy Officer: