z5game Privacy Policy

01Introduction

This Privacy Policy applies to all personal data collected and processed by z5game in connection with the operation of the online gaming platform available at z5game.org. z5game is a PAGCOR-regulated online gaming platform serving Filipino players across the Philippines. This policy is written in clear English to ensure that every player — whether based in Metro Manila, Cebu City, Davao, Quezon City, or anywhere else in the Philippines — fully understands how their personal information is handled.

By registering a z5game account, accessing the platform as a guest, depositing funds, or otherwise using any z5game service, you acknowledge that you have read and understood this Privacy Policy and you consent to the collection, use, and processing of your personal data as described herein.

If you have questions about this Privacy Policy or wish to exercise any of your data rights, you may contact z5game's support team at [email protected] at any time. Our team is available 24 hours a day, seven days a week.

02Data We Collect

z5game collects personal data through several channels: directly from you when you register or update your account, automatically as you use the platform, and from third-party service providers involved in payment processing and identity verification. The categories of personal data we collect are described below.

03How We Use Your Data

z5game uses your personal data only for legitimate, clearly defined purposes. We do not use your data for any purpose that is incompatible with the reason it was originally collected. The primary purposes for which z5game processes personal data are:

• Account management: Creating and maintaining your z5game player account, verifying your identity, and managing your account preferences and security settings.
• Payment processing: Facilitating deposits and withdrawals via GCash, Maya, BPI, BDO, InstaPay, PesoNet, and other accepted payment methods; verifying that payment sources belong to the account holder.
• Regulatory compliance: Meeting z5game's obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws and regulations.
• Fraud prevention and security: Detecting and preventing unauthorized account access, bonus abuse, collusion, money laundering, and other prohibited conduct on the platform.
• Customer support: Responding to your queries, complaints, and disputes; providing technical assistance; resolving account issues.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviors; administering self-exclusion requests, deposit limits, and session controls.
• Platform improvement: Analyzing aggregated, anonymized usage data to improve the z5game platform, game selection, user interface, and overall player experience.
• Marketing communications: Sending promotional offers, bonus notifications, and tournament announcements — only where you have given explicit prior consent and only until you withdraw that consent.

z5game will never use your personal data to make fully automated decisions that produce significant legal or similarly significant effects on you without providing a meaningful avenue for human review.

04Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, z5game must have a lawful basis for each purpose for which it processes personal data. The legal bases relied upon by z5game are:

• Contractual necessity: Processing required to perform the contract between you and z5game — i.e., operating your player account, processing your transactions, and delivering the gaming services you have requested.
• Legal obligation: Processing required to comply with z5game's legal obligations under PAGCOR regulation, the AMLA, the Data Privacy Act, and any lawful order from a Philippine government authority.
• Legitimate interests: Processing necessary for z5game's legitimate business interests — including fraud prevention, platform security, responsible gaming monitoring, and internal analytics — provided those interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications, optional profiling features, and any other non-essential purpose where you have given freely, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting any other aspect of your account.

05Data Sharing & Disclosure

z5game does not sell, rent, or trade your personal data to any third party for commercial or advertising purposes. We share personal data only in the following limited circumstances:

• Payment processors: GCash, Maya, GrabPay, BPI, BDO, UnionBank, Metrobank, InstaPay, PesoNet, 7-Eleven CLiQQ, Coins.ph, and USDT TRC20 receive transaction data necessary to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party eKYC services receive identity documents and facial recognition data where required to complete player verification in line with PAGCOR requirements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities may receive data as required by law or in response to a valid legal order.
• Game content providers: Third-party game studios and live dealer operators may receive anonymized session data necessary to deliver their games within the z5game platform. These providers do not receive your identity or financial data.
• Professional advisers: Legal counsel, auditors, and compliance consultants engaged by z5game may access personal data on a strictly need-to-know basis, subject to professional confidentiality obligations.
• Business transfer: In the event of a merger, acquisition, or sale of substantially all of z5game's assets, personal data may be transferred to the successor entity. Affected players will be notified in advance, and data will continue to be processed under the same or stricter privacy protections.

06Cookies & Tracking

z5game uses cookies and similar tracking technologies to operate the platform, maintain your login session, detect fraud, and analyze how players use the site. A cookie is a small text file stored on your device by your web browser when you visit z5game.org.

The types of cookies used by z5game are as follows:

• Strictly necessary cookies: These cookies are essential for the platform to function — they maintain your login session, remember your language and currency preferences, and enable secure navigation. These cookies cannot be disabled without breaking core platform functionality.
• Functional cookies: These remember your preferences and settings across sessions — such as your preferred game lobby view, notification settings, and responsible gaming limits — to provide a more personalized experience.
• Analytical cookies: Anonymized data about how players navigate z5game — including pages visited, time on page, and error events — is used to improve platform performance and user experience. This data is aggregated and does not identify individual players.
• Security cookies: Used to detect suspicious activity, prevent bot access, and protect against cross-site request forgery (CSRF) and session hijacking attacks.

z5game does not use third-party advertising cookies or tracking pixels from external ad networks. You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may affect the functionality of the z5game platform.

