eswin Privacy Policy

1. Introduction and Scope

eswin Operations Inc. (hereinafter "eswin," "we," "us," or "our"), a corporation duly registered under the laws of the Republic of the Philippines and operating under PAGCOR License No. 2020-XXX-XXXX-001, is committed to protecting the privacy and security of personal information provided by users ("you," "User," or "Player") of our gaming platform (the "Platform").

This Privacy Policy (the "Policy") describes our practices concerning the collection, use, disclosure, storage, and protection of personal data in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (the "DPA"), its Implementing Rules and Regulations, issuances of the National Privacy Commission (the "NPC"), and applicable PAGCOR regulations governing licensed gaming operators.

By accessing the eswin Platform, creating an account, or using any of our services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree with any provision herein, you must immediately cease using the Platform and refrain from providing any personal information to eswin.

2. Information We Collect

eswin collects various categories of personal data necessary to provide gaming services, comply with legal obligations, and enhance user experience. The types of information collected include:

2.1 Information You Provide Directly

• Registration Information: When you create an eswin account, we collect your full legal name as it appears on government-issued identification, date of birth, residential address (street address, city/municipality, province, postal code), valid email address, mobile phone number, and username/password credentials.
• Identity Verification Documents: To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements under PAGCOR regulations, we collect copies of government-issued photo identification (Philippine Passport, Driver's License, UMID, SSS ID, or Postal ID), proof of address documents (utility bills, bank statements, or government correspondence dated within the last three months), and selfie photographs for biometric verification purposes.
• Financial Information: Payment method details including GCash or PayMaya account information, bank account numbers and names for direct transfers, credit/debit card details (we store only tokenized representations; full card numbers are not retained), cryptocurrency wallet addresses for crypto deposits and withdrawals, and transaction history records.
• Communications: Records of all communications you have with eswin Customer Support through live chat, email, phone calls, or support tickets, including the content of your inquiries and our responses.
• Marketing Preferences: Your consent choices regarding promotional emails, SMS messages, push notifications, and other marketing communications.

2.2 Information Collected Automatically

• Device Information: Device type, model, and manufacturer; operating system and version; browser type and version; screen resolution and display settings; unique device identifiers (IMEI, MAC address, or advertising IDs).
• Usage Data: IP addresses and approximate geolocation; pages visited and features accessed; timestamps of login/logout events; game history including bets placed, outcomes, winnings, and losses; session duration and frequency; referral sources and campaign attribution data.
• Technical Information: Cookies and similar tracking technologies (as detailed in Section 6); log files recording system events, errors, and performance metrics.

2.3 Information from Third-Party Sources

eswin may receive information about you from third-party service providers including payment processors (transaction verification and fraud detection data), identity verification services (validation of submitted documents and biometric matching results), credit reference agencies (where applicable for credit-based products), and social media platforms (if you choose to register using social login features).

3. How We Use Your Personal Data

eswin processes your personal information for the following lawful purposes:

3.1 Account Management and Service Provision

To create and maintain your eswin account; verify your identity and age eligibility (minimum 21 years); process deposits, withdrawals, and other financial transactions; provide access to gaming services including live casino, slots, sports betting, and bingo; maintain accurate account records and transaction histories; communicate important account-related information including security alerts and policy updates.

3.2 Legal and Regulatory Compliance

To comply with PAGCOR licensing requirements and regulatory oversight obligations; fulfill KYC and AML obligations under Philippine anti-money laundering laws (RA 9160 as amended by RA 10365 and RA 10927); detect and prevent fraud, money laundering, identity theft, and other illegal activities; respond to legal process including court orders, subpoenas, and lawful requests from government authorities; maintain records required by law for specified retention periods; report suspicious transactions to the Anti-Money Laundering Council (AMLC) when required.

3.3 Security and Risk Management

To monitor for unauthorized access attempts and account takeovers; detect unusual betting patterns indicative of fraud or match-fixing; implement responsible gaming measures including deposit limits and self-exclusion protocols; protect the integrity of games and prevent cheating or collusion; investigate disputes and resolve complaints.

3.4 Marketing and Personalization

Subject to your consent where required by law, we may use your information to send promotional offers, bonuses, and loyalty rewards; personalize game recommendations based on play history; conduct market research and customer satisfaction surveys; improve Platform functionality and user experience through analytics.

3.5 Business Operations

To analyze Platform performance and identify technical issues; conduct data analytics to improve services and develop new features; manage customer support inquiries and maintain quality standards; enforce our Terms & Conditions and prevent policy violations.

4. Data Sharing and Disclosure

eswin does not sell, rent, or trade your personal information to third parties for their independent marketing purposes. We may share your data only in the following limited circumstances:

4.1 Service Providers and Business Partners

We engage trusted third-party service providers to perform functions on our behalf, including payment processors (GCash, PayMaya, bank partners, cryptocurrency exchanges), identity verification services (biometric authentication, document validation), cloud hosting providers (data storage and server infrastructure), customer support platforms (helpdesk software, live chat systems), analytics and performance monitoring tools, and marketing service providers (email platforms, SMS gateways).

All service providers are contractually obligated to maintain the confidentiality and security of your personal data, use it only for the specified purposes, and comply with applicable data protection laws. eswin conducts due diligence to ensure service providers implement appropriate technical and organizational security measures.

4.2 Regulatory Authorities

We disclose personal information to PAGCOR and other regulatory bodies as required by gaming regulations, to the National Privacy Commission upon lawful request or during privacy audits, to the Anti-Money Laundering Council for suspicious transaction reports and compliance purposes, and to law enforcement agencies in response to valid legal process (search warrants, court orders, subpoenas) or to protect public safety.

4.3 Business Transfers

In the event of a merger, acquisition, corporate reorganization, sale of assets, or bankruptcy proceeding, your personal information may be transferred to the successor entity. We will notify affected users via email and prominent Platform notice before such transfer occurs, providing an opportunity to exercise data subject rights prior to the transition.

4.4 Legal Obligations and Rights Protection

eswin may disclose your information when we believe in good faith that such disclosure is necessary to comply with applicable law or respond to legal process, enforce our Terms & Conditions or investigate potential violations, detect, prevent, or address fraud, security issues, or technical problems, or protect the rights, property, or safety of eswin, our users, or the public as required by law.

5. Data Security Measures

eswin implements comprehensive technical, administrative, and physical security measures to protect personal data against unauthorized access, alteration, disclosure, or destruction:

5.1 Technical Safeguards

• Encryption: All data transmitted between your device and eswin servers is encrypted using Transport Layer Security (TLS) 1.2 or higher. Sensitive personal information stored in our databases is encrypted at rest using AES-256 encryption standards.
• Access Controls: Role-based access controls (RBAC) ensure employees access only data necessary for their job functions. Multi-factor authentication is required for administrative access to systems containing personal data.
• Network Security: Firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) protect against unauthorized network access. Regular vulnerability assessments and penetration testing identify and remediate security weaknesses.
• Secure Development: Security-by-design principles are integrated into our software development lifecycle. Code reviews and security testing are conducted before deploying new features.

5.2 Administrative Safeguards

• Employees receive mandatory data privacy and security training upon hiring and annually thereafter.
• Confidentiality agreements require all personnel to protect user information.
• Data breach response procedures enable rapid detection, containment, and notification of security incidents.
• Regular audits verify compliance with internal policies and regulatory requirements.

5.3 Physical Safeguards

Our data centers employ 24/7 security monitoring, biometric access controls, environmental controls (temperature, humidity, fire suppression), and redundant power and network connectivity to prevent data loss.

6. Cookies and Tracking Technologies

6.1 Types of Cookies Used

eswin uses cookies and similar technologies (web beacons, pixels, local storage) to enhance user experience and analyze Platform performance:

• Essential Cookies: Required for basic Platform functionality including user authentication, session management, and security features. These cannot be disabled without impairing core services.
• Performance Cookies: Collect anonymous data about how users interact with the Platform, helping us identify popular features, diagnose technical issues, and optimize performance.
• Functional Cookies: Remember user preferences such as language selection, display settings, and previously viewed content to personalize your experience.
• Marketing Cookies: Track your activity across websites to deliver targeted advertisements and measure campaign effectiveness. Used only with your explicit consent.

6.2 Managing Cookie Preferences

You may manage cookie preferences through your account settings or browser controls. Most browsers allow you to refuse cookies or delete existing cookies. Please note that disabling essential cookies may impair Platform functionality, and disabling performance cookies may reduce our ability to improve services.

6.3 Third-Party Analytics

eswin uses third-party analytics services (such as Google Analytics) to understand user behavior and improve the Platform. These services may collect information about your use of eswin and other websites. You may opt out of Google Analytics by installing the Google Analytics Opt-Out Browser Add-on.

7. Your Data Subject Rights

Under the Philippine Data Privacy Act, you have the following rights regarding your personal information:

7.1 Right to Access

You may request confirmation of whether eswin processes your personal data and obtain a copy of such data. Access requests can be submitted through your account settings or by contacting our Data Protection Officer at [email protected]. We will respond within fifteen (15) calendar days of receiving a valid request.

7.2 Right to Correction

If you believe personal information we hold about you is inaccurate, incomplete, or outdated, you may request correction. Most account information can be updated directly through account settings. For corrections requiring identity verification (such as name or date of birth changes), contact Customer Support with supporting documentation.

7.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data under certain circumstances, including when the data is no longer necessary for the purposes for which it was collected, when you withdraw consent (where processing was based on consent), or when the data has been unlawfully processed. Note that eswin may retain certain information where required by law (e.g., transaction records for AML compliance) or to establish, exercise, or defend legal claims.

7.4 Right to Object

You may object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests by demonstrating compelling grounds relating to your particular situation. We will cease such processing unless we can demonstrate overriding legitimate grounds.

7.5 Right to Data Portability

You have the right to receive personal data you provided to eswin in a structured, commonly used, and machine-readable format and to transmit that data to another controller where technically feasible. Data portability requests may be submitted to our Data Protection Officer.

7.6 Right to File a Complaint

If you believe eswin has violated your data privacy rights, you may file a complaint with the National Privacy Commission of the Philippines. Contact information: National Privacy Commission, 5th Floor, Philippine International Convention Center (PICC), CCP Complex, Roxas Boulevard, Pasay City 1308, Philippines. Email: [email protected]. Website: privacy.gov.ph.

8. Data Retention Periods

eswin retains personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements. Specific retention periods include:

• Account Information: Retained for the duration of your active account and for five (5) years following account closure to comply with PAGCOR record-keeping requirements and potential dispute resolution needs.
• Transaction Records: Financial transaction data is retained for five (5) years following the transaction date as required by anti-money laundering regulations (RA 10927) and tax laws.
• Identity Verification Documents: Copies of government-issued IDs and proof of address documents are retained for five (5) years following account closure to comply with KYC record-keeping obligations.
• Marketing Communications: Records of marketing consents and preferences are retained until you withdraw consent or close your account, plus an additional six (6) months to process any pending communications.
• Customer Support Records: Support tickets, chat transcripts, and email correspondence are retained for three (3) years to maintain quality standards and resolve potential disputes.
• Technical Logs: Server logs and security audit trails are retained for ninety (90) days unless specific events require longer retention for investigation purposes.

Following expiration of applicable retention periods, personal data is securely deleted or anonymized such that it can no longer be associated with an identifiable individual.

9. Protection of Minors' Privacy

The eswin Platform is strictly prohibited for use by individuals under twenty-one (21) years of age. We do not knowingly collect personal information from minors. Our age verification procedures are designed to prevent underage registration and access to gaming services.

If we discover that a minor has provided personal information or created an account, we will immediately suspend the account, void all transactions and winnings, refund any deposited funds to the payment source, and permanently delete all associated personal data. Parents or guardians who believe their child has accessed the Platform should contact us immediately at [email protected].

Parents are encouraged to use parental control software and monitor their children's internet usage to prevent access to gambling websites. Resources for parental controls are available through most internet service providers and device manufacturers.

10. Changes to This Privacy Policy

eswin reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform functionality. Material changes will be communicated through prominent notice on the Platform homepage, email notification to your registered email address thirty (30) days prior to the effective date of changes, and in-app notification when you next log into your account.

The date of the most recent revision is displayed at the beginning of this Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of the Platform following notice of changes constitutes acceptance of the modified Privacy Policy.

If you do not agree with changes to this Privacy Policy, you must cease using the Platform and may request account closure with deletion of your personal data, subject to our legal retention obligations.

11. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact: