ezwin Privacy
Policy

01. Introduction

ezwin ("the Company," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who interact with the ezwin online gaming platform, accessible at ezwin.one ("the Platform"). This Privacy Policy has been prepared in accordance with the requirements of Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC") of the Philippines.

This Privacy Policy describes the types of personal information that ezwin collects from and about you, the purposes for which that information is used, the parties with whom it may be shared, the security measures we employ to protect it, and the rights available to you as a data subject under Philippine law. It applies to all personal data collected through the ezwin website, mobile platform, customer support channels, and any other touchpoints through which you interact with ezwin.

This Privacy Policy should be read together with the ezwin Terms & Conditions, which govern your use of the platform and form part of the overall agreement between you and ezwin.

02. Data Controller

For the purposes of the Data Privacy Act of 2012 and its IRR, ezwin acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes in connection with the operation of the ezwin platform. As PIC, ezwin determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

Where ezwin engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and IT infrastructure partners — those parties act as Personal Information Processors (PIPs) and are bound by data processing agreements that require them to process personal data only on ezwin's documented instructions and in compliance with applicable data protection law.

03. Personal Data We Collect

ezwin collects the following categories of personal data in connection with the provision of its services:

3.1 Identity and Contact Data

• Full legal name as it appears on a government-issued ID
• Date of birth and age verification information
• Residential address (including barangay, city/municipality, province)
• Email address and mobile number
• Government-issued identification document numbers (e.g., Philippine passport, driver's license, PhilSys National ID, UMID, SSS ID)
• Selfie or photograph submitted for identity verification purposes

3.2 Account and Transaction Data

• ezwin account username and encrypted password credentials
• Account registration date and history of account changes
• Deposit and withdrawal transaction records, including amounts, dates, and payment method references
• GCash, PayMaya, BPI, BDO, and Metrobank account references (masked where applicable)
• Bonus and promotional activity records
• Gaming history, including games played, wager amounts, and outcomes

3.3 Technical and Usage Data

• IP address and approximate geolocation data
• Device type, operating system, and browser information
• Session duration, login timestamps, and platform navigation data
• Cookie identifiers and similar tracking technology data (see Section 8)

3.4 Communications Data

• Records of communications between you and the ezwin customer support team
• Feedback, complaints, and dispute records
• Marketing preference records and communication opt-in/opt-out history

04. How We Collect Your Data

ezwin collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar technologies when you access and use the ezwin platform.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment verification data from payment processors such as GCash and PayMaya.
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with licensing compliance or investigation requirements.

05. Purposes of Processing

ezwin processes your personal data for the following purposes:

Purpose	Description
Account Management	Creating, maintaining, and administering your ezwin player account, including authentication and security.
Identity Verification (KYC)	Verifying your identity and age (21+) in compliance with PAGCOR requirements and anti-money laundering regulations.
Payment Processing	Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
Regulatory Compliance	Meeting obligations under Philippine law, including AML/CTF regulations, PAGCOR licensing conditions, and the Data Privacy Act.
Fraud Prevention	Detecting, investigating, and preventing fraudulent activity, money laundering, and other prohibited conduct on the platform.
Customer Support	Responding to your queries, complaints, and support requests in a timely and effective manner.
Responsible Gaming	Monitoring gaming activity to identify problem gambling indicators and enforcing responsible gaming tools and self-exclusion requests.
Marketing	Sending promotional offers, bonuses, and platform updates where you have provided consent to receive such communications.
Platform Improvement	Analyzing usage patterns and technical data to improve platform performance, user experience, and game offerings.

06. Legal Basis for Processing

Under the Data Privacy Act of 2012, ezwin processes your personal data on the following legal bases:

• Consent: Where you have given your freely given, specific, informed, and unambiguous consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and ezwin — specifically, the provision of online gaming services as described in the Terms & Conditions.
• Legal Obligation: Where processing is required to comply with a legal obligation to which ezwin is subject, including AML/CTF regulations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate Interests: Where processing is necessary for the legitimate interests of ezwin or a third party, such as fraud prevention, platform security, and responsible gaming monitoring, provided that such interests are not overridden by your rights and interests.

07. Data Sharing & Disclosure

ezwin does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML screening service providers engaged to verify your identity and screen against sanctions and watchlists.
• IT and Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on ezwin's behalf under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or regulatory directive.
• Professional Advisors: Legal counsel, auditors, and compliance consultants, where necessary for the conduct of ezwin's business and subject to professional confidentiality obligations.

08. Cookies & Tracking Technologies

The ezwin platform uses cookies and similar tracking technologies to enhance your user experience, maintain session security, and collect analytical data about platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the platform, including session management, authentication, and security. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Used to remember your preferences and settings, such as language preferences and responsible gaming tool configurations.
• Analytical Cookies: Used to collect aggregated, anonymized data about how users interact with the platform, helping ezwin improve performance and user experience.
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ezwin platform. Strictly necessary and security cookies cannot be disabled as they are essential to the secure operation of the platform.

09. Data Retention

ezwin retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

Data Category	Retention Period
Account and Identity Data	Duration of account plus 5 years after account closure, in compliance with AML record-keeping requirements.
Transaction Records	5 years from the date of the transaction, as required by the Anti-Money Laundering Act.
KYC Documents	5 years from account closure or last transaction, whichever is later.
Customer Support Records	3 years from the date of the last interaction.
Marketing Preferences	Until consent is withdrawn or the account is closed, plus 1 year for audit purposes.
Technical / Log Data	Up to 12 months from collection, unless required for ongoing fraud investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with ezwin's data disposal procedures.

10. Data Security

ezwin implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data in transit is protected using TLS 1.2 or higher. All sensitive data at rest is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All staff with access to personal data undergo background checks and regular data privacy training.
• Network Security: The ezwin platform is protected by enterprise-grade firewalls, intrusion detection systems, and DDoS mitigation infrastructure.
• Vulnerability Management: Regular security assessments, penetration testing, and vulnerability scanning are conducted to identify and remediate security risks.
• Incident Response: ezwin maintains a documented data breach response procedure. In the event of a personal data breach that poses a real risk to data subjects, ezwin will notify the National Privacy Commission and affected individuals within the timeframes prescribed by the DPA and its IRR.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ezwin. You may exercise any of these rights by contacting us using the details in Section 14:

ezwin will respond to all data subject rights requests within 30 calendar days of receipt. In complex cases, this period may be extended by a further 30 days, in which case you will be notified of the extension and the reasons for it. There is no fee for exercising your data subject rights, unless requests are manifestly unfounded or excessive.

If you are not satisfied with ezwin's response to a data subject rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

12. Children's Privacy

The ezwin platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gambling regulations. ezwin does not knowingly collect personal data from individuals under the age of 21. If ezwin becomes aware that personal data has been collected from a person under 21, such data will be immediately deleted and the associated account will be permanently closed.

If you are a parent or guardian and believe that your child has registered on the ezwin platform or provided personal data to ezwin, please contact us immediately using the details in Section 14 so that we can take appropriate action.

13. Updates to This Privacy Policy

ezwin reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The effective date of the current version is displayed at the top of this page.

Where changes to this Privacy Policy are material, ezwin will make reasonable efforts to notify registered players via email or an in-platform notification prior to the changes taking effect. We encourage you to review this Privacy Policy periodically to stay informed about how ezwin protects your personal data.

Your continued use of the ezwin platform following the posting of any changes to this Privacy Policy constitutes your acknowledgment of those changes. If you do not agree with the updated Privacy Policy, you must cease using the platform and may request account closure in accordance with the Terms & Conditions.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ezwin, please contact our Data Protection Officer or customer support team using the details below. Our support team is available 24 hours a day, 7 days a week, and is ready to assist players from Manila, Cebu, Davao, Quezon City, Makati, and across the Philippines.

If you wish to lodge a complaint about ezwin's data processing practices with the Philippine data protection authority, you may contact the National Privacy Commission (NPC) directly. Details of how to contact the NPC are available on the NPC's official website.

For matters relating to responsible gaming, account self-exclusion, or problem gambling support, please visit our dedicated Responsible Gaming page.