Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by ezeph ("ezeph," "we," "us," or "our") and applies to all personal data collected from users ("Players," "you," or "your") who access or use the ezeph online gaming platform at ezeph.app and all associated services (the "Platform").

ezeph is committed to protecting the privacy and personal data of every Filipino player who uses the Platform. We operate in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

By registering on the ezeph Platform or otherwise providing us with your personal data, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein.

2. Personal Data We Collect

ezeph collects personal data in the following categories:

• Registration Data: Full legal name, date of birth, Philippine mobile number, email address, and a self-selected password (stored in hashed form — never in plain text).
• Identity Verification Data (KYC): Government-issued identification document (e.g., Philippine passport, SSS ID, UMID, driver's license), selfie or liveness verification image, and proof of address where required by regulatory obligations.
• Financial Data: GCash number, Maya / PayMaya account details, bank account number, transaction history, deposit amounts, withdrawal amounts, and bonus redemption records. Note: ezeph does not store full payment card numbers.
• Gaming Activity Data: Bet history, game session logs, win/loss records, responsible gaming settings (deposit limits, exclusions), and in-platform communications.
• Device and Technical Data: IP address, browser type and version, operating system, device identifiers, session duration, and referring URL. This data is collected automatically when you access the Platform.
• Communications Data: Records of your correspondence with ezeph support via live chat or email, including the content of messages and timestamps.

ezeph does not knowingly collect personal data from individuals under 21 years of age. If we become aware that data has been collected from a minor, we will delete it immediately and close the associated account.

3. How We Collect Personal 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 support, or update your profile settings.
• Automatically: When you access the Platform, our servers, analytics systems, and cookies automatically record technical and usage data as described in Section 7.
• From third parties: Identity verification may be conducted in part through third-party KYC providers who cross-reference your submitted documents against official Philippine government databases. Payment processors (e.g., GCash, Maya) may share transaction confirmation data with ezeph to reconcile your account balance.

4. Purposes of Processing

ezeph processes your personal data for the following lawful purposes:

• To create, maintain, and manage your ezeph account and associated player profile.
• To verify your identity and age in compliance with PAGCOR licensing requirements and the Anti-Money Laundering Act (AMLA) of the Philippines.
• To process deposits, withdrawals, and bonus credits to and from your account in Philippine Peso (PHP).
• To provide customer support and respond to inquiries, complaints, or disputes submitted via live chat or email.
• To detect and prevent fraud, money laundering, account takeover, and other prohibited activities.
• To comply with applicable Philippine laws and regulations, including but not limited to the DPA, AMLA, and PAGCOR operating conditions.
• To operate responsible gaming tools such as deposit limits, session controls, and self-exclusion, and to monitor gaming patterns that may indicate problem gambling.
• To communicate service notices, account alerts, and material updates to these policies (transactional communications only — not marketing without separate consent).
• To improve the Platform through anonymized analytics and aggregate usage data.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform the agreement between you and ezeph when you register an account and use the Platform (e.g., account management, payment processing).
• Legal obligation: Processing required to comply with Philippine laws, including PAGCOR regulations, AMLA, and NPC guidelines (e.g., KYC, transaction reporting).
• Legitimate interests: Processing necessary for fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights.
• Consent: Where required by law or where processing goes beyond contractual or statutory necessity (e.g., optional marketing communications), ezeph will seek your explicit consent, which you may withdraw at any time.

6. Data Sharing and Disclosure

ezeph does not sell, rent, or trade your personal data to any third party. We may share your data in the following limited circumstances:

• Service providers: Third-party KYC verification providers, payment processors (GCash, Maya, BPI, BDO, and others), IT infrastructure providers, and fraud detection services engaged to support the operation of the Platform. All such providers are bound by data processing agreements requiring them to protect your data in accordance with the DPA.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies where disclosure is required by law, regulation, or court order.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all assets of ezeph, player data may be transferred to the acquiring entity, subject to equivalent privacy protections.
• With your consent: In any other circumstance where you have given explicit written consent to the disclosure.

