zs77 Privacy Policy

1. Introduction

zs77 ("zs77", "we", "us", "the Platform") is committed to protecting the privacy and personal data of all users of zs77.app ("the Website"). This Privacy Policy ("Policy") describes how zs77 collects, processes, stores, shares, and protects information that identifies or could identify you ("personal data") when you access or use the zs77 Platform, create an account, make a deposit, play games, or otherwise interact with our services.

This Policy is issued in compliance with Republic Act No. 10173, known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations as administered by the National Privacy Commission ("NPC") of the Philippines. By using the zs77 Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy applies solely to data processed by zs77 through zs77.app. It does not cover the privacy practices of third-party game providers, payment processors, or any other external services that may be accessible through the Platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, zs77 is the personal information controller responsible for the personal data collected and processed through the zs77 Platform. Our designated Data Protection Officer ("DPO") can be contacted at the email address stated in Section 15 of this Policy.

Where zs77 engages third parties to process personal data on its behalf — for example, payment service providers or identity verification platforms — those parties act as personal information processors under written agreements that require them to process your data only on zs77's documented instructions and in compliance with applicable Philippine privacy law.

3. Personal Data We Collect

zs77 collects the following categories of personal data, to the extent necessary for the purposes described in Section 6:

• Registration data: Full name, date of birth, email address, and account password (stored as a cryptographic hash).
• Identity verification (KYC) data: Government-issued Philippine ID (e.g., PhilSys ID, passport, driver's licence), proof of residential address, and selfie or liveness verification image, collected in compliance with PAGCOR's Know Your Customer requirements.
• Financial data: Payment method details (e.g., GCash account number, BPI/BDO account details), transaction history, deposit and withdrawal records. Full payment card or bank account numbers are not stored by zs77 — they are handled directly by our licensed payment processors.
• Device and technical data: IP address, device type and operating system, browser type and version, session timestamps, and geographic location data derived from IP address.
• Usage and behavioural data: Game play history, wagering patterns, bonus redemption history, login frequency, and on-site navigation activity.
• Communications data: Content of communications submitted to our support team via chat or email, including account queries, complaints, and responsible gaming requests.
• Marketing preferences: Email communication opt-in or opt-out status and promotional interaction history.

4. How We Collect Personal Data

zs77 collects personal data through the following means:

• Directly from you when you register an account, complete KYC verification, make a deposit, submit a withdrawal request, or contact support;
• Automatically through the use of cookies, server logs, and similar tracking technologies when you access or navigate zs77.app;
• From third parties including identity verification service providers (who confirm the authenticity of identity documents), payment processors (who confirm transaction status), and fraud detection services.

5. Legal Basis for Processing

zs77 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to register your account, process deposits and withdrawals, and deliver the gaming services you have contracted for;
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, anti-money laundering obligations under Republic Act No. 9160 (AMLA), and NPC regulatory requirements;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where such interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit opt-in consent. You may withdraw this consent at any time.

6. How We Use Your Personal Data

zs77 uses the personal data it collects for the following purposes:

• To create, verify, and maintain your zs77 account and provide access to the Platform;
• To process deposits, withdrawals, and bonus credits;
• To conduct identity verification and age verification in compliance with PAGCOR regulations — including the mandatory 21+ age requirement;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited conduct as defined in the zs77 Terms & Conditions;
• To monitor gameplay patterns for responsible gaming purposes and to apply deposit limits, session limits, or self-exclusion as requested or required;
• To respond to customer support enquiries and resolve disputes;
• To send transactional communications (deposit confirmations, withdrawal notifications, security alerts) — these cannot be opted out of while your account is active;
• To send promotional communications about zs77 offers and games, subject to your marketing preferences;
• To improve Platform performance, game selection, and user experience through aggregated analytics.

7. Sharing Your Personal Data

zs77 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly as necessary:

• Payment service providers (GCash, Maya, BDO, BPI, Metrobank, UnionBank, and others) to process deposits and withdrawals;
• Identity verification providers to conduct KYC and age verification;
• Game providers (Pragmatic Play, PG Soft, Evolution, and others) to the extent required to deliver their games to your session — typically limited to a session token and game history;
• Fraud prevention and security services that assist zs77 in detecting and preventing prohibited conduct;
• Regulatory and law enforcement authorities including PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission, where disclosure is required by law or court order;
• Professional advisers including legal counsel and auditors, under strict confidentiality obligations.

All third-party processors engaged by zs77 are required to process personal data only on zs77's written instructions, implement appropriate technical and organisational security measures, and comply with the Data Privacy Act of 2012.

8. Cookies and Tracking Technologies

zs77.app uses cookies and similar technologies to operate the Platform and, with your consent, to analyse usage patterns. The categories of cookies used are:

• Strictly necessary cookies: Required for login session management, security token storage, and basic Platform functionality. These cannot be disabled without impairing the functionality of the site;
• Analytics cookies: Used to collect aggregated, anonymised data about how users navigate the Platform. This data helps us identify performance issues and improve the user experience. These are only set with your consent;
• Preference cookies: Store your language, display, and notification preferences to personalise your experience across sessions.

You can manage or delete cookies at any time through your browser settings. Note that disabling strictly necessary cookies will prevent access to your zs77 account. For further information on managing cookies, consult your browser's help documentation.

9. Data Security

zs77 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and zs77.app;
• Encryption of sensitive data at rest, including identity documents and KYC records;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Multi-factor authentication requirements for internal systems accessing personal data.

Notwithstanding these measures, no internet transmission or electronic storage method is completely secure. In the event of a personal data breach that is likely to result in serious harm, zs77 will notify affected individuals and the National Privacy Commission within the timeframes prescribed by the Data Privacy Act and its implementing rules.

10. Data Retention

zs77 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC records: Retained for a minimum of 5 years following account closure, as required by Republic Act No. 9160 (AMLA) and PAGCOR licence conditions;
• Transaction records: Retained for a minimum of 5 years following each transaction date for financial compliance and dispute resolution purposes;
• Support communications: Retained for 3 years following resolution of each support ticket;
• Marketing data: Deleted upon unsubscription from marketing communications or within 30 days of account closure, whichever is earlier;
• Analytics data: Anonymised or deleted within 24 months of collection.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with zs77's data disposal procedures.

11. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by zs77:

• Right to be informed: The right to be notified of how your personal data is collected and processed, as set out in this Policy;
• Right of access: The right to request a copy of the personal data zs77 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, subject to zs77's legal obligations to retain certain records;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to object: The right to object to processing based on legitimate interests, including profiling for marketing purposes;
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our Data Protection Officer at the details provided in Section 15. We will respond to all verifiable requests within 15 business days. We may need to verify your identity before processing a request.

12. Children's Privacy

The zs77 Platform is strictly prohibited for use by any person under the age of 21 years, in accordance with PAGCOR regulations governing online gaming in the Philippines. zs77 does not knowingly collect personal data from individuals under 21 years of age. If we become aware that a user is under 21, we will immediately suspend the account, void any associated balance or bonus credits, and delete all personal data associated with the account.

If you believe that a person under 21 has registered on the zs77 Platform, please contact support immediately at the address in Section 15.

13. International Data Transfers

zs77's primary infrastructure is located within the Asia-Pacific region. In some circumstances, personal data may be transferred to or accessed by third-party service providers located outside the Philippines — for example, game providers with servers in Europe or identity verification providers with operations in other jurisdictions.

Where such transfers occur, zs77 ensures that the receiving party provides a comparable level of data protection, either through contractual safeguards (standard data protection clauses), the recipient's adherence to a recognised data protection framework, or other lawful transfer mechanisms recognised under the Data Privacy Act and NPC guidance.

14. Changes to This Privacy Policy

zs77 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, Platform functionality, or our data processing practices. Material changes will be communicated to registered users by email to the address on file at least 7 days prior to the revised Policy taking effect. The "Last updated" date at the top of this page reflects the date of the most recent revision.

Your continued use of the zs77 Platform after the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree to the revised Policy, you must close your account before the effective date.

15. Contact and Data Protection Officer

For any privacy-related enquiries, requests to exercise your data rights, or concerns about how zs77 processes your personal data, please contact our Data Protection Officer:

Email: [email protected] (plain text — not a clickable link)

Please include "Privacy Request" or "DPO" in the subject line of your message to ensure your enquiry reaches the correct team. We aim to acknowledge all privacy-related correspondence within 3 business days and provide a substantive response within 15 business days.

If you are not satisfied with zs77's response to a privacy complaint, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines.