eazywin
Privacy Policy

1 Overview & Scope

This Policy applies to all personal data collected and processed by eazywin in connection with the eazywin platform and services, including but not limited to: account registration and management; deposits and withdrawals; game participation; sports betting; customer support interactions; bonus and promotional participation; and marketing communications.

This Policy applies to all users of the eazywin platform regardless of their location within the Philippines, including players in Metro Manila, Cebu, Davao, and all other regions. It does not apply to third-party websites or services that may be referenced on the platform, which are governed by their own privacy policies.

eazywin acts as a Personal Information Controller (PIC) under RA 10173 with respect to the personal data described in this Policy. In certain circumstances — such as when processing data on behalf of game providers — eazywin may act as a Personal Information Processor (PIP). Both roles carry legal obligations that eazywin takes seriously.

2 Personal Data We Collect

eazywin collects personal data necessary to provide and improve the platform. The categories of personal data we collect are set out in the table below:

eazywin does not collect sensitive personal information (as defined by RA 10173 Section 3(l)) beyond what is strictly required for age verification, identity verification, and AML (Anti-Money Laundering) compliance. Where sensitive data is collected — such as government ID details — it is processed under strict access controls and is not used for any purpose other than those stated in this Policy.

3 How We Collect Your Data

eazywin collects personal data through the following channels and methods:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or updating your account profile.
• Platform activity: Data generated automatically as you use the eazywin platform — including game participation logs, betting records, session data, and responsible gaming tool usage.
• Payment processors: Transaction reference data transmitted by GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard payment gateways when you make a deposit or withdrawal. eazywin does not store full card numbers; only tokenized or masked references are retained.
• Cookies and tracking technologies: Session cookies, analytical cookies, and similar technologies deployed on the eazywin platform. See Section 10 for full details.
• Third-party game providers: Aggregated or session-level data shared by game software providers (such as Vivo Gaming, PG Soft, Pragmatic Play) necessary to render game history and resolve disputes.
• Identity verification services: Where eazywin uses a third-party KYC provider to verify identity documents, that provider shares the verification outcome (pass/fail) and a confidence score with eazywin. Raw document images are not retained by eazywin beyond the KYC process.

4 Purposes of Processing

eazywin processes your personal data only for the purposes listed below. Processing for any new or incompatible purpose will be disclosed to you and, where required by law, will require your fresh consent.

• Account creation and management: To register, authenticate, and maintain your eazywin account.
• KYC and age verification: To comply with PAGCOR-aligned age verification requirements and AML obligations under Philippine law.
• Payments processing: To facilitate deposits, process withdrawal requests, and maintain accurate financial records.
• Game delivery and history: To deliver game content, record bet outcomes, calculate winnings, and maintain a transparent game history accessible to you.
• Bonus and promotional administration: To credit bonuses, verify wagering requirement completion, and administer loyalty programme benefits.
• Responsible gaming: To enforce player-set deposit limits, loss limits, session timers, and self-exclusion instructions; to identify players who may need responsible gaming support.
• Customer support: To respond to your enquiries, complaints, and support requests; to maintain records for quality assurance.
• Platform security: To detect, prevent, and investigate fraud, bonus abuse, account takeover, money laundering, and other prohibited conduct.
• Legal and regulatory compliance: To meet reporting obligations under the AMLA, NPC regulations, PAGCOR guidelines, and other applicable Philippine laws.
• Platform improvement: To analyse aggregate usage patterns, identify technical issues, and improve the eazywin experience.
• Marketing communications: To send promotional offers, bonus alerts, and platform updates — subject to your communication preferences and opt-in/opt-out status.

5 Legal Basis for Processing

Under RA 10173, eazywin processes personal data on the following lawful bases:

• Consent (Section 12(a)): For marketing communications, promotional opt-ins, and non-essential analytics. You may withdraw consent at any time without affecting prior processing.
• Contractual necessity (Section 12(b)): For data required to register your account, deliver platform services, process payments, and administer your gaming activity — all necessary to fulfill our contract with you.
• Legal obligation (Section 12(c)): For KYC/AML compliance, age verification, tax reporting, and regulatory disclosures required under Philippine law.
• Legitimate interests (Section 12(f)): For fraud prevention, platform security, responsible gaming monitoring, and improving the platform — where these interests do not override your fundamental rights and freedoms.

6 Data Sharing & Disclosure

eazywin does not sell, rent, or trade your personal data. We share your data only in the following circumstances and with the following categories of recipients:

• Game software providers: Session and bet data shared with providers such as Vivo Gaming, PG Soft, Pragmatic Play, Jili, and Habanero for the purpose of game delivery and dispute resolution. These providers are contractually bound to process your data only for these purposes.
• Payment processors: Transaction initiation data shared with GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard payment infrastructure providers to process deposits and withdrawals.
• KYC and identity verification providers: Identity document data shared with our KYC service provider for the purpose of age and identity verification. The provider is bound by a Data Processing Agreement that limits use to verification services only.
• Regulatory and law enforcement authorities: Personal data disclosed to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies where required by applicable Philippine law, pursuant to a lawful request, court order, or regulatory obligation.
• Professional advisers: Legal counsel, auditors, and compliance consultants under confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all eazywin's assets, your personal data may be transferred to the acquirer. You will be notified of any such transfer and the privacy commitments applicable to your data post-transfer.

7 International Data Transfers

Some of eazywin's game software providers and technical infrastructure partners operate servers outside the Philippines. Where personal data is transferred internationally, eazywin ensures that adequate safeguards are in place as required by Section 21 of RA 10173 and the NPC's rules on cross-border data transfers. These safeguards may include: contractual data processing agreements containing standard data protection clauses; the transfer to countries recognized by the NPC as providing adequate data protection; or other legally recognized transfer mechanisms.

You may request details of the specific safeguards applicable to any international transfer of your data by contacting eazywin's Data Protection Officer (see Section 16).

8 Data Retention

eazywin retains personal data for the periods necessary to fulfill the purposes for which it was collected, subject to longer retention where required by law:

• Account data: Retained for the duration of your active account plus five (5) years from account closure, in accordance with AMLC record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required under the Anti-Money Laundering Act of 2001 (RA 9160) and its amendments.
• KYC documentation: Retained for the duration of your account plus five (5) years, consistent with AML record-keeping obligations.
• Game history and bet records: Retained for a minimum of three (3) years from the date of each transaction, or longer if subject to a pending dispute.
• Customer support records: Retained for three (3) years from the date of the interaction.
• Marketing communications records: Retained until you unsubscribe or withdraw consent, plus one (1) year for compliance audit purposes.

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

9 Security Measures

eazywin implements technical and organizational security measures appropriate to the risk of processing personal data, in accordance with Section 20 of RA 10173. These measures include:

• Encryption: 256-bit SSL/TLS encryption of all data in transit between your device and eazywin's servers; encryption at rest for sensitive data fields.
• Access controls: Role-based access control ensuring that eazywin personnel can only access personal data necessary for their specific function. All access is logged and audited.
• Password security: Passwords are stored using industry-standard cryptographic hashing — never in plain text.
• Two-factor authentication: OTP-based verification for new device logins and high-value withdrawal requests.
• Intrusion detection: Automated monitoring systems that detect and respond to unauthorized access attempts, suspicious login patterns, and potential data exfiltration.
• Vendor due diligence: All third-party service providers with access to personal data are assessed for security compliance prior to engagement and are bound by data processing agreements.
• Employee training: All eazywin personnel handling personal data receive data privacy training and are bound by confidentiality obligations.

10 Cookies & Tracking Technologies

eazywin uses the following categories of cookies and similar tracking technologies on the platform:

• Strictly necessary cookies: Essential for the platform to function — including session management, login authentication, and security token verification. These cannot be disabled without impairing platform access.
• Functional cookies: Remember your preferences (such as language, game lobby view, and responsible gaming settings) to provide a consistent experience across sessions.
• Analytical cookies: Collect aggregate, anonymized data about how players interact with the platform — page visit frequency, session duration, feature usage — to help eazywin improve the experience. Individual-level data from analytical cookies is not used for profiling.
• Security cookies: Used to detect fraudulent activity, multiple-account patterns, and unauthorized access attempts.

eazywin does not use third-party advertising or targeting cookies. You may manage cookie preferences through your browser settings. Note that disabling functional or analytical cookies may affect aspects of your eazywin experience but will not prevent access to core gaming functions.

11 Your Data Rights Under RA 10173

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to personal data held by eazywin. To exercise any of these rights, contact eazywin's Data Protection Officer (see Section 16).