7. Cookies and Tracking Technologies

The ezeph Platform uses cookies — small text files stored on your device — and similar technologies including local storage and session tokens. These are used for the following purposes:

• Strictly necessary cookies: Required for the Platform to function, including session authentication and security tokens. These cannot be disabled without impairing Platform functionality.
• Functional cookies: Remember your language preferences, game display settings, and responsible gaming configurations.
• Analytics cookies: Collect anonymized and aggregated data on how players navigate the Platform to help us identify usability issues and improve the user experience. No individual player is identified in analytics reporting.

ezeph does not use third-party advertising or behavioral tracking cookies. You may manage cookie settings through your browser; however, disabling strictly necessary cookies will prevent you from logging in to your ezeph account.

8. Data Retention

ezeph retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law:

• Active account data is retained for the duration of your account's existence on the Platform.
• Following account closure, personal data and transaction records are retained for a minimum of five (5) years in compliance with PAGCOR record-keeping requirements and AMLA obligations.
• KYC documents are retained for the period required by the AMLC and NPC guidelines applicable to online gaming operators.
• Support communications are retained for three (3) years from the date of the last interaction, unless a longer period is required for a pending dispute or legal matter.

After the applicable retention period expires, personal data is securely deleted or anonymized so that it can no longer be attributed to any individual.

9. 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 know what personal data ezeph collects, and the purpose and basis of processing — as set out in this Policy.
• Right of access: The right to request a copy of the personal data ezeph 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 where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to restriction: The right to request that processing of your personal data be temporarily suspended in certain circumstances.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to object: The right to object to processing of your personal data based on legitimate interests.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph) if you believe your data rights have been violated.

To exercise any of the above rights, please contact ezeph's Data Protection Officer (DPO) at [email protected]. ezeph will respond to all verified data rights requests within thirty (30) days in accordance with NPC guidelines.

10. Data Security

ezeph implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, destruction, or accidental loss. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ezeph Platform.
• Encryption of sensitive data fields at rest within the ezeph database infrastructure.
• Strict access controls limiting personal data access to authorized personnel with a legitimate business need.
• Regular security audits and vulnerability assessments of the Platform and supporting infrastructure.
• Incident response procedures compliant with NPC breach notification requirements.

In the event of a personal data breach that poses a risk to your rights and freedoms, ezeph will notify the National Privacy Commission and affected players within the timeframes prescribed by the DPA and its IRR.

11. Cross-Border Data Transfers

Where personal data is transferred outside the Philippines — for example, to cloud infrastructure providers or international KYC services — ezeph ensures that appropriate safeguards are in place to protect your data in accordance with NPC guidelines. Such transfers are made only where necessary and are governed by contractual protections that require the recipient to apply data protection standards equivalent to those mandated by the Philippine DPA.

12. Children's Privacy

The ezeph Platform is strictly for individuals who are 21 years of age or older, as required by PAGCOR regulations. ezeph does not knowingly collect or process personal data from persons under the age of 21. If you believe that a minor has registered on the Platform or provided personal data to ezeph, please contact us immediately at [email protected] and we will take prompt action to close the account and delete the associated data.

13. Changes to This Policy

ezeph may update this Privacy Policy from time to time to reflect changes in our data practices, the Platform, or applicable Philippine law. When material changes are made, we will notify registered players via the email address on file or through a prominent notice on the Platform prior to the changes taking effect.

Your continued use of the ezeph Platform following the effective date of any revised Privacy Policy constitutes your acknowledgment and acceptance of the updated terms. The date of the most recent revision is displayed at the top of this page.

14. Contact — Data Protection Officer

For any privacy-related questions, data rights requests, or concerns about how ezeph handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: 8AM – 2AM PHT daily, via the ezeph Platform

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data rights under the DPA have not been upheld by ezeph.