echo33 Privacy Policy

This Privacy Policy applies to all personal information collected, processed, stored, or disclosed by echo33 (referred to herein as "echo33", "we", "us", or "the Company") in connection with your use of the echo33 online gaming platform at echo33.cam and any related services, mobile interfaces, customer support interactions, and promotional communications.

By registering an account with echo33 or by continuing to use the echo33 Platform, you acknowledge that you have read, understood, and consented to the collection and processing of your personal information as described in this Privacy Policy. If you do not agree with any part of this Policy, you should not register for or use the echo33 Platform.

echo33 is committed to operating in a manner consistent with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

For the purposes of applicable data protection law, the data controller responsible for your personal information is the operator of the echo33 Platform. The Data Protection Officer (DPO) appointed by echo33 is responsible for overseeing compliance with this Privacy Policy and applicable data protection regulations. Contact details for the DPO are provided in Section 15 of this Policy.

Where echo33 engages third-party processors — such as payment service providers, game software providers, identity verification services, and cloud infrastructure providers — those parties act as data processors under the instruction and oversight of echo33. echo33 remains responsible as the data controller for the lawful processing of your personal information by those processors.

echo33 collects personal data through several channels, including account registration, payment transactions, identity verification, customer support interactions, and your use of the Platform. The categories of personal data we collect include:

• Full legal name as it appears on your government-issued identification document.
• Date of birth (used to verify you are 21 years of age or older, as required by Philippine gambling regulations).
• Nationality and country of residence.
• Government-issued ID number and copies of identification documents submitted for KYC verification (e.g., Philippine Passport, SSS ID, UMID, PhilHealth ID, Driver's Licence, Voter's ID).
• Selfie or liveness verification photographs where required to confirm document ownership.

• Philippine mobile number (required for account registration and OTP delivery).
• Email address (used for account communication and, where opted-in, promotional messages).
• Residential address (required for KYC verification and as stated in account settings).

• GCash account number or registered mobile number linked to your GCash wallet.
• Maya (PayMaya) account details where used for transactions.
• Bank account details (BPI, BDO, Metrobank, UnionBank, or other Philippine banks) where provided for withdrawal processing.
• Transaction history: deposit amounts, withdrawal requests, dates, methods, and processing statuses.
• Cryptocurrency wallet addresses (where USDT TRC20 or Coins.ph are used).

• echo33 username and encrypted account password.
• Game participation history: games played, bet amounts, outcomes, session durations, and win/loss records.
• Bonus and promotion history: bonuses claimed, wagering progress, and bonus wallet balances.
• Sports betting selections, stake amounts, and market data where applicable.
• Responsible gaming settings: deposit limits, session limits, self-exclusion status, and cooling-off periods.

• IP address and approximate geolocation data derived from your IP address.
• Device type, operating system, browser type, and version.
• Session timestamps, page visit data, clickstream patterns, and feature usage analytics.
• Cookies and local storage data as described in Section 10.

• Records of all communications between you and echo33 customer support, including live chat transcripts, email correspondence, and support ticket history.
• Responses to surveys, feedback forms, or promotional participation where provided voluntarily.

echo33 processes your personal data only for specific, legitimate purposes. The primary purposes for which your data is used are as follows:

• Account management: Creating, maintaining, and managing your echo33 Member account, including authentication, session management, and account history.
• Identity verification (KYC): Verifying your identity and age to comply with applicable gambling regulations, anti-money laundering laws, and internal security policies.
• Payment processing: Processing deposits and withdrawal requests through GCash, Maya, BPI, BDO, and other accepted payment methods. Reconciling transactions and maintaining financial records.
• Game delivery and integrity: Providing access to echo33's game library, recording game activity for dispute resolution, and maintaining the integrity of all games and betting markets on the Platform.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, unauthorised account access, collusion, bonus abuse, and other prohibited conduct.
• Legal compliance: Meeting obligations under Philippine law, including anti-money laundering (AML) obligations, tax reporting requirements, and responses to lawful regulatory or law enforcement requests.
• Responsible gaming: Monitoring gaming patterns for indicators of problem gambling, managing self-exclusion requests, and enforcing deposit and session limits set by Members.
• Customer support: Responding to enquiries, resolving disputes, processing complaints, and providing assistance through live chat and email support.
• Marketing (with consent): Sending promotional emails, SMS messages, and in-platform notifications about echo33 bonuses, new games, and special offers where you have opted in to receive such communications.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the Platform's performance, user experience, and game selection.

