Privacy Policy — z25 Casino

1. Who We Are

z25 ("z25," "we," "our," or "us") operates the online gambling platform accessible at z25.one (the "Platform"). z25 is the personal information controller responsible for the personal data of users ("you," "Player," or "Data Subject") collected through the Platform.

This Privacy Policy applies to all personal information that z25 collects, processes, and stores in connection with your registration, account management, use of the Platform, and any communications between you and z25. By registering or using the z25 Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Personal Data We Collect

z25 collects the following categories of personal data in the course of operating the Platform:

2.1 Identity & Registration Data

• Full legal name as it appears on a government-issued ID
• Date of birth (to verify the 21+ age requirement)
• Philippine mobile number and/or email address
• Username and hashed password

2.2 KYC & Verification Data

• Copies of government-issued Philippine identification documents (e.g., PhilSys National ID, passport, UMID, driver's license, voter's ID)
• Selfie photographs taken with the submitted ID document
• Any additional documentation requested for source-of-funds or address verification

2.3 Financial & Transaction Data

• GCash account number, Maya account number, or other e-wallet identifiers
• Bank account details (where applicable for bank transfer methods such as BPI, BDO, or Metrobank)
• Deposit amounts, withdrawal amounts, transaction dates, and payment method references
• Account balance history and bonus credit/debit records

2.4 Gaming & Behavioural Data

• Game play history (games played, bets placed, outcomes, session durations)
• Bonus usage and wagering activity
• Responsible gaming limit settings and self-exclusion records
• Login timestamps and session activity logs

2.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser version
• Cookie identifiers and session tokens
• Referral source and UTM parameters where applicable

2.6 Communications Data

• Contents of live chat conversations with z25 support
• Email correspondence with z25
• Feedback, complaints, and survey responses

3. How We Collect Your Data

z25 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or respond to a survey.
• Automatically — through cookies, web beacons, and server logs when you access and browse the z25 Platform.
• From third-party service providers — including our payment processors (e.g., GCash/GXI, Maya/PayMaya), KYC verification partners, game software providers, and fraud prevention services, who may share information with us as part of their service delivery.
• From regulatory authorities — where z25 is required to receive or provide information as part of its licensing and compliance obligations.

4. How We Use Your Personal Data

z25 uses the personal data it collects for the following purposes:

Purpose	Data Categories Used
Account registration and authentication	Identity, technical
Age verification and KYC compliance	Identity, KYC documents
Processing deposits and withdrawals	Financial, identity
Providing and personalizing gaming services	Gaming behaviour, technical
Fraud detection and prevention	All categories
Anti-money laundering (AML) compliance	Identity, financial, KYC
Customer support and dispute resolution	Identity, communications
Responsible gaming monitoring and intervention	Gaming behaviour, identity
Marketing communications (with consent)	Identity, communications
Platform security and abuse prevention	Technical, gaming behaviour
Legal and regulatory reporting obligations	All categories as required

5. Legal Basis for Processing

Under the Philippine Data Privacy Act and its Implementing Rules and Regulations, z25 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the z25 Terms and Conditions, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws, including KYC/AML obligations under the Anti-Money Laundering Act (AMLA), PAGCOR regulatory requirements, and the Data Privacy Act itself.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improving our services, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where z25 has obtained your specific, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

z25 does not sell your personal data to third parties. 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 agreements:

• Payment processors: GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), and other payment service providers for the purpose of processing your deposits and withdrawals.
• KYC and identity verification partners: Third-party verification services used to authenticate government-issued Philippine IDs and process selfie verification.
• Game software providers: Licensed third-party game studios (e.g., Pragmatic Play, PG Soft, Evolution Gaming) whose platforms are integrated into z25, for the purpose of delivering game content and maintaining bet records.
• Fraud prevention and security services: Specialist providers that assist z25 in detecting and preventing fraudulent activity, bonus abuse, and multi-accounting.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where disclosure is required by law or court order.
• Professional advisers: Lawyers, auditors, and compliance consultants engaged by z25 under strict confidentiality obligations.

Any third party with whom z25 shares personal data is bound by contractual obligations to process that data only for the stated purpose and in compliance with applicable privacy laws.

7. International Data Transfers

Some of z25's third-party service providers — particularly game software providers and certain technical infrastructure partners — may be located outside the Republic of the Philippines. Where personal data is transferred internationally, z25 ensures that appropriate safeguards are in place, including:

• Contractual clauses requiring the recipient to process personal data to a standard equivalent to Philippine data protection requirements;
• Selection of recipients located in jurisdictions that the NPC has determined to provide an adequate level of data protection; or
• Other lawful transfer mechanisms recognized under the Data Privacy Act and its Implementing Rules.

8. Data Retention

z25 retains your personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with legal obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, to comply with AML record-keeping requirements under Philippine law.
• KYC documents: Retained for a minimum of five (5) years from the date of verification, as required by AMLA implementing regulations.
• Financial and transaction data: Retained for a minimum of five (5) years from each transaction date.
• Gaming behaviour data: Retained for two (2) years from the date of generation, or longer where required for dispute resolution or regulatory investigation.
• Communications data: Retained for two (2) years from the date of communication, or longer where an active complaint or legal matter is pending.

After the applicable retention period, personal data is securely deleted or anonymized in accordance with z25's data disposal procedures.

9. Your Rights as a Data Subject

Under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by z25:

• Right to be Informed: To know how your personal data is collected, processed, and used — as described in this Privacy Policy.
• Right to Access: To request a copy of the personal data z25 holds about you.
• Right to Rectification: To request correction of inaccurate, incomplete, or outdated personal data.
• Right to Erasure / Right to be Forgotten: To request deletion of your personal data where it is no longer necessary for its original purpose, subject to z25's legal retention obligations.
• Right to Object: To object to the processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: To receive a structured, machine-readable copy of personal data that you provided to z25.
• Right to Damages: To claim compensation for damages suffered as a result of a violation of your data privacy rights.
• Right to File a Complaint: To lodge a complaint with the National Privacy Commission of the Philippines if you believe z25 has violated your data privacy rights.

To exercise any of the above rights, contact z25's Data Protection Officer using the details in Section 14. z25 will respond to all legitimate requests within thirty (30) days of receipt, or within such extended period as permitted by the Data Privacy Act where the request is complex.

10. Cookies & Tracking Technologies

z25 uses cookies and similar tracking technologies on the Platform. Cookies are small data files stored on your device that help us deliver and improve our services. The types of cookies z25 uses include:

• Strictly necessary cookies: Required for the Platform to function, including session authentication tokens and security cookies. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, game lobby layout) to personalize your experience.
• Analytics cookies: Collect aggregated, anonymized data about how users navigate the Platform to help us improve its performance.
• Marketing cookies: Track your engagement with z25 promotions to help us deliver relevant offers, where you have consented to such use.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the z25 Platform.

11. Children's Privacy

The z25 Platform is strictly for adults aged 21 years and older. z25 does not knowingly collect personal data from individuals under 21 years of age. If z25 discovers or has reason to believe that personal data has been collected from a person under the required age, the relevant account will be immediately closed, all personal data will be deleted, and any deposited funds will be returned (net of any winnings, which shall be forfeited).

If you believe that a minor has registered on the z25 Platform, please contact z25 support or our Data Protection Officer immediately using the contact details in Section 14.

12. Security Measures

z25 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and z25 servers
• Encrypted storage of sensitive data, including KYC documents and financial records
• Hashing of passwords using industry-standard algorithms (passwords are never stored in plain text)
• Role-based access controls limiting z25 staff access to personal data on a strict need-to-know basis
• Regular security assessments and penetration testing of Platform infrastructure
• Two-factor authentication (2FA) available for player accounts and mandatory for internal administrative access

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, z25 will notify the National Privacy Commission and affected data subjects within seventy-two (72) hours of becoming aware of the breach, in accordance with the Data Privacy Act.

13. Updates to This Privacy Policy

z25 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. The "Last Updated" date at the top of this page reflects the most recent revision.

Where changes to this Privacy Policy are material, z25 will notify registered players via email or Platform notification prior to the effective date of the change. Your continued use of the z25 Platform following notification of a material change constitutes your acceptance of the revised Privacy Policy.

14. Contact Us & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data rights, you may contact z25 as follows:

• Live Chat: 24/7 via the z25 Platform — average response time 3–5 minutes, in English and Tagalog
• Email (Data Privacy Matters): [email protected] — plain text, not a clickable link

Please mark your subject line with "Data Privacy Request" or "DPO Inquiry" to ensure your request is directed to the appropriate team. z25 acknowledges all data privacy requests within two (2) business days and provides a substantive response within thirty (30) days of receipt, or such extended period as the Data Privacy Act permits.

If you are not satisfied with z25's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about how to do so is available on the NPC's official website.