zzcc Casino – Privacy Policy

zzcc Casino ("zzcc," "we," "our," "the Platform") is the operator of the online gaming platform accessible at https://zzcc.bio and all associated mobile interfaces. zzcc acts as the Personal Information Controller (PIC) for the personal data of players and users of the platform, as defined under Republic Act No. 10173 (Data Privacy Act of 2012).

zzcc operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Our platform is designed primarily for Filipino players residing in the Philippines, and all data processing activities described in this Policy are governed by Philippine law, including the DPA, the Anti-Money Laundering Act (AMLA), and PAGCOR's applicable data governance requirements.

This Privacy Policy applies to all personal data collected through the zzcc website, mobile platform, customer support channels, and any other interaction you have with zzcc as a registered player, visitor, or prospective player.

zzcc collects the following categories of personal data, the necessity of which varies depending on the stage of your relationship with the platform:

Identity & Contact Data:

• Full legal name as it appears on your government-issued ID;
• Date of birth (used to verify the mandatory 21+ age requirement);
• Philippine mobile number (primary account identifier and OTP channel);
• Residential address;
• Email address (where provided).

Identity Verification (KYC) Data:

• Copies of government-issued identification documents (e.g., PhilSys National ID, UMID, Passport, Driver's License);
• Selfie photographs for liveness verification;
• Source-of-funds declarations where required by AMLA thresholds.

Financial Data:

• GCash account number or PayMaya number linked to your zzcc wallet;
• Bank account details (BDO, BPI, Metrobank) where bank transfers are used;
• Transaction history: deposits, withdrawals, and bonus credits;
• Wallet balance history.

Gaming Activity Data:

• Game sessions, bet amounts, game outcomes, and win/loss records;
• Game preferences and lobby interaction patterns;
• Bonus claims, wagering records, and VIP tier progression.

Technical & Device Data:

• IP address and approximate geolocation (province/city level);
• Device type, operating system, and browser version;
• Session timestamps and platform access logs;
• Cookie identifiers and analytics event data.

Communications Data:

• Live chat transcripts with zzcc support;
• Support ticket contents and resolution records.

zzcc collects personal data through the following means:

• Direct Submission: Information you provide during account registration, KYC verification, deposit/withdrawal requests, and support interactions;
• Automated Collection: Technical and device data collected automatically when you access the zzcc platform, including via cookies, server logs, and analytics tools;
• Third-Party Sources: Identity verification data confirmed through third-party KYC and document verification service providers; payment transaction data from GCash, PayMaya, and banking partners for the purpose of confirming deposits and processing withdrawals;
• Regulatory Sources: Watchlist data and sanctions screening results from PAGCOR-mandated compliance databases.

zzcc processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and securing your zzcc player account;
• Age & Identity Verification: Confirming that all players meet the PAGCOR-mandated 21+ age requirement and that accounts are operated by the verified account holder;
• Payment Processing: Processing deposits and withdrawals via GCash, PayMaya, and partner banks;
• Regulatory Compliance: Fulfilling obligations under PAGCOR licensing conditions, AMLA reporting requirements, and National Privacy Commission (NPC) data governance standards;
• Game Delivery: Providing the full range of zzcc gaming services and personalizing the game lobby based on your activity;
• Bonus & Promotions Administration: Calculating wagering requirements, verifying bonus eligibility, and crediting promotional rewards;
• Customer Support: Resolving account issues, processing disputes, and responding to player enquiries;
• Responsible Gaming: Monitoring gaming patterns to identify problem gambling indicators and administering self-exclusion requests;
• Security & Fraud Prevention: Detecting multi-accounting, unauthorized access, money laundering, and other prohibited conduct;
• Platform Improvement: Analyzing aggregated usage data to improve platform performance, game offerings, and user experience.

zzcc processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract between you and zzcc — including account creation, payment processing, and game delivery;
• Legal Obligation: Processing required to comply with PAGCOR conditions, AMLA obligations, and NPC requirements;
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data privacy rights;
• Consent: Processing for optional marketing communications, where your prior opt-in consent has been obtained.

zzcc does not sell your personal data to third parties. We share personal data only in the following limited circumstances:

• Game Providers: Game session data is shared with licensed game providers (e.g., JILI Games, PG Soft, Pragmatic Play) solely for the purpose of game delivery and fairness verification. Game providers act as Personal Information Processors (PIPs) under binding data processing agreements with zzcc;
• Payment Partners: Financial data is shared with GCash, PayMaya, BDO, BPI, and Metrobank solely to process your deposits and withdrawals;
• KYC/AML Service Providers: Identity documents are shared with third-party identity verification providers under strict data processing agreements for the purpose of satisfying PAGCOR KYC requirements;
• Regulatory Authorities: zzcc is legally required to report covered transactions and suspicious transactions to the Anti-Money Laundering Council (AMLC) and to provide player data to PAGCOR upon lawful request;
• Law Enforcement: zzcc will disclose personal data to law enforcement agencies when compelled by a valid court order or lawful legal process under Philippine law;
• Professional Advisors: Legal counsel, auditors, and compliance consultants under strict confidentiality obligations.

Some of zzcc's third-party service providers — particularly game engine providers and cloud infrastructure partners — may process data outside of the Philippines. Where such transfers occur, zzcc ensures that appropriate safeguards are in place, including contractual clauses requiring the receiving party to maintain data protection standards equivalent to those required by the Philippine Data Privacy Act of 2012.

zzcc remains accountable for personal data transferred to third-party processors and requires all processors to process data only on zzcc's documented instructions and for no other purpose.

zzcc retains personal data for the following minimum periods, or longer where required by law:

• Account & KYC Records: Five (5) years from account closure, as required by AMLA and PAGCOR regulations;
• Financial Transaction Records: Five (5) years from the date of each transaction;
• Gaming Activity Logs: Three (3) years from the date of each session;
• Support Communications: Two (2) years from the date of the final communication;
• Self-Exclusion Records: Permanently retained to prevent re-registration by excluded players.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with NPC-approved data disposal procedures.

zzcc implements organizational and technical security measures proportionate to the sensitivity of the personal data held, including:

• 256-bit SSL/TLS encryption for all data transmitted between your device and zzcc's servers;
• Encryption of sensitive personal data at rest, including KYC documents and financial records;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication required for all zzcc administrative systems;
• Regular independent security audits and penetration testing;
• Incident response procedures with NPC notification obligations in the event of a personal data breach affecting 100 or more individuals, as required by NPC Circular 16-03.

zzcc uses cookies and similar tracking technologies on its platform for the following purposes:

• Essential Cookies: Required for platform functionality, including maintaining your authenticated session after zzcc login. These cannot be disabled without preventing access to the platform;
• Performance Cookies: Collect anonymized data about how players navigate the platform to identify performance issues and improve page load times;
• Analytics Cookies: Used to understand aggregate player behavior, game popularity, and feature usage. Data collected is anonymized at the platform level.

You may manage non-essential cookies through your browser settings. Please note that disabling certain cookies may affect platform functionality. zzcc does not use cookies to serve third-party advertising or to track players across external websites.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by zzcc:

• Right to Be Informed: The right to know that your personal data is being collected and processed, as reflected in this Policy;
• Right of Access: The right to request a copy of the personal data zzcc holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data where processing is no longer necessary and no legal obligation requires retention;
• Right to Restrict Processing: The right to request that zzcc limit the processing of your personal data in certain circumstances;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Object: The right to object to processing based on legitimate interests, including direct marketing;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) at privacy.gov.ph if you believe your data privacy rights have been violated.

To exercise any of these rights, contact zzcc's Data Protection Officer using the details in Section 14. zzcc will respond to verified requests within fifteen (15) business days, as required by the DPA.

zzcc Casino is strictly prohibited from processing the personal data of individuals under 21 years of age for the purpose of real-money gaming, in compliance with PAGCOR's minimum age requirements. We do not knowingly collect personal data from individuals under 21.

If zzcc discovers that personal data has been collected from an individual who is under 21 years of age, all associated account data will be deleted immediately, and any deposited funds will be returned to the source payment method following identity verification. Any person who provided false age information during registration may be subject to legal action under applicable Philippine law.

zzcc reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes will be communicated to registered players via the platform notification system or via the mobile number associated with your account, no less than seven (7) days prior to the effective date of the change.

The current version of this Privacy Policy, with its effective date, is always accessible at https://zzcc.bio/privacy-policy. Your continued use of the zzcc platform following the effective date of any updated Policy constitutes your acknowledgment of the updated terms.

zzcc Casino has appointed a Data Protection Officer (DPO) as required under the Data Privacy Act of 2012. For all data privacy enquiries, rights requests, or concerns, you may contact the zzcc DPO through the following channels:

• Live Chat: Available 24/7 within the zzcc platform — request to speak with the Data Privacy team;
• Email: [email protected] (subject line: "Data Privacy Request")

zzcc aims to acknowledge all data privacy requests within two (2) business days and to resolve requests within fifteen (15) business days. If you are not satisfied with zzcc's response, you have the right to escalate your concern to the National Privacy Commission (NPC).