Under the Philippine Data Privacy Act and applicable data protection principles, echo33 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the account agreement with you — including account operation, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable laws, including AML regulations, KYC requirements, tax obligations, and responses to lawful regulatory requests.
• Legitimate interests: Processing necessary for echo33's legitimate business interests — including fraud prevention, platform security, dispute resolution, and service improvement — where those interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily applicable to marketing communications. You may withdraw this consent at any time through your account settings or by contacting echo33 support.

echo33 does not sell, rent, or commercially trade your personal data. We may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment service providers: GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven CLiQQ, and other payment processors — to process deposits and withdrawals in connection with your account. Each payment provider is subject to their own privacy terms.
• Identity verification services: Third-party KYC and AML compliance providers engaged to assist with identity document verification, age verification, and sanctions screening.
• Game software providers: Providers of the games available on the echo33 Platform may receive limited gameplay and session data for game functionality, RTP audit purposes, and dispute resolution.
• Cloud and infrastructure providers: Hosting, database, and technical infrastructure providers that store and process data on echo33's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Government agencies, regulatory bodies, or law enforcement authorities — where echo33 is legally required or lawfully compelled to disclose data, including the Philippine National Privacy Commission, PAGCOR, AMLC, the Bureau of Internal Revenue, or Philippine law enforcement agencies.
• Professional advisers: Legal counsel, auditors, and compliance consultants engaged by echo33 who are bound by professional confidentiality obligations.

echo33 may process or store some of your personal data outside the Philippines — for example, where cloud infrastructure or game server infrastructure is operated from jurisdictions outside Philippine territory. In such cases, echo33 will ensure that appropriate safeguards are in place to protect your personal data, including contractual protections equivalent to those required under Philippine law. Where transfers occur to countries with data protection standards different from those of the Philippines, echo33 will apply contractual clauses or other approved transfer mechanisms consistent with NPC guidance. You may request information about specific transfer safeguards by contacting our Data Protection Officer at the address in Section 15.

echo33 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, or to protect echo33's legitimate interests in connection with potential disputes or legal claims. Indicative retention periods include:

• Account data and gaming history: Retained for the duration of your account plus a minimum of five (5) years following account closure, in compliance with AML and financial record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years following the completion of the verification or the closure of your account, whichever is later, in accordance with applicable AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction for financial audit and tax compliance purposes.
• Customer support records: Retained for three (3) years from the date of the last interaction, or longer where the communication relates to a formal complaint or legal dispute.
• Marketing consent records: Retained until consent is withdrawn plus one (1) year to demonstrate compliance with opt-in requirements.
• Technical and usage data: Session-level technical data is typically retained in identifiable form for up to twelve (12) months, after which it is aggregated and anonymised for platform analytics purposes.

Upon the expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents its reconstruction.

echo33 implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and echo33 servers is encrypted using SSL/TLS 256-bit encryption. Stored passwords are hashed using a cryptographic one-way function — echo33 does not store plaintext passwords.
• Access controls: Access to personal data within echo33's systems is restricted to authorised personnel who require it to perform their specific roles. Role-based access controls and multi-factor authentication are enforced for all internal system access.
• OTP authentication: All Member logins may be secured with one-time password (OTP) verification delivered via SMS to your registered Philippine mobile number.
• System monitoring: echo33's infrastructure is monitored continuously for security anomalies, intrusion attempts, and suspicious data access patterns. Alerts are reviewed by the security operations team in real time.
• Regular testing: echo33 conducts regular security assessments and penetration testing to identify and remediate potential vulnerabilities in our systems before they can be exploited.
• Vendor assessment: All third-party data processors engaged by echo33 are assessed for data security practices before engagement and are required to maintain security standards consistent with applicable law.

Notwithstanding these measures, no method of data transmission or storage over the internet is entirely secure. While echo33 makes every reasonable effort to protect your personal data, we cannot guarantee absolute security against all threats.

echo33 uses cookies and similar tracking technologies to operate and improve the Platform, maintain your session, and — where you have consented — to deliver personalised content. The types of cookies used by echo33 include:

• Strictly necessary cookies: Required for the Platform to function correctly. These include session cookies that maintain your logged-in state and security cookies that protect against cross-site request forgery. These cookies cannot be disabled without affecting Platform functionality.
• Performance and analytics cookies: Used to collect aggregated, anonymised information about how Members use the Platform — including page views, navigation paths, game category preferences, and session duration. This information is used solely to improve the Platform experience. You may opt out of non-essential analytics cookies through your browser settings.
• Functionality cookies: Used to remember your preferences, language settings, and display choices across sessions. These enhance your experience but are not strictly required.
• Marketing cookies (with consent only): Used to deliver relevant promotional messages. These cookies are activated only where you have provided explicit consent. You may withdraw consent at any time by adjusting your preferences in the Platform or by modifying your browser settings.

You may control cookie settings through your browser's privacy or cookie preferences settings. Please note that disabling strictly necessary cookies may impair your ability to log in to and use the echo33 Platform.

Under the Philippine Data Privacy Act of 2012 and applicable implementing regulations, you have the following rights regarding your personal data held by echo33:

To exercise any of the above rights, please contact echo33's Data Protection Officer using the contact details provided in Section 15. All requests will be acknowledged within 3 business days. We may require verification of your identity before processing a request. Where a request is refused, echo33 will provide a written explanation of the legal basis for refusal.

The echo33 Platform is strictly for individuals who are 21 years of age or older, in accordance with Philippine gambling law. echo33 does not knowingly collect personal data from individuals under the age of 21.

During account registration, you are required to confirm your date of birth. Before your first withdrawal is processed, you are required to submit a valid government-issued ID confirming your age. If echo33 discovers or has reasonable grounds to believe that a Member is under 21 years of age, the account will be immediately suspended and all associated personal data will be reviewed and, where permissible, deleted.

echo33 may send you promotional communications — including bonus offers, new game announcements, event notifications, and special promotions — via email and SMS, but only where you have explicitly opted in to receive such communications during registration or through your account settings.

You may opt out of marketing communications at any time by:

• Adjusting your communication preferences in the Notifications section of your echo33 account settings.
• Clicking the "unsubscribe" link included in any promotional email from echo33.
• Replying "STOP" to any promotional SMS from echo33.
• Contacting echo33 support and requesting removal from marketing lists.

Opting out of marketing communications does not affect transactional notifications — echo33 will continue to send you account-related messages such as deposit confirmations, withdrawal notifications, security alerts, and KYC requests, as these are necessary for the operation of your account.

echo33 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or Platform features. Where changes are material, echo33 will notify you by email to your registered address or by a notice displayed upon your next login to the Platform, at least 14 days before the changes take effect.

Continued use of the echo33 Platform following notification of a revised Privacy Policy constitutes your acknowledgement of and agreement to the updated terms. The current version of the Privacy Policy, including its effective date, is always available at echo33.cam/privacy-policy. We encourage you to review this Policy periodically.

For all data privacy-related enquiries, requests to exercise your data subject rights, or concerns about echo33's handling of your personal information, please contact echo33's designated Data Protection Officer through the following channels:

• Email: [email protected] — please include "Data Privacy Request" in the subject line of your message.
• Live Chat: Available 24 hours a day, 7 days a week on the echo33 Platform. Tagalog and English are both supported.

echo33 will acknowledge all data privacy requests within 3 business days and provide a substantive response within 15 business days. Where a request is complex or involves a large volume of data, echo33 may extend this period by a further 15 business days, in which case you will be notified of the extension and the reason for it.

If you are not satisfied with echo33's response to your privacy concern, you may escalate your complaint to the National Privacy Commission of the Philippines. Information about the NPC's complaint process is available through the NPC's official government channels.