ezwin5 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how ezwin5 ("the Platform," "we," "us," or "our") collects, processes, stores, and protects the personal information of users ("you," "Player," or "User") who access or use the ezwin5 online gaming platform at https://ezwin5.com.

ezwin5 is committed to protecting the privacy and personal data of all players in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its implementing rules and regulations. We take our obligations as a data controller seriously and have implemented appropriate technical and organizational measures to safeguard your personal information.

By registering an account on ezwin5 or by continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the platform and contact us to request account closure.

This Policy should be read alongside the ezwin5 Terms & Conditions, which govern your overall use of the platform. In the event of any conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, ezwin5 is the data controller responsible for your personal information collected through the platform. As data controller, ezwin5 determines the purposes and means of processing your personal data.

If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

ezwin5 collects the following categories of personal data from players:

Identity & Contact Information:

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify the 21+ age requirement);
• Registered mobile number;
• Email address;
• Residential address (city, province, and country).

Identity Verification (KYC) Documents:

• Copies of valid Philippine government-issued identification documents (e.g., PhilSys ID, passport, driver's license, SSS/GSIS ID, PRC ID, voter's ID);
• Selfie or live photo for facial verification purposes, where required;
• Proof of address documents, where required.

Financial Information:

• GCash or PayMaya mobile number associated with your e-wallet;
• Bank account name and number (for BPI, BDO, or Metrobank withdrawals);
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used;
• Account balance information.

Gaming Activity Data:

• Game session logs, including games played, bet amounts, win/loss outcomes, and session duration;
• Bonus and promotion usage history;
• Responsible gaming tool settings (deposit limits, self-exclusion status, etc.).

Technical & Device Data:

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session timestamps and login history;
• Cookie and tracking data as described in Section 10.

Communications Data:

• Records of your communications with ezwin5 customer support, including chat transcripts, emails, and call logs;
• Feedback, complaints, and dispute records.

4. How We Collect Your Data

ezwin5 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 data collected automatically when you access the platform, including IP address, device information, and session data via cookies and similar tracking technologies;
• Third-party sources: Identity verification data from KYC service providers; payment transaction data from GCash, PayMaya, BPI, BDO, and Metrobank; fraud prevention data from security service providers;
• Publicly available sources: Where permitted by law, information from publicly available databases used for fraud prevention and regulatory compliance purposes.

5. How We Use Your Personal Data

ezwin5 processes your personal data for the following purposes:

• Account management: Creating, maintaining, and managing your ezwin5 player account;
• Identity verification: Verifying your age (21+), identity, and eligibility to use the platform in compliance with regulatory requirements;
• Payment processing: Processing deposits, withdrawals, and refunds through your chosen payment method;
• Gaming services: Providing access to games, recording game outcomes, and maintaining accurate account balances;
• Promotions & bonuses: Administering bonuses, free spins, cashback offers, and other promotional activities;
• Customer support: Responding to your inquiries, complaints, and support requests;
• Fraud prevention & security: Detecting, investigating, and preventing fraudulent activity, money laundering, multi-accounting, and other prohibited conduct;
• Regulatory compliance: Complying with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations and reporting requirements;
• Responsible gaming: Monitoring gaming activity to identify potential problem gambling patterns and administering responsible gaming tools;
• Platform improvement: Analyzing usage patterns to improve the platform's features, performance, and user experience;
• Communications: Sending you account-related notifications, security alerts, and — where you have opted in — promotional communications.

ezwin5 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

6. Legal Basis for Processing

ezwin5 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and ezwin5 (i.e., providing gaming services, processing payments, managing your account);
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, KYC requirements, and regulatory reporting obligations;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and certain cookie-based tracking, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

ezwin5 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 only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing your financial transactions;
• KYC and identity verification providers: Third-party service providers that assist with identity verification and age verification;
• Fraud prevention and security providers: Service providers that assist with detecting and preventing fraudulent activity on the platform;
• IT and infrastructure providers: Cloud hosting, data storage, and platform infrastructure providers who process data on our behalf under strict data processing agreements;
• Regulatory and law enforcement authorities: Where required by applicable Philippine law, court order, or regulatory directive, including disclosures to PAGCOR, the Anti-Money Laundering Council (AMLC), or law enforcement agencies;
• Professional advisors: Legal counsel, auditors, and other professional advisors, subject to confidentiality obligations.

All third-party service providers who process personal data on behalf of ezwin5 are required to do so under written data processing agreements that impose data protection obligations consistent with this Policy and applicable law.

8. Data Retention

ezwin5 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specific retention periods applicable to ezwin5 data include:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship, as required by Philippine AML regulations;
• Transaction records: Retained for a minimum of five (5) years following the date of the transaction;
• Customer support communications: Retained for three (3) years following the resolution of the relevant inquiry or complaint;
• Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter as evidence of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with ezwin5's data disposal procedures.

9. Data Security

ezwin5 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• SSL/TLS encryption for all data transmissions between your device and the ezwin5 platform;
• Encryption of sensitive data at rest, including payment information and identity documents;
• Access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of the platform;
• Two-factor authentication (2FA) available for all player accounts;
• Incident response procedures for detecting, reporting, and responding to personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ezwin5 will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.

10. Cookies & Tracking Technologies

ezwin5 uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and support security functions. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled;
• Functional cookies: Remember your preferences and settings (e.g., language, display preferences) to provide a more personalized experience;
• Analytics cookies: Collect anonymized data about how players use the platform to help us improve performance and user experience;
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ezwin5 platform. Strictly necessary cookies cannot be disabled as they are essential for platform operation.

11. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ezwin5:

• Right to be informed: The right to be informed about how your personal data is collected and processed, as described in this Policy;
• Right of access: The right to request a copy of the personal data ezwin5 holds about you;
• 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, subject to applicable legal retention requirements;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to withdraw consent: Where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of prior processing;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will respond to your request within thirty (30) days. We may require you to verify your identity before processing your request.

12. Minors

13. Changes to This Privacy Policy

ezwin5 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform features. When material changes are made, we will notify registered players via the mobile number or email address associated with their account and update the "Effective Date" at the top of this page.

Your continued use of the ezwin5 platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how we protect your personal data.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the ezwin5 Data Protection Officer. Our support team is available 24/7.

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012.