Privacy Notice for Eplayment Wallet
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 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.
As advocates of data privacy, we recognize the importance of protecting your data, and commit to safeguarding the confidentiality of all of our clients and users. 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. Furthermore, we only collect and process personal information that is necessary to fulfill the purpose of our platforms.
In accordance with this, this privacy notice will cover any and all necessary information about how Eplayment will collect, process, and store your personal data. This includes how long we will retain the information, all your privacy rights in relation to that data, and to whom we may share it with when necessary.
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.
DEFINITION OF TERMS
- 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;
- Personal Information Data Subject / User refers to an individual whose Personal, Sensitive or Privileged information is processed;
- 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;
- 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;
- 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;
- 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
WHAT WE COLLECT
In order to create an account, we request the following information from our users so that we register them properly:
- Mobile Number
- First and Last Name
- Middle Name (optional)
- Date of birth (must be 18 and above)
- Email address (optional)
- Mobile Personal Identification Number
Upon registering your account, we shall request further 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:
- Your name and personal particulars such as contact details, residence, gender, birthdate, civil status, nationality, and mother’s maiden name
- Financial Information such as income source
- Employment details and business information
- Government ID(s) and corresponding photo with the ID
PURPOSE OF COLLECTION / HOW WE USE YOUR DATA
We may use your personal data 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
- 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 processor, EON/UnionBank. Our technology partners, Multisys and UniPin, 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 EON/UnionBank 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 EON/UnionBank shall securely delete the data collected upon 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, you are entitled to the following data privacy rights:
- To be informed whether Personal Data pertaining to him or her shall be, are being, or have been processed;
- To reasonable access to any Personal Data collected and processed in duration of employment;
- To object or withhold consent with regards to the collection and processing of your Personal Data.
- To suspend, withdraw, or order the blocking, removal, or destruction of Personal Data from the relevant company’s filing system;
- 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;
- 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;
- To be indemnified for any damages sustained pursuant to the provisions of the Data Privacy Act or Other Privacy Laws