ezph Privacy Policy

1. Introduction

ezph ("we," "us," "our") operates the online gaming platform accessible at ezph.org (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, whether as registered players or as visitors browsing our content.

This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), and its Implementing Rules and Regulations. It sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by ezph.

Please read this Privacy Policy carefully. If you have any questions about how we handle your personal data, you are welcome to contact us using the details provided in Section 15 of this policy. Your trust matters to us, and we want to be as transparent as possible about our data practices.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, ezph is the personal information controller in respect of the personal data collected through the Platform. This means that ezph determines the purposes for which, and the manner in which, your personal data is processed.

Our designated Data Protection Officer (DPO) is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. You may contact our DPO directly using the contact details set out in Section 15 of this policy.

3. Data We Collect

Depending on how you interact with the ezph Platform, we may collect the following categories of personal data:

3.1 Identity and Contact Data

• Full legal name
• Date of birth (for age verification purposes)
• Nationality and country of residence
• Email address
• Mobile phone number
• Residential address

3.2 Identity Verification Data

• Government-issued identification documents (e.g., Philippine National ID, passport, driver's licence, SSS/GSIS ID)
• Selfie or facial image submitted for identity verification
• Proof of address documents

3.3 Account and Transaction Data

• Username and encrypted password
• Account registration date and history
• Deposit and withdrawal records, including amounts and payment method references
• Bonus and promotion history
• Gaming activity records, including game history, wager amounts, and session durations

3.4 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, features used, and time spent on the Platform
• Referring URLs and search terms used to find the Platform
• Cookie identifiers and similar tracking data (see Section 7)

3.5 Communications Data

• Records of communications between you and ezph customer support
• Feedback, complaints, and survey responses
• Email and notification preferences

4. How We Collect Your Data

ezph collects personal data through the following means:

• Direct interactions: Data you provide when registering an Account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Data received from identity verification service providers, payment processors, 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. How We Use Your Data

ezph uses your personal data for the following purposes:

Purpose	Description
Account Management	To register and maintain your ezph Account, verify your identity, and manage your player profile.
Service Delivery	To provide access to games, process deposits and withdrawals, and deliver the features of the Platform.
Legal Compliance	To comply with anti-money laundering (AML) obligations, PAGCOR regulatory requirements, and other applicable Philippine laws.
Fraud Prevention	To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the Platform.
Responsible Gaming	To monitor gaming behaviour, enforce deposit limits and self-exclusion requests, and identify players who may need support.
Customer Support	To respond to your queries, complaints, and feedback, and to improve our support services.
Marketing	To send you promotional offers, bonuses, and platform updates, where you have consented to receive such communications.
Platform Improvement	To analyse usage patterns, conduct research, and improve the features, performance, and security of the Platform.

6. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you, including providing access to the Platform, processing transactions, and managing your Account.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations, PAGCOR requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for our legitimate interests, including fraud prevention, platform security, and improving our services, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device when you visit the ezph Platform. They help us recognise your device, remember your preferences, and understand how you use our Platform. We also use similar technologies such as web beacons, pixel tags, and local storage objects.

7.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and game history to provide a more personalised experience.
• Analytics cookies: Help us understand how players use the Platform by collecting aggregated, anonymised data about page visits, session durations, and feature usage. This data is used solely to improve the Platform.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These are only placed with your consent.

7.3 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the ezph Platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the Platform.

8. Data Sharing & Disclosure

ezph 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:

8.1 Service Providers

We engage trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, Maya, and partner banks), identity verification providers, cloud hosting providers, customer support platforms, and analytics services. All service providers are bound by contractual obligations to process your data only on our instructions and in accordance with applicable data protection laws.

8.2 Regulatory and Law Enforcement Authorities

ezph may be required to disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts of competent jurisdiction where required by law, court order, or regulatory directive. Such disclosures are made only to the extent required and in compliance with applicable legal procedures.

8.3 Fraud Prevention and Security

We may share data with fraud prevention agencies, identity verification bureaus, and industry bodies for the purpose of detecting and preventing fraud, money laundering, and other illegal activity. This sharing is conducted on the basis of our legitimate interests and legal obligations.

8.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of ezph's business, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and any material changes to this Privacy Policy that may result from it.

9. International Data Transfers

The ezph Platform is operated primarily within the Philippines. However, some of our service providers and technology partners may be located in other countries. Where personal data is transferred outside the Philippines, ezph ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012.

Such safeguards may include contractual clauses approved by the National Privacy Commission, adequacy decisions, or other legally recognised transfer mechanisms. By using the ezph Platform, you acknowledge that your data may be transferred to and processed in countries outside the Philippines in accordance with this policy.

10. Data Retention

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

As a general guide, the following retention periods apply:

• Account data: Retained for the duration of your Account and for a period of five (5) years following Account closure, in accordance with AML and regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations.
• Identity verification documents: Retained for five (5) years following Account closure or the completion of the relevant verification process.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Marketing preferences and consent records: Retained for the duration of your Account and for one (1) year following Account closure.
• Technical and usage data: Retained in aggregated or anonymised form for analytical purposes; identifiable technical data is retained for up to twelve (12) months.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

11. Your Data Rights

Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights in respect of your personal data held by ezph:

11.1 Right to Access

You have the right to request a copy of the personal data that ezph holds about you, together with information about how it is being used. We will respond to access requests within thirty (30) days of receipt.

11.2 Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update certain Account details directly through your Account settings, or contact our support team for assistance.

11.3 Right to Erasure

You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where the data has been unlawfully processed. Please note that we may be required to retain certain data to comply with legal obligations, even following a deletion request.

11.4 Right to Object and Restrict Processing

You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also request that we restrict the processing of your data in certain circumstances, such as while a rectification request is being assessed.

11.5 Right to Data Portability

Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.

11.6 How to Exercise Your Rights

To exercise any of the rights described above, please contact our Data Protection Officer using the details in Section 15. We may need to verify your identity before processing your request. We will respond to all valid requests within thirty (30) days. If your request is complex or numerous, we may extend this period by a further thirty (30) days, and we will notify you accordingly.

12. Security Measures

ezph takes the security of your personal data seriously and has implemented a range of technical and organisational measures to protect it against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data stored at rest on our servers;
• Multi-factor authentication options for 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;
• Incident response procedures for detecting, reporting, and managing personal data breaches;
• Staff training on data protection obligations and security best practices.

While ezph takes all reasonable steps to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of data transmitted to or from the Platform. You are responsible for keeping your Account login credentials confidential and for notifying us immediately if you suspect any unauthorised access to your Account.

13. Children's Privacy

The ezph Platform is strictly intended for individuals who are at least twenty-one (21) years of age. We do not knowingly collect personal data from persons under the age of 21. If we become aware that we have inadvertently collected personal data from an individual under 21, we will take immediate steps to delete that data and close the associated Account.

If you are a parent or guardian and believe that your child has provided personal data to ezph, please contact us immediately using the details in Section 15 so that we can take appropriate action.

14. Changes to This Privacy Policy

ezph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or the features of the Platform. When we make material changes to this policy, we will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect.

The date at the top of this Privacy Policy indicates when it was last updated. We encourage you to review this policy periodically to stay informed about how ezph protects your personal data. Your continued use of the Platform following notification of any changes constitutes your acceptance of the updated Privacy Policy.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way ezph handles your personal data, please contact our Data Protection Officer:

Please note that email addresses above are displayed as plain text for informational purposes. For the fastest response to privacy-related queries, we recommend using the live chat feature available on the Platform. We aim to respond to all privacy-related enquiries within five (5) business days.