Effective Date: June 26, 2025
EASYWIN INC. ("EASYWIN", "Company", "we", "us", or "our") is engaged in the development and operation of skill-based social games (the “Applications”). In addition, we manage and maintain the website located at https://easywin.network, including all associated subdomains and features (collectively referred to as the “Website”). Together, the Applications and the Website are referred to herein as the “Services.”
At EASYWIN, we are committed to respecting and safeguarding your privacy and ensuring that our handling of personal information is transparent, fair, and in accordance with applicable data protection laws. This Privacy Policy (the “Policy”) is intended to provide clear and comprehensive information about the ways in which we collect, process, store, and disclose your personal data when you interact with our Services.
This Policy applies to all users who access or use our Services, whether by visiting the Website, downloading or interacting with our Applications, or engaging with any other functionality we offer. Please be advised that certain provisions of this Policy may not apply to you based on your country of residence or local legal requirements.
We strongly encourage you to review this Policy carefully to ensure that you understand it fully. If you do not accept the terms of this Policy, you should refrain from accessing or using our Services. You are entitled to withdraw from the use of our Services at any time, in accordance with the terms outlined herein.
Please note that while you are under no statutory or contractual obligation to provide us with personal data, choosing not to do so may limit your ability to use certain features or receive the full benefit of our Services.
This Policy is incorporated by reference into, and forms an integral part of, EASYWIN’s Terms of Use, which can be found at: https://easywin.network.
We may collect information about you by the following means:
Directly from you, when you provide information to us or interact with us;
Through use of cookies and other similar tracking technologies;
From online advertising companies who may share information about the marketing and advertisements you have seen or clicked on, and from social networks and other sources of publicly available data;
From other third party sources (for example, service providers who provide consumer data, sub-contractors in technical, payment services, analytics and tracking software providers).
We collect various categories of personal information that, either alone or in combination with other data, may be used to identify you with a reasonable degree of certainty (“Personal Data”). This section outlines the types of Personal Data we may collect, as well as the circumstances under which such data is obtained and processed.
When you register an account to use our Services, we collect information that you provide during the registration process. This typically includes your full name, email address, phone number, date of birth, and a chosen username or nickname. You may also optionally upload a profile picture or other personal details.
If you opt to sign in or link your account through a third-party social media platform (such as Facebook, Instagram, or Twitter), we may access and collect your user ID or handle on that platform, in addition to any public information or data that the platform makes available to us based on your settings and permissions.
When you initiate a transaction within our Applications (such as by depositing funds) you may be required to submit billing details. The exact data we collect depends on the payment method you select. For instance, if you choose to pay via credit card, we may collect your card number, expiration date, and other relevant payment credentials necessary to process the transaction securely.
As you interact with our Services, we automatically gather technical and behavioral information related to your usage. This may include, but is not limited to, session logs, gameplay activity (including video recordings), geolocation information, IP address, device identifiers, and other diagnostic data that reflects how you engage with the Services.
If you reach out to us via email, through in-App support channels, or through the contact forms available on our Website, we will collect the information you provide as part of your inquiry. This typically includes your name, email address, and the contents of your message, along with any additional details you voluntarily choose to include.
This section sets out the reasons we handle your Personal Data and identifies the lawful bases upon which such processing is conducted.
Purpose | Lawful Basis |
Service Delivery and Customer Support. We utilize your Personal Data (such as your name and contact details) to provide our Services and respond to customer support inquiries. | The lawful bases for this processing include the performance of contractual obligations, your consent (e.g., when you voluntarily provide Personal Data), and our legitimate interests in delivering and supporting our Services. |
Payment Processing. Through our third-party payment providers, we collect billing details to facilitate transactions, link payment instruments to user accounts, and send relevant financial documents such as receipts and billing reminders. | The lawful bases for this processing include the performance of a contract, the fulfillment of our legal obligations, and our legitimate interests in ensuring seamless payment functionality. |
Service Enhancement. We collect and assess data regarding your interactions with our Services to enhance functionality, user experience, and overall performance. | This processing is based on our legitimate interests in maintaining and optimizing our Services. |
Personalized Content and Advertising. We may use data-gathering technologies (e.g., cookies) to show tailored advertisements or content that align with your preferences while using our Services. | The lawful bases include your consent (where required by law) and our legitimate interests in providing customized content and marketing relevant to your interests. |
Security and Fraud Prevention. We may process usage data to uphold the security of our Services, prevent unauthorized access or fraudulent activity, verify user identities, and enforce our internal policies. | This processing is based on your consent (where applicable), our legitimate interests in protecting the integrity of our Services, and compliance with legal requirements. |
Legal Compliance. We process Personal Data to comply with applicable legal and regulatory requirements. | The lawful basis for this processing is our compliance with legal obligations, as well as our legitimate interests in cooperating with law enforcement and regulatory authorities. |
Ensuring that users enjoy a fair, equitable, and competitive environment while using our Services is of utmost importance to us. Consequently, we rigorously prohibit any form of cheating, hacking, unauthorized account access, or other fraudulent conduct. By registering an account, engaging in gameplay, or otherwise utilizing our Services, you acknowledge that we may deploy various anti-cheat and fraud detection mechanisms to identify and mitigate malicious behavior. Such measures may involve the collection and analysis of data related to the game software or your device, and may be implemented either directly by us or through third-party service providers.
We may share, transfer, and disclose your Personal Data in the following circumstances, as outlined below:
Your Personal Data may be shared internally with our affiliated companies and subsidiaries to fulfill the purposes set forth in this Privacy Policy.
We disclose your payment details to authorized third-party payment processors to facilitate transactions made through our Services. These entities may access your Personal Data solely to perform payment processing functions on our behalf.
Certain third-party service providers engaged by us may require access to Personal Data to deliver services such as customer support, infrastructure management, and cloud storage. These providers act as our agents and process data only as necessary to support our operations.
We collaborate with third-party advertisers who may display ads within our Services or manage our advertising across external websites and applications. These partners may employ tracking technologies to collect information about your activities on our platforms and others, enabling tailored advertising based on your interests and browsing behavior. For additional details, please consult the privacy policies of our advertising partners.
Our Services permit integration with third-party platforms (e.g., Facebook, Apple) for account linking or in-app purchases. Usage of these integrations is subject to the respective third parties’ terms and privacy policies, which we encourage you to review. We do not access or store your login credentials for these external services.
We may disclose your Personal Data to governmental or law enforcement authorities, or private parties, when we deem it necessary to comply with legal obligations, respond to claims or legal proceedings (including subpoenas), protect the rights or property of ourselves or others, ensure public or individual safety, or prevent activities we reasonably suspect to be illegal or harmful. Such disclosures may be compelled by lawful requests or national security requirements.
Your data may be shared with external auditors, legal counsel, accountants, insurers, and other professional advisors to ensure compliance with applicable laws, regulations, and industry standards.
In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your Personal Data may be transferred, sold, or otherwise shared as part of such business transactions.
We may process your Personal Data, either directly or through authorized third-party service providers, for the purpose of delivering marketing communications related to our Services, as well as other offerings, platforms, or applications associated with EASYWIN, its affiliates, and strategic business partners (collectively referred to as "Marketing Affiliates") that we believe may be of interest to you.
You retain the right to opt out of receiving future marketing communications from us or our Marketing Affiliates at any time by contacting us at: support@easywin.network.
Please be aware that opting out of promotional messages will not affect our ability to send you important service-related notices, such as updates regarding your account or the functionality of the Services.
Depending on your place of residence, you may be entitled to certain rights under applicable data protection laws concerning the collection and use of your Personal Data. Where such rights are granted to you under relevant legislation, you may exercise them by contacting us using the details provided below.
In accordance with applicable law, you may have the right to:
Certain jurisdictions may provide individuals with additional rights regarding the collection and use of their personal data. For example, you may have the right to request that we: (i) disclose any personal data we hold
about you; (ii) correct or delete your personal data (subject to certain exceptions); or (iii) restrict or opt out of the disclosure or sale of your information to third parties (excluding qualified service providers). If you are a resident of any of the following jurisdictions, please review the notice applicable to your location to learn more. Please note that privacy rights and obligations may vary depending on the jurisdiction, and the rights described below represent the primary rights afforded under applicable laws and may not be exhaustive.
