ezeph Privacy Policy

1. Introduction

ezeph ("we," "us," or "our") is committed to protecting the privacy and personal data of all users of the ezeph online gaming platform, accessible at ezeph.com and any associated mobile or web applications (collectively, the "Platform"). This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information in connection with your use of the Platform.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). By registering an account or using the ezeph Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference.

2. Personal Data We Collect

ezeph collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Identity & Registration Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify the 21+ age requirement);
• Gender;
• Nationality and country of residence;
• Username and account credentials (passwords are stored in hashed form only).

2.2 Contact Data

• Email address;
• Mobile phone number;
• Residential address (city, province, postal code).

2.3 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID);
• Selfie or live photo for facial verification purposes;
• Proof of address documents where required.

2.4 Financial Data

• GCash or PayMaya account reference numbers;
• Bank account details (BPI, BDO, Metrobank) used for withdrawals;
• Transaction history, including deposit amounts, withdrawal amounts, and dates;
• Source of funds documentation where required by anti-money laundering regulations.

2.5 Gaming & Behavioural Data

• Game history, bet records, and wagering activity;
• Session duration, login times, and frequency of play;
• Bonus usage and promotional participation records;
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status).

2.6 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Cookies and similar tracking technologies (see Section 7);
• Platform access logs and error reports.

2.7 Communications Data

• Records of your communications with ezeph customer support;
• Feedback, survey responses, and complaint records.

3. How We Collect Your Data

ezeph collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions;
• Automatically — through cookies, web beacons, and server logs when you access and interact with the Platform;
• From third parties — including identity verification service providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud detection services, and regulatory bodies where required by law;
• From publicly available sources — where necessary for compliance with anti-money laundering obligations or to verify information you have provided.

4. How We Use Your Personal Data

ezeph uses your personal data for the following purposes:

5. Legal Basis for Processing

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

• Consent — where you have given us clear, informed, and freely given consent to process your data for a specific purpose, such as receiving marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal;
• Contract Performance — where processing is necessary to fulfil our obligations under the Terms & Conditions you have agreed to, including providing gaming services, processing transactions, and managing your account;
• Legal Obligation — where processing is required to comply with applicable Philippine laws and regulations, including the Anti-Money Laundering Act, PAGCOR licensing requirements, and NPC data protection obligations;
• Legitimate Interest — where processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and freedoms.

6. Data Sharing & Disclosure

6.1 ezeph 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:

• Identity Verification Providers — third-party KYC and document verification services used to confirm your identity and age in compliance with regulatory requirements;
• Payment Processors — GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers necessary to process your deposits and withdrawals;
• Fraud Prevention & Security Services — providers of fraud detection, risk scoring, and cybersecurity services that help protect the integrity of the Platform;
• IT Infrastructure Providers — cloud hosting, data storage, and platform infrastructure providers who process data on our behalf under strict data processing agreements;
• Regulatory Authorities — PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies where disclosure is required by law or regulatory directive;
• Legal and Professional Advisers — lawyers, auditors, and compliance consultants bound by professional confidentiality obligations;
• Business Transfers — in the event of a merger, acquisition, or sale of all or part of ezeph's business, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

6.2 All third-party service providers who process personal data on behalf of ezeph are required to enter into data processing agreements that obligate them to handle your data securely and only for the purposes specified by ezeph.

6.3 Where personal data is transferred outside the Philippines, ezeph will ensure that appropriate safeguards are in place in accordance with NPC requirements, including contractual clauses that provide equivalent data protection standards.

7. Cookies & Tracking Technologies

7.1 ezeph uses cookies and similar tracking technologies (such as web beacons and pixel tags) to operate and improve the Platform, personalise your experience, and analyse usage patterns. The types of cookies we use include:

• Strictly Necessary Cookies — essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled;
• Performance & Analytics Cookies — used to collect aggregated, anonymised data about how players use the Platform, helping us identify areas for improvement;
• Functional Cookies — used to remember your preferences, such as language settings and responsible gaming tool configurations;
• Marketing Cookies — used to deliver relevant promotional content based on your interests and gaming activity. These are only set with your consent.

7.2 You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. Detailed cookie information is available in our Cookie Notice, accessible from the Platform's footer.

8. Data Retention

8.1 ezeph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting obligations.

8.2 The following retention periods apply as a general guide:

• Account and KYC data — retained for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering regulations;
• Transaction and financial records — retained for a minimum of five (5) years from the date of the transaction;
• Gaming history and behavioural data — retained for three (3) years following account closure, or longer where required for responsible gaming or regulatory purposes;
• Customer support communications — retained for three (3) years from the date of the last communication;
• Marketing consent records — retained for the duration of your account and for two (2) years following withdrawal of consent.

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

9. Data Security

9.1 ezeph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. 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 KYC documents and financial information;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Multi-factor authentication for internal systems and administrative access;
• Regular security audits, vulnerability assessments, and penetration testing;
• Real-time monitoring and intrusion detection systems;
• Staff training on data protection and information security obligations.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ezeph will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay where required by law.

9.3 While ezeph takes all reasonable steps to protect your data, no security system is completely impenetrable. 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.

10. Your Data Rights

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

• Right to be Informed — the right to be notified of how your personal data is being collected 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 for direct marketing purposes or where processing is based on legitimate interest;
• 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 rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days, or within the timeframe required by applicable law.

11. Children's Privacy

11.1 The ezeph Platform is strictly intended for persons who are twenty-one (21) years of age or older. We do not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the mandatory KYC process for all registered accounts.

11.2 If ezeph becomes aware that personal data has been collected from a person under 21 years of age without appropriate verification, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact us immediately at [email protected].

11.3 We encourage parents and guardians to use parental control software on shared devices to prevent minors from accessing online gambling platforms.

12. Changes to This Privacy Policy

12.1 ezeph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The date of the most recent revision will always be displayed at the top of this page.

12.2 Where changes are material, we will notify registered players via the email address associated with their account or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

12.3 Your continued use of the ezeph Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure.

13. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer: