eswin Privacy Policy

1 Introduction

1.1 eswin is committed to protecting the privacy and personal data of all players and visitors who use our Platform. We understand that trust is the foundation of any good relationship — and that's especially true when real money and personal information are involved.

1.2 This Policy applies to all personal information collected through the eswin Platform, including information collected during account registration, identity verification, deposits and withdrawals, gameplay, customer support interactions, and marketing communications.

1.3 eswin's data practices are governed by the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its implementing rules and regulations. We are committed to full compliance with these requirements and to upholding the rights of Filipino data subjects.

1.4 This Policy should be read alongside our Terms & Conditions, which govern your use of the eswin Platform.

2 Data We Collect

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

2.2 Sensitive Personal Information. In the course of KYC verification, eswin may collect sensitive personal information as defined under the Data Privacy Act, including government ID numbers and financial account details. Such information is handled with the highest level of care and is subject to additional security controls.

2.3 Automatically Collected Data. When you access the eswin Platform, certain technical data is automatically collected by our servers and analytics systems. This includes your IP address, device identifiers, browser type and version, operating system, referring URLs, and pages visited. This data is used for security monitoring, fraud prevention, and Platform improvement.

3 How We Use Your Data

3.1 eswin uses your personal information for the following purposes:

• Account Management: To create, maintain, and manage your eswin account, including processing your registration and verifying your identity;
• Service Delivery: To provide you with access to games, process deposits and withdrawals, and deliver customer support;
• Regulatory Compliance: To comply with our legal and regulatory obligations, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and age verification requirements;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other illegal or prohibited conduct on the Platform;
• Responsible Gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, and to enforce self-exclusion requests;
• Communications: To send you transactional communications (e.g., deposit confirmations, withdrawal notifications, account alerts) and, where you have opted in, promotional communications about eswin offers and promotions;
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the eswin Platform;
• Legal Claims: To establish, exercise, or defend legal claims in connection with the eswin Platform.

3.2 eswin will not use your personal information for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by applicable law.

4 Legal Basis for Processing

4.1 eswin processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our contract with you — i.e., to provide the eswin gaming services you have registered for;
• Legal Obligation: Processing is necessary to comply with our legal and regulatory obligations, including AML, KYC, and responsible gaming requirements;
• Legitimate Interests: Processing is necessary for our legitimate interests, such as fraud prevention, Platform security, and improving our services, provided these interests are not overridden by your rights and interests;
• Consent: Where we rely on your consent (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Data Sharing

5.1 eswin does not sell, rent, or trade your personal information to third parties for their own commercial purposes. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and AML service providers who assist us in verifying player identities and screening for financial crime risks;
• Game Software Providers: Licensed game developers and content providers whose games are available on the eswin Platform, to the extent necessary to deliver gameplay;
• IT and Cloud Service Providers: Providers of hosting, data storage, security, and analytics services who process data on our behalf under strict data processing agreements;
• Regulatory Authorities: Government agencies, law enforcement bodies, and regulatory authorities in the Philippines, where we are required by law to disclose information;
• Legal and Professional Advisers: Lawyers, auditors, and other professional advisers where necessary for legal compliance or the defence of legal claims.

5.2 All third parties with whom eswin shares personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

5.3 International Transfers. Some of our service providers may be located outside the Philippines. Where personal data is transferred internationally, eswin ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012.

6 Cookies & Tracking Technologies

6.1 eswin uses cookies and similar tracking technologies (such as web beacons and pixel tags) on the Platform. Cookies are small text files placed on your device that help us recognise you, remember your preferences, and improve your experience.

6.2 We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled as they are required for security, session management, and core functionality;
• Performance & Analytics Cookies: Help us understand how players use the Platform, which pages are most visited, and where errors occur. This data is aggregated and anonymised;
• Functional Cookies: Remember your preferences (e.g., language settings, display preferences) to personalise your experience;
• Marketing Cookies: Used to deliver relevant promotions and measure the effectiveness of our marketing campaigns. These are only set with your consent.

6.3 You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the eswin Platform. Strictly necessary cookies cannot be disabled without impacting your ability to use the Platform.

7 Data Retention

7.1 eswin retains your personal data 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.

7.2 As a general rule, eswin retains account and transaction data for a minimum of five (5) years following account closure, in accordance with applicable AML regulations and the requirements of Philippine financial regulators.

7.3 Gaming activity data and responsible gaming records may be retained for longer periods where required by regulatory obligations or where necessary to enforce self-exclusion arrangements.

7.4 When personal data is no longer required, eswin will securely delete or anonymise it in accordance with our data retention and disposal procedures.

8 Data Security

8.1 eswin implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the eswin Platform;
• Encryption of sensitive data at rest, including financial information and government ID data;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Multi-factor authentication for administrative access to systems containing personal data;
• Staff training on data protection obligations and security best practices.

8.2 While eswin takes all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for keeping your eswin login credentials confidential and for notifying us immediately if you suspect any unauthorised access to your account.

8.3 Data Breach Notification. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, eswin will notify the National Privacy Commission (NPC) and affected individuals in accordance with the requirements of the Data Privacy Act of 2012 and its implementing rules.

9 Your Rights

9.1 Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by eswin:

• Right to be Informed: The right to be informed about how your personal data is collected and processed — which this Policy fulfils;
• Right of Access: The right to request a copy of the personal data eswin 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, 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 on grounds relating to your particular situation;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller where technically feasible;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

9.2 To exercise any of these rights, please contact our Data Protection Officer via live chat support or by emailing [email protected]. We will respond to all verified requests within thirty (30) days, or within such other timeframe as required by applicable law.

9.3 We may need to verify your identity before processing your request. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

10 Children's Privacy

10.1 The eswin Platform is strictly intended for adults aged 21 years and older. eswin does not knowingly collect personal data from individuals under the age of 21.

10.2 If we become aware that we have inadvertently collected personal data from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any deposits made by an underage player will be returned.

10.3 If you are a parent or guardian and believe that your child has provided personal information to eswin, please contact our support team immediately via live chat so that we can take appropriate action.

11 Policy Updates

11.1 eswin reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you by email or through a prominent notice on the Platform.

11.2 Your continued use of the eswin Platform after any changes to this Policy constitutes your acceptance of the updated Policy. We encourage you to review this page periodically to stay informed about how we protect your information.

11.3 If you disagree with any changes to this Policy, you should stop using the Platform and may request closure of your account by contacting our support team.

12 Contact Us

12.1 If you have any questions, concerns, or requests regarding this Privacy Policy or eswin's data practices, please contact our Data Protection Officer:

12.2 Email: [email protected]

12.3 Live Chat: Available 24/7 directly on the eswin Platform.

12.4 You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have not been respected. For more information, visit the NPC's official channels.