US states California
The California Consumer Privacy Act (“CCPA”), along with the California Privacy Rights Act amendment (“CPRA”), provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of information about them, as well as rights to know/access, delete, and limit sharing of Personal Data. You have the right to be free from discrimination based on your exercise of your CCPA rights.
If you are a California resident, you can see more details about the types of personal data we have collected from you in the past 12 months and may collect from you, how we collect such personal data and purposes for which we collect your personal data in Section 3 “PERSONAL DATA WE COLLECT” above. We do not share your personal data with any third-party except as further described in Section 5 “DISCLOSURE AND SHARING OF YOUR PERSONAL DATA” above. Please refer to the other terms of this Privacy Policy to see further rights afforded to you and how we use your personal data.
We do not “Sell” (as defined in the CCPA) your personal data which we have collected or may collect and in the event we will sell your personal data, we will notify you by updating this Privacy Policy and we will provide you with the option of opting out of such “sale”.
We may, however, use your personal data for “sharing” as defined under the CPRA for purposes of cross-context behavioral advertising, and you have the right to opt out of such sharing.
Privacy Rights for Californians:
Under the CCPA, California residents have specific rights regarding their personal data. This section describes Californians' rights and explains how California residents can exercise those rights.
Below we further outline specific rights which California residents may have under the CCPA.
How to Submit a Request:
You may submit a request to exercise your rights to know/access or delete your personal data through submitting a request via email to support@easywin.network.
Upon submission of your request, we will contact you via the email address provided in your request. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In some instances, such as a request for data deletion, we may first separately confirm that you would like for us to in fact delete your personal data before acting on your request. With all requests, we will aim to complete requests as soon as reasonably practicable and consistent with any timeframes mandated by applicable laws. If we require more time, we will inform you of the reason and extension period in writing. You may authorize another individual or a business registered with the California Secretary of State, or designate an authorized agent, to make requests on your behalf through these means.
In some cases our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the personal data, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
The Virginia Consumer Data Privacy Act (“VCDPA”) provides Virginia residents with certain additional privacy rights regarding the collection, use and sharing of personal data. If you are a Virginia resident, you can see more details about the types of personal data we have collected from you in the past 12 months and may collect from you, how we collect such personal data and purposes for which we collect your personal data in Section 3 “PERSONAL DATA WE COLLECT” above. We do not share your personal data with any third-party except as further described in Section 5 “DISCLOSURE AND SHARING OF YOUR PERSONAL DATA” above. Please refer to the other terms of this Privacy Policy to see further rights afforded to you and how we use your personal data.
We do not sell personal data as defined under the VCDPA. We also do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer. However, EASYWIN does engage in targeted advertising, as that term is defined in the VCDPA.
Privacy Rights for Virginians:
Under the VCDPA, Virginia residents have specific rights regarding their personal data. This section describes Virginians' rights and explains how Virginia residents can exercise those rights.
How to Submit a Request:
You may submit a request to exercise your rights to know/access or delete your personal data through submitting a request via email to support@easywin.network .
Under the Colorado Privacy Act (“CPA”), Colorado residents have certain privacy rights regarding the collection, use and disclosure of their personal data. If you are a Colorado resident, you can see more details about the types of personal data we have collected from you in the past 12 months and may collect from you, how we collect such personal data and purposes for which we collect your personal data in Section 3 “PERSONAL DATA WE COLLECT” above. We do not share your personal data with any third-party except as further described in Section 5 “DISCLOSURE AND SHARING OF YOUR PERSONAL DATA” above. Please refer to the other terms of this Privacy Policy to see further rights afforded to you and how we use your personal data.
We do not sell the personal data of Colorado residents, as the term “sale” is defined under the CPA. We also do not process personal data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects. However, EASYWIN does engage in targeted advertising, as that term is defined under the CPA.
Privacy Rights for Coloradoians:
Under the CPA, Colorado residents have specific rights regarding their personal data. This section describes Coloradoians' rights and explains how Colorado residents can exercise those rights.
confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies.
How to Submit a Request:
You may submit a request to exercise your rights to know/access or delete your personal data through submitting a request via email to support@easywin.network.
Under the Connecticut Data Privacy Act (“CDPA”), Connecticut residents have certain privacy rights regarding the collection, use and disclosure of their personal data. If you are a Connecticut resident, you can see more details about the types of personal data we have collected from you in the past 12 months and may collect from you, how we collect such personal data and purposes for which we collect your personal data in Section 3 “PERSONAL DATA WE COLLECT” above. We do not share your personal data with any third-party except as further described in Section 5 “DISCLOSURE AND SHARING OF YOUR PERSONAL DATA” above. Please refer to the other terms of this Privacy Policy to see further rights afforded to you and how we use your personal data.
We do not sell the personal data of Connecticut residents, as the term “sale” is defined under the CDPA. We do not process personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects. However, EASYWIN does engage in targeted advertising, as that term is defined under the CDPA.
Privacy Rights for Connecticut Residents:
Under the CDPA, Connecticut residents have specific rights regarding their personal data. This section describes those rights and explains how Connecticut residents can exercise those rights.
How to Submit a Request:
You may submit a request to exercise your rights to know/access or delete your personal data through submitting a request via email to support@easywin.network.
If you are a resident of Iowa, Indiana, Montana, New Jersey, New Hampshire, Nebraska, Minnesota, Tennessee, Texas, or Oregon, you have specific rights under applicable state privacy laws regarding your personal data. These rights may include the right to access, correct, delete, or restrict the processing of your personal data.
To exercise any of these rights, please submit your request by emailing us at support@easywin.network. We will respond to your request in accordance with the applicable state privacy laws.
If you are located in the EEA, Switzerland, or the UK, you are entitled to certain rights, subject to applicable exceptions, under the GDPR, Swiss, and UK data protection laws. Please note that, in order to verify your identity, we may require you to provide additional information before granting access to any records containing your personal data.
If you are a resident of the EEA, Switzerland, or the UK, you can see more details about the types of personal data we may collect from you, how we collect such personal data and purposes for which we collect your personal data in Section 3 “PERSONAL DATA WE COLLECT” above. We do not share your personal data with any third-party except as further described in Section 5 “DISCLOSURE AND SHARING OF YOUR PERSONAL DATA” above. Please refer to the other terms of this Privacy Policy to see further rights afforded to you and how we use your personal data.
Privacy Rights for resident of the EEA, Switzerland, or the UK:
know first at support@easywin.network. We care about your privacy and want to make sure that we do everything to address any of your concerns.
To submit a request to exercise your rights, please request via email to support@easywin.network. We may have a reason under the law why we do not have to comply with your request, or may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
If you are located in a jurisdiction outside of the aforementioned jurisdictions, and would like to request a data right (access, transfer, deletion of your data, etc.) please submit your request via email to support@easywin.network. We will evaluate your request, based on applicable data protection laws.
Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through support@easywin.network.
Only you, or a person legally permitted to act on your behalf under applicable law, may submit a request relating to your Personal Data. If you wish to appoint an authorized agent to act on your behalf, please contact us at support@easywin.network for further instructions. We will require a signed authorization from you and your designated agent before proceeding.
To help safeguard your privacy and the integrity of your Personal Data, we must verify your identity (or the identity of your authorized representative) before processing certain privacy-related requests. This may involve confirming account details or requesting additional identifying information, such as your UID number or the email address associated with your account.
Where permitted by law, if we are unable to comply with your request, you may have the right to appeal our decision. If applicable, you can initiate an appeal by notifying us and providing relevant supporting information.
As a globally operating organization, we may collect, process, and transfer your Personal Data across multiple jurisdictions worldwide. This includes, but is not limited to, transfers to and from locations within the European Economic Area (EEA), the United Kingdom (UK), and the United States, for the purposes set forth in this Privacy Policy.
