ey447 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how ey447 ("we," "us," "our," or "the Platform") collects, uses, stores, shares, and protects the personal data of users ("you," "your," or "Player") who access or use the ey447 website at ey447.com, its mobile application, and all associated services.

ey447 is committed to protecting the privacy and personal data of all Players, particularly those based in the Philippines. This Policy is designed to comply with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

By registering an Account on ey447 or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform immediately.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, ey447 is the data controller responsible for the personal data collected through the Platform. As data controller, ey447 determines the purposes and means of processing your personal data.

ey447 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection laws. If you have any questions or concerns regarding the processing of your personal data, you may contact the DPO directly at the contact details provided in Section 16 of this Policy.

3 Personal Data We Collect

ey447 collects the following categories of personal data from Players:

4 How We Collect Your Data

ey447 collects personal data through the following means:

• Direct Collection: Data you provide when registering an Account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and similar tracking technologies. See Section 10 for more details on cookies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors.
• Publicly Available Sources: In limited circumstances, ey447 may supplement your data with information from publicly available sources for fraud prevention or regulatory compliance purposes.

ey447 does not collect personal data from individuals who have not registered an Account, except for technical data collected automatically from all visitors to the Platform for security and analytics purposes.

5 How We Use Your Personal Data

ey447 uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your ey447 Account, including verifying your identity and age (21+ requirement), processing login requests, and managing Account settings.
• Service Delivery: To provide access to Games, process deposits and withdrawals, credit bonuses, and deliver all features of the Platform.
• KYC and Regulatory Compliance: To verify your identity and age in compliance with PAGCOR regulations and applicable Philippine law, and to fulfill anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized Account access, money laundering, and other illegal or prohibited conduct on the Platform.
• Responsible Gaming: To monitor gaming behavior for signs of problem gambling, enforce deposit limits and self-exclusion requests, and fulfill our responsible gaming obligations.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing and Promotions: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where we have a legitimate interest in doing so. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the Platform.
• Legal Obligations: To comply with applicable laws, regulations, court orders, and requests from regulatory authorities including PAGCOR and the NPC.

6 Legal Basis for Processing

ey447 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions, including Account management, service delivery, and payment processing.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC verification, AML/CTF compliance, and PAGCOR regulatory requirements.
• Legitimate Interests: Processing necessary for ey447's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing and Disclosure

ey447 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• KYC and Identity Verification Providers: Third-party identity verification services used to confirm your identity and age in compliance with regulatory requirements.
• AML and Fraud Prevention Partners: Compliance technology providers used to screen transactions and detect suspicious activity.
• Game Content Providers: Licensed game studios and software providers whose games are available on the Platform, to the extent necessary to deliver game services.
• IT and Cloud Service Providers: Hosting, infrastructure, and security service providers who process data on our behalf under strict data processing agreements.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, law enforcement agencies, and other government bodies, where disclosure is required by law or court order.
• Professional Advisors: Legal counsel, auditors, and other professional advisors, subject to professional confidentiality obligations.

All third parties with whom ey447 shares personal data are required to process that data in accordance with applicable data protection laws and ey447's data protection standards. ey447 does not permit third-party service providers to use your personal data for their own purposes beyond the scope of the services they provide to ey447.

8 International Data Transfers

Some of ey447's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, ey447 ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012 and NPC guidelines.

Such safeguards may include data processing agreements incorporating standard contractual clauses approved by the NPC, or transfers to countries that have been determined to provide an adequate level of data protection. ey447 will not transfer your personal data to a jurisdiction that does not provide adequate protections without your explicit consent or a lawful basis for doing so.

If you would like more information about the specific safeguards applied to international transfers of your personal data, please contact our Data Protection Officer at the details provided in Section 16.

9 Data Retention

ey447 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, in compliance with PAGCOR record-keeping requirements and AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML law.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory authority.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing Data: Retained until you withdraw consent or opt out of marketing communications, after which it will be deleted or anonymized within thirty (30) days.
• Technical and Usage Data: Retained for up to twenty-four (24) months for analytics and security purposes, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, ey447 will securely delete or anonymize your personal data in a manner that prevents reconstruction or identification.

10 Cookies & Tracking Technologies

ey447 uses cookies and similar tracking technologies to enhance your experience on the Platform, ensure security, and gather analytics data. A cookie is a small text file placed on your device when you visit the Platform.

ey447 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting Platform functionality.
• Performance and Analytics Cookies: Used to collect anonymized data about how Players use the Platform, including pages visited, session duration, and error reports. This data helps us improve Platform performance.
• Functional Cookies: Used to remember your preferences, such as language settings, display preferences, and responsible gaming tool configurations.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of marketing campaigns. These are only placed with your consent.

You may manage your cookie preferences through your browser settings or through the cookie consent tool available on the Platform. Please note that disabling certain cookies may affect the functionality of the Platform.

11 Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ey447. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 16.

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and shared — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data ey447 holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by ey447.
• 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 ey447's 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 interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

ey447 will respond to all data rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case you will be notified of the extension and the reasons for it.

12 Children's Privacy

The ey447 Platform is strictly intended for adults aged 21 years and above. ey447 does not knowingly collect, process, or store personal data from individuals under the age of 21. The minimum legal age for casino-style gambling in the Philippines is 21 years, as prescribed under PAGCOR regulations.

ey447 employs mandatory KYC verification to confirm the age of all registered Players. If ey447 discovers that personal data has been collected from a person under the age of 21, the relevant Account will be immediately suspended, all funds will be returned to the depositing payment method, and all personal data associated with the Account will be securely deleted.

If you are a parent or guardian and believe that your child has registered an Account on ey447, please contact us immediately at the details provided in Section 16 so that we can take prompt action.

13 Security Measures

ey447 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the ey447 Platform is protected by 256-bit SSL/TLS encryption. Sensitive data at rest, including financial data and KYC documents, is encrypted using industry-standard algorithms.
• Access Controls: Access to personal data is restricted to authorized ey447 personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Two-Factor Authentication: ey447 supports and encourages the use of two-factor authentication (2FA) for all Player Accounts to prevent unauthorized access.
• Penetration Testing: ey447 conducts regular security assessments and penetration tests to identify and remediate vulnerabilities in the Platform.
• Incident Response: ey447 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, ey447 will notify the NPC and affected Players within seventy-two (72) hours of becoming aware of the breach, as required by the Data Privacy Act of 2012.
• Staff Training: All ey447 personnel who handle personal data receive regular data protection training and are bound by confidentiality obligations.

14 Third-Party Links

The ey447 Platform may contain links to third-party websites or services, including payment provider portals and game studio interfaces. This Privacy Policy applies solely to the ey447 Platform and does not govern the data practices of any third-party websites or services.

ey447 is not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party services you access through or in connection with the ey447 Platform before providing any personal data to those services.

15 Updates to This Policy

ey447 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The most current version of this Policy will always be available on the Platform, identified by the effective date at the top of the document.

Where changes to this Policy are material — meaning they significantly affect your rights or how we process your personal data — ey447 will provide advance notice to registered Players via the email address on file or through a prominent notice on the Platform, at least fourteen (14) days before the changes take effect.

Your continued use of the Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you should cease using the Platform and may request Account closure by contacting our support team.

16 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by ey447, please contact our Data Protection Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available within the Platform 24 hours a day, 7 days a week after logging in to your Account.
• Response Time: ey447 aims to acknowledge all privacy-related inquiries within 48 hours and to provide a substantive response within 30 calendar days.