• Right to Access (Section 16(b)): You may request a copy of the personal data eazywin holds about you, along with information about how it is processed.
• Right to Rectification (Section 16(c)): You may request correction of inaccurate or incomplete personal data. Account profile updates can be made directly through your eazywin account settings for common data fields.
• Right to Erasure / Blocking (Section 16(d)): You may request deletion or blocking of your personal data where: the data is no longer necessary for the purpose for which it was collected; you withdraw consent and there is no other lawful basis; or the data has been unlawfully processed. Note that deletion requests may be limited where retention is required by law (e.g., AML record-keeping obligations).
• Right to Object (Section 16(f)): You may object to processing based on legitimate interests, or to direct marketing at any time. Upon receipt of a valid objection, eazywin will cease the relevant processing unless it can demonstrate compelling legitimate grounds that override your rights.
• Right to Data Portability (Section 18): You may request your personal data in a structured, commonly used, machine-readable format for transfer to another controller, where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect prior lawful processing.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe eazywin has violated your data privacy rights.

eazywin will respond to all data rights requests within fifteen (15) calendar days of receipt. Where a request is complex or numerous, we may extend this period by a further thirty (30) days with notification.

12 Children's Privacy

The eazywin platform is strictly for adults aged twenty-one (21) years and above. eazywin does not knowingly collect personal data from individuals under the age of 21. If eazywin becomes aware that personal data has been collected from an individual under 21 — whether through misrepresentation during registration or otherwise — eazywin will immediately close the affected account, delete the personal data collected (except where retention is required for regulatory compliance), and return any deposits to the original payment source without applying any winnings.

Parents or guardians who believe a minor may have registered on the eazywin platform should contact the eazywin Data Protection Officer immediately. eazywin will investigate and resolve all such reports as a priority matter.

13 Marketing Communications

eazywin may send you promotional communications — including bonus offers, new game announcements, sports betting promotions, and platform updates — via SMS to your registered Philippine mobile number and/or email to your registered email address, subject to your communication preferences.

Opt-in: By default, new eazywin accounts are opted in to receive promotional communications unless you deselect this option during registration.

Opt-out: You may opt out of marketing communications at any time by: updating your communication preferences in your eazywin account settings; following the unsubscribe link in any email; or contacting eazywin customer support. Opt-out requests will be processed within five (5) business days. Unsubscribing from marketing communications does not affect transactional communications (such as deposit confirmations, withdrawal notifications, and account security alerts), which are part of the platform service and cannot be disabled.

14 Data Breach Protocol

In the event of a personal data breach — defined as a security incident involving unauthorized access to, disclosure of, or loss of personal data — eazywin will act immediately in accordance with its data breach response plan and the NPC's notification requirements under NPC Circular 16-03.

Specifically, eazywin will:

• Contain the breach and assess its nature, scope, and impact as quickly as possible
• Notify the National Privacy Commission within seventy-two (72) hours of becoming aware of a breach that is likely to result in risk to the rights and freedoms of affected data subjects
• Notify affected players without undue delay where the breach is likely to result in a high risk to their rights and freedoms, providing clear information about what happened, what data was affected, and what steps to take
• Maintain a record of all data breaches, whether or not notification to the NPC is required

If you suspect your eazywin account has been compromised, change your password immediately and contact eazywin's 24/7 customer support team.

15 Updates to This Privacy Policy

eazywin reserves the right to update this Privacy Policy to reflect changes in our data processing practices, new services, changes in applicable Philippine law, or NPC guidance. Material changes — those that significantly affect how we collect, use, or share your personal data — will be communicated to you via email or prominent in-platform notice at least fourteen (14) days before taking effect. Non-material changes (such as clarifications and structural reorganization) may be updated without advance notice.

Your continued use of the eazywin platform after the effective date of any updated Privacy Policy constitutes your acceptance of the updated Policy. If you do not accept the changes, you should cease using the platform and may request account closure and data deletion (subject to legal retention requirements).

16 Contact & Data Protection Officer

eazywin has designated a Data Protection Officer (DPO) responsible for overseeing compliance with RA 10173 and this Privacy Policy. To exercise your data rights, report a privacy concern, or ask any question about how eazywin handles your personal data, contact the DPO using the details below:

• Data Protection Officer: eazywin DPO
• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please include "Data Privacy Request" in your subject for faster routing
• Live Support: Available 24/7 through the eazywin platform; privacy requests will be escalated to the DPO
• Response Time: Privacy requests acknowledged within 48 hours; substantive responses within 15 calendar days

If you are not satisfied with eazywin's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.