zpjili Privacy Policy: Protecting Your Personal Information

1. Introduction and Scope

This Privacy Policy (hereinafter "Policy") describes how zpjili ("we," "us," "our," or the "Company") collects, uses, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use our online gaming platform, website located at https://zpjili.cam, mobile applications, and related services (collectively, the "Services").

zpjili is committed to protecting your privacy and ensuring the security of your personal data in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its implementing rules and regulations, issuances of the National Privacy Commission (NPC), and other applicable Philippine laws. As a PAGCOR-licensed online gaming operator, we also adhere to gaming industry standards for data protection and responsible gaming practices.

By registering for an account, accessing our website, or using zpjili Services, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Policy. If you do not agree with the terms of this Policy, you must immediately discontinue use of zpjili Services.

2. Information We Collect

zpjili collects various categories of personal information necessary to provide our gaming services, ensure platform security, comply with legal obligations, and enhance user experience. The information we collect includes:

2.1 Information You Provide Directly

Registration Information: When you create a zpjili account, we collect:

• Full legal name as it appears on government-issued identification
• Date of birth
• Gender
• Residential address (street, barangay, city/municipality, province, postal code)
• Email address
• Mobile phone number
• Username and password
• Preferred currency (typically Philippine Peso)
• Security questions and answers for account recovery

Identity Verification Documents: To comply with age verification, anti-money laundering (AML), and know-your-customer (KYC) requirements, we collect:

• Government-issued photo identification (Driver's License, Passport, UMID, SSS ID, Postal ID, Voter's ID, PRC ID, or other valid Philippine government IDs)
• Selfie photographs for biometric verification
• Proof of address documents (utility bills, bank statements, or government correspondence dated within the last three months)
• Source of funds documentation for high-value transactions (employment certificates, