Eplayment Privacy Notice

Eplayment Corporation is a financial technologies and entertainment company creating a digital space for people to conveniently and securely engage with others, and experience the fullest potential of fintech, gaming, and entertainment combined. Our Eplayment Wallet and PIXEL is a digital wallet application currently available in the Philippines that holds money and enables financial transactions. The Eplayment Wallet aims to be known and utilized as the go-to wallet for gaming and entertainment that follows our company values: Fun, Secure, Convenient, Excellent, and Adaptable.

Eplayment Corporation respects your right to privacy and is fully committed to observing the general data privacy principles of transparency, legitimate purpose and proportionality. That being said, we ensure that we comply with the Data Privacy Act of 2012 (RA 10173), along with its Implementing Rules and Regulations as well as any other relevant data privacy related laws and issuances by the National Privacy Commission.

This Privacy Notice outlines our data privacy principles and practices. This will cover any and all necessary information about what data and information we collect and your data privacy rights relating to the collection, processing, usage, storage, protection, retention, and deletion of your personal data and information.

CONSENT

By using the Eplayment Wallet and PIXEL and providing us your Personal Data, you will be treated as having given your permission for the collection, use, and processing of your Personal Data, and accepted the policies and practices described in this Privacy Notice.

If you do not allow the collection, use, and processing of your Personal Data, kindly do not use our platform or contact us.

DEFINITION OF TERMS

1. Personal Information refers to any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual;
2. Data Subject / User refers to an individual whose Personal, Sensitive or Privileged information is processed;
3. Consent of the Data Subject refers to any freely given, specific, informed indication of will, whereby the Data Subject agrees to the processing of his or her personal, sensitive personal, or privileged information. It may also be given on behalf of a Data Subject by a lawful representative or an agent specifically authorized by the Data Subject to do so;
4. Outsourcing refers to the disclosure or transfer of Personal Data by the Parties to their respective Personal Information Processor/s (PIP/s), if any, for the Processing of Personal Data obtained or shared under this Agreement;
5. Processing refers to any operation or set of operations performed upon Personal Data including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure, or destruction of data. Processing may be performed through automated means, or manual processing, if the Personal Data are contained or are intended to be contained in a filing system;
6. Personal Data Breach refers to a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored, or otherwise processed. processed
7. Sensitive Personal Information refers to personal information about an individual’s, marital status, age, birthdate, sex, gender, information contained in any government issued identification documents.

WHY WE COLLECT AND WHAT WE COLLECT

For Eplayment Wallet Registration: We request the following information from our users for the purpose of setting up their Eplayment Wallet account:

1. Mobile Number
2. First and Last Name
3. Username
4. Password
5. Mobile Personal Identification Number

For Eplayment Wallet Verification: Upon registering your account, we shall request further personal information and sensitive personal information for verification purposes, as well as for the usage of the various functions of the platform such as add money, pay bills, buy load, buy game credits and vouchers, withdraw money, and send money. Said information may include but is not limited to:

1. Your name and personal particulars such as contact details, place of residence, gender, birthdate, place of birth, civil status, nationality, and mother’s maiden name
2. Financial Information such as income source
3. Employment details and business information
4. Government ID(s) and all data and information contained therein
5. Selfie

Users may opt to not verify their accounts, but will only have limited access to the features of the application. Furthermore, users may also choose to enable biometrics (Facial Recognition or Fingerprint Recognition), on their respective device as a method of logging in to their account for ease of access. This feature is completely optional and will not be activated unless the user gives the specific permissions.

For PIXEL Registration and Content Creation: While using the PIXEL Platform we may collect various contents ranging from text (e.g. blogs, articles, short stories, responses to Q&A, etc.), videos, live streams, photos and links of other content from external social media and streaming platforms containing personal and/or sensitive information that users voluntarily generate.

For Marketing and Advertising: We may also collect your personal information to assess your preferences and activities so we can recommend new services, promotions, products, offers and/or promotional discounts of Eplayment or third-parties which we believe may suit your interest.

For Product and Market Research: Your personal data may also be used for purposes of product and market research so we can analyze trends and patterns in the market and utilize it to innovate new financial products and services.

For Customer Service: Personal information may likewise be collected by our customer support team to enable them to properly address and resolve any of your queries and concerns while using the Eplayment Wallet.

For Legal Compliance: We also collect your personal information when necessary for compliance with our legal obligations, regulatory and reportorial requirements and for other legal purposes as may be mandated by law and other law enforcement agencies.

In any instance wherein we request data for a specific reason that is not covered in this privacy policy, we will expound on the purpose of why we need said information, as well as our lawful basis for collecting it. Correspondingly, if there is any instance where we are to process your data for any purpose other than for which it was originally collected, we shall provide you with a clear explanation and description of said purpose, along with any other relevant information pertinent to the processing.

HOW WE COLLECT

Most of the personal data that we collect are provided to us through the following means:

1. Direct input of your data when creating, registering, and verifying your Eplayment Wallet and PIXEL account through our app or website;
2. Your use of our Eplayment Wallet products and services through electronic channels and/or the creation of user-generated contents on the PIXEL platform;
3. You browse or conduct transactions through our Eplayment Website;
4. Whenever you directly contact our customer support team through our Website, telephone and email;
5. Whenever you enable biometric login through facial recognition or fingerprint recognition; and
6. When you direct a third-party to conduct certain transactions with Eplayment or when there are complaints lodged or investigations conducted by law enforcement and regulatory bodies against you.

HOW WE USE YOUR DATA

We may use your personal data and PIXEL data usage for various purposes, including the following and any other future purpose not mentioned herein shall be disclosed and lawful:

• Know-Your-Customer examination/investigation or client identification-related activities as required by law
• Assessment and/or processing your applications or transactions with the Bank such as but not limited to opening of accounts, fund transfer, withdrawal, bill payments, avail load and purchase game credits and vouchers
• Responding to any customer inquiries, requests, concerns or complaints
• Management of your accounts and performing other audit, administrative and operational tasks necessary and incidental to the management of the account
• Detection, prevention, investigation, and prosecution of fraud or crime while using the Eplayment account
• Detection prevention, investigation of any violation of the Community Guidelines and/or prosecution of crimes while generating contents on the PIXEL platform
• Performance of activities that you have consented to
• Performance of other activities permitted by law

DATA SHARING / OUTSOURCING

Within the company, data will be accessible to our backend developers, admin, support, and finance teams, who will only have access to the relevant data to perform their tasks successfully for the purposes of the application. Data collected for the Know-Your-Customer procedure shall only be disclosed and shared with our partner processors, ZOLOZ and Netbank. Our technology partners will have only limited access to any pertinent data to facilitate their respective services within the application. Technology partners may not store any of the information, and no data collected by the application shall be disclosed or shared with any other third parties.

RETENTION OF USER DATA

Eplayment and Netbank shall retain data provided by the user for a period of five (5) years upon account closure. No data shall be deleted while there is still a remaining balance within the user’s wallet. Users also have the option of contacting us and requesting their data to be deleted at any given time. Once the retention period is over or if the data is no longer needed, we shall securely delete said information.

HOW WE PROTECT YOUR INFORMATION

We implement reasonable and appropriate physical, technical, and organizational measures to prevent the loss, destruction, misuse, or alteration of your information. We keep and protect your information using a secured server behind a firewall, encryption, and security controls to ensure our clients we are committed to protecting their information from personal data breaches. In line with our retention policy, Eplayment and Netbank shall securely delete the data collected upon the expiry of the aforementioned retention period or when deemed no longer necessary.

YOUR RIGHTS AS A DATA SUBJECT

As a user of our Eplayment Wallet and PIXEL, you are entitled to the following data privacy rights:

1. To be informed whether Personal Data pertaining to him or her shall be, are being, or have been processed;
2. To reasonable access to any Personal Data collected and processed in duration of employment;
3. To object or withhold consent with regards to the collection and processing of your Personal Data.
4. To suspend, withdraw, or order the blocking, removal, or destruction of Personal Data from the relevant company’s filing system;
5. To dispute the inaccuracy or error in Personal Data, and the relevant company shall correct it immediately and accordingly, upon the request unless the request is vexatious or otherwise unreasonable;
6. To obtain a copy of their data in an electronic or structured format that is commonly used and allows for further use by the Data Subject;
7. To file a complaint before the National Privacy Commission if you think your right to privacy and data protection was violated, and the right to claim damages.

CHANGES OF THIS PRIVACY NOTICE

The content of this Privacy Notice may be updated or amended from time to time to align with any future platform configurations, and to comply with any changes in relevant laws and policies. Should these changes require your consent, we will be sure to notify you and request for your said updated consent as you proceed with using the platform. Otherwise, changes will be rendered effective immediately upon posting.

CONTACT US

Eplayment is fully committed to protecting and maintaining your privacy. For any questions, concerns or clarifications regarding this privacy policy and how to exercise your rights as a data subject, you may contact our Data Protection Officer at dpo@eplayment.com. You may also get in touch with us at support@eplayment.com, or reach us at our main office at LG1 CapitolGreenstreet, Capitol Hills Drive, Matandang Balara, Quezon City 1119.