07Data Retention

z5game retains personal data only for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. Our standard retention periods are:

• Account data: Retained for the duration of your active account and for a minimum of five years following account closure, in accordance with PAGCOR record-keeping requirements.
• Transaction records: Retained for a minimum of five years from the date of each transaction, as required by the Anti-Money Laundering Act and its implementing regulations.
• KYC and identity documents: Retained for the duration of account activity and for five years following account closure or the last transaction date.
• Support communications: Retained for three years from the date of the interaction, or longer where a communication relates to an active dispute or regulatory investigation.
• Technical and log data: Retained for 12 months from collection, unless a specific log is required for an ongoing investigation or security incident review.
• Marketing consent records: Retained for the duration of your consent and for three years following withdrawal of consent, as evidence of your consent history.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Anonymized data may be retained indefinitely for statistical and platform improvement purposes, as it can no longer be used to identify any individual.

08Data Security

z5game implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• Encryption in transit: All data transmitted between your browser or mobile device and z5game's servers is encrypted using TLS 1.2 or higher, enforced via 256-bit SSL certificates.
• Encryption at rest: Sensitive personal data stored in z5game's databases — including identity documents and financial records — is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data within z5game's internal systems is restricted on a strict need-to-know basis. Staff members access only the data required for their specific role, and all access is logged and audited.
• Two-factor authentication: All internal z5game system accounts with access to personal data are required to use multi-factor authentication (MFA). Players are strongly encouraged to enable 2FA via SMS OTP on their player accounts.
• Vulnerability management: z5game conducts regular security assessments, penetration testing, and vulnerability scans of its platform and infrastructure. Identified vulnerabilities are remediated according to a risk-based prioritization process.
• Incident response: z5game maintains a documented data breach response procedure. In the event of a personal data breach that poses a real risk of serious harm to affected players, z5game will notify the National Privacy Commission and affected individuals within the timeframes required by the Data Privacy Act.

09Your Privacy Rights

Under the Data Privacy Act of 2012 and related NPC regulations, you — as a data subject — have the following rights with respect to your personal data held by z5game:

• Right to be informed: You have the right to know that z5game is collecting and processing your personal data, the purposes for which it is being processed, and who it may be shared with — all of which are covered in this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data that z5game holds about you, including information about how it is being processed.
• Right to rectification: If any personal data z5game holds about you is inaccurate, incomplete, or outdated, you have the right to request that it be corrected or updated.
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful — subject to z5game's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests on grounds relating to your particular situation.
• Right to data portability: Where processing is based on your consent or on a contract, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: If you believe that z5game has processed your personal data in violation of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

10Minors & Age Policy

z5game's services are strictly intended for adults aged 21 years and above, in compliance with PAGCOR regulations governing online gaming in the Philippines. z5game does not knowingly collect, use, or store personal data from individuals under the age of 21.

All players are required to confirm their age during registration and to submit valid government-issued identification as part of the KYC process. Where z5game discovers or has reasonable grounds to suspect that an account is held by a person under the age of 21, the account will be immediately suspended pending investigation. Any funds held in such an account will be managed in accordance with applicable PAGCOR guidelines and will not be paid out as winnings.

11International Transfers

z5game's primary data processing operations are based within the Philippines. However, certain third-party service providers — including game content providers and cloud infrastructure partners — may process or store data on servers located outside the Philippines.

Where personal data is transferred outside of the Philippines, z5game ensures that such transfers comply with the Data Privacy Act of 2012 and NPC regulations on cross-border data flows. Specifically, z5game will only transfer personal data internationally where:

• The recipient country or territory has been assessed as providing an adequate level of data protection comparable to Philippine standards; or
• z5game has entered into appropriate contractual clauses with the recipient that impose data protection obligations equivalent to those required under Philippine law; or
• The transfer is required by PAGCOR, another competent Philippine authority, or is otherwise permitted under the Data Privacy Act.

You may request further information about international data transfers involving your personal data by contacting z5game at [email protected].

12Changes to This Policy

z5game reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, PAGCOR regulatory requirements, or the nature of the services we provide. The "Last updated" date at the top of this page reflects the date of the most recent revision.

Where changes to this Privacy Policy are material — meaning they significantly affect how z5game processes your personal data or alter your rights as a data subject — z5game will notify registered players by email to their registered address and/or via an in-platform notification displayed upon next login. Non-material clarifications or formatting changes may be made without specific notification.

Your continued use of the z5game platform after any revised Privacy Policy has been posted and communicated constitutes your acknowledgement of the updated policy. If you do not agree with any material change to this Privacy Policy, you may request account closure by contacting [email protected] — any real-money balance will be returned to your registered payment method following standard verification procedures.

13Contact & DPO

If you have any questions, concerns, or requests relating to this Privacy Policy or z5game's handling of your personal data, please reach out to our team. z5game has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and ensuring that your privacy rights are respected.