Where the GDPR or the UK GDPR applies, we ensure that any transfer of Personal Data outside the EEA or UK is carried out in compliance with applicable data protection laws. Specifically, such transfers will only occur where:
The recipient is located within the EEA or UK;
The destination country has been formally recognized by the European Commission or UK authorities as providing an adequate level of data protection; or
Appropriate safeguards are in place, such as legally binding agreements incorporating standard contractual clauses or other lawful transfer mechanisms that ensure your Personal Data is protected to a standard comparable with that of the EEA or UK.
We implement physical, administrative, and technical safeguards designed to protect your Personal Data from unauthorized access, use, or disclosure. We also contractually require that our service providers protect such information from unauthorized access, use, and disclosure. In addition, we limit access to Personal Data to those employees, agents, contractors, and other third-parties that have a legitimate business need for such access.
Our Services are intended for individuals who are at least 18 years of age, or the minimum age required by applicable law in their jurisdiction, whichever is higher, as set forth in our Terms of Use. We do not knowingly collect or process personal data from individuals who do not meet this age requirement. If you believe that we have inadvertently collected personal data from someone under the applicable minimum age, please contact us at support@easywin.network. Upon verification, we will promptly delete such information and take appropriate steps in accordance with applicable data protection laws.
We comply with global privacy regulations, including but not limited to the Children’s Online Privacy Protection Act (COPPA), the General Data Protection Regulation (GDPR), and other laws designed to protect the privacy of minors.
We retain your Personal Data only for as long as it is necessary to fulfill the purposes for which it was collected, including the provision of our Services, compliance with applicable legal and regulatory obligations, the resolution of disputes, and the enforcement of our terms and policies.
The specific retention period applicable to any given category of Personal Data will be determined based on factors such as the nature and sensitivity of the data, the reason it was collected, relevant legal requirements, and our operational needs. We strive to ensure that Personal Data is not retained for longer than is reasonably required and will securely delete or anonymize information when it is no longer needed.
When you access or interact with our Services, we and certain authorized third parties deploy a variety of tracking mechanisms such as cookies, web beacons, pixels, local storage, and other similar technologies (“Tracking Technologies”). These tools are used to automatically gather information regarding your device, usage patterns, and browsing behavior. The purpose of employing such technologies is to streamline user navigation, enhance functionality, perform analytics, personalize your experience, and deliver content and advertisements that are better aligned with your preferences.
When you engage with our Services, the following types of Tracking Technologies may be deployed:
The use of these technologies by third parties is subject to their respective privacy or cookie policies, over which EASYWIN exercises no control.
Tracking Technologies may be placed on your device either by us (“First-Party Tracking Technologies”) or by third parties that provide services or content on our behalf, such as analytics providers, advertisers, and business partners (“Third-Party Tracking Technologies”). These technologies may persist only for the duration of your browsing session or remain active for repeat visits to our Services.
You can control how Tracking Technologies operate on your device through several methods:
For further control over third-party advertising cookies, you can also visit the following industry opt-out platforms:
EASYWIN may update or modify this Privacy Policy from time to time to reflect changes in our business practices, regulatory requirements, or applicable laws. We encourage you to review this page periodically for any updates.
When we make material changes to this Privacy Policy, we will post the revised version on this page with an updated “effective date” at the top.
EASYWIN expressly reserves the right to amend this Privacy Policy as necessary to comply with changes in applicable privacy laws and regulations in the jurisdictions where we operate or provide services. Your continued use of our Services following the posting of any changes or after receiving notice of such changes constitutes your acknowledgment and acceptance of the updated Privacy Policy and the collection, use, and sharing of your personal data in accordance with its terms as of the effective date.
If you do not agree to the updated terms, you should discontinue use of the Services.
If you have any further questions, please contact us by email at: support@easywin.network. EASYWIN INC.
501 Silverside Road Suite 105, Wilmington, 19809, New Castle, DE, USA
For inquiries related to data protection within the European Union, you may also contact EASYWIN’s EU Data Protection Representative via email at: support@easywin.network
For inquiries related to data protection within the United Kingdom, you may also contact EASYWIN’s UK Data Protection Representative via email at: support@easywin.network