Privacy Policy

1. Introduction

ezwin Casino is committed to protecting the privacy and security of your personal information. This Policy has been prepared in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations, as administered by the National Privacy Commission of the Philippines.

This Policy applies to all personal data collected through the ezwin Casino website, mobile applications, customer support channels, and any other touchpoints through which you interact with the ezwin platform. It should be read together with the ezwin Casino Terms & Conditions, which govern your use of the Platform.

We review and update this Policy periodically to reflect changes in our data practices, applicable law, or regulatory guidance. The date of the most recent revision is indicated at the top of this document.

---

2. Data Controller

For the purposes of the Data Privacy Act of 2012, ezwin Casino acts as the personal information controller in respect of the personal data collected through the Platform. Our designated Data Privacy Officer ("DPO") is responsible for overseeing compliance with this Policy and applicable data privacy laws.

You may contact the DPO at any time with questions, concerns, or requests relating to your personal data. Contact details are provided in Section 15 of this Policy.

---

3. Data We Collect

ezwin Casino collects the following categories of personal data:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification numbers (e.g., passport number, driver's licence number, SSS/UMID number).
• Contact Data: Email address, mobile phone number, and residential address.
• Account Data: Username, account number, account preferences, and communication history with ezwin Casino.
• Financial Data: GCash account details, Maya account details, bank account numbers (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), debit card details, transaction history, deposit and withdrawal records.
• Gaming Data: Game history, wagering activity, session duration, bonus usage, and responsible gaming tool settings.
• Technical Data: IP address, device identifiers, browser type and version, operating system, time zone, and platform access logs.
• Usage Data: Information about how you navigate and interact with the Platform, including pages visited, features used, and click-stream data.
• KYC Documentation: Copies of government-issued identification documents and supporting documents submitted for identity verification purposes.

We do not intentionally collect sensitive personal information (as defined under the DPA) unless it is strictly necessary for compliance with legal obligations, such as anti-money laundering regulations.

---

4. How We Collect Data

ezwin Casino collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the Platform, including cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Data received from payment processors (GCash, Maya, banks), identity verification service providers, fraud prevention agencies, and regulatory authorities, where permitted by law.
• Public sources: Publicly available information used for fraud prevention and compliance purposes, such as sanctions lists and politically exposed persons (PEP) databases.

---

5. Purpose of Processing

ezwin Casino processes your personal data for the following purposes:

• To create, manage, and maintain your player account.
• To verify your identity and age in compliance with Philippine gaming regulations (21+ requirement).
• To process deposits, withdrawals, and other financial transactions.
• To detect, prevent, and investigate fraud, money laundering, and other illegal activity.
• To comply with legal and regulatory obligations, including reporting requirements under the Anti-Money Laundering Act (AMLA) and gaming regulations.
• To provide customer support and respond to your enquiries and complaints.
• To administer bonuses, promotions, and loyalty programmes.
• To personalise your gaming experience and improve the Platform.
• To send you service-related communications, including account notifications and security alerts.
• To enforce the ezwin Casino Terms & Conditions and protect the rights of ezwin Casino and other players.
• To support responsible gaming initiatives, including monitoring for signs of problem gambling and administering self-exclusion requests.

---

6. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions, including account management and transaction processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including the DPA, AMLA, and gaming regulations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and the improvement of our services, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for certain marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

---

7. Data Sharing and Disclosure

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

• Payment processors: GCash, Maya, and banking partners, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers.
• Game providers: Licensed game software providers whose titles are available on the Platform, to the extent necessary for game operation and dispute resolution.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers operating under strict data processing agreements.
• Regulatory and law enforcement authorities: The Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent authorities, where required by law.
• Professional advisers: Lawyers, auditors, and accountants, subject to professional confidentiality obligations.

Any third party with whom we share personal data is required to process that data only for the specified purpose and in accordance with applicable data privacy laws.

---

8. Data Retention

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

• Account data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• KYC documentation: Retained for a minimum of five (5) years following the end of the business relationship.
• Technical and usage data: Retained for up to two (2) years from the date of collection, unless a longer period is required for security or legal purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

---

9. Cookies and Tracking Technologies

ezwin Casino uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how the Platform is used.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled.
• Performance cookies: Used to collect anonymised analytics data about how players use the Platform, helping us identify and fix issues.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. ezwin Casino does not use third-party advertising or tracking cookies.

---

10. Data Security

ezwin Casino implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including financial data and KYC documentation.
• Two-factor authentication (2FA) available for all player accounts.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing conducted by independent third parties.
• Incident response procedures to detect, contain, and notify affected individuals and the National Privacy Commission of any personal data breach within the timeframes prescribed by the DPA.

While ezwin Casino takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

---

11. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ezwin Casino:

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed, as set out in this Policy.
• Right of access: The right to request a copy of the personal data we hold about you and information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation, where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Privacy Officer using the details provided in Section 15. We will respond to all verified requests within fifteen (15) business days, in accordance with the DPA. We may require proof of identity before processing your request.

---

12. Children's Privacy

The ezwin Casino platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on the Platform, please contact our support team immediately.

---

13. Cross-Border Data Transfers

In certain circumstances, personal data collected by ezwin Casino may be transferred to, stored in, or processed in countries outside the Philippines — for example, where our technology infrastructure providers or game software partners operate servers in other jurisdictions.

Where such transfers occur, ezwin Casino ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual clauses approved by the National Privacy Commission or equivalent data protection authorities.

By using the Platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the operation of the Platform, subject to the safeguards described above.

---

14. Amendments to this Policy

ezwin Casino reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory guidance. The revised Policy will be published on the Platform with an updated effective date.

Where changes are material, we will endeavour to notify registered players via email or an in-platform notification prior to the changes taking effect. Your continued use of the Platform following the publication of any amendment constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how ezwin Casino protects your personal information.

---

15. Contact & Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the ezwin Casino Data Privacy Officer:

• Data Privacy Officer Email: dpo ezwin.asia
• General Support Email: support ezwin.asia

Our support team is available 24 hours a day, 7 days a week. For formal data subject requests, please include your full name, registered email address, and a clear description of your request. We may require a copy of a valid government-issued ID to verify your identity before processing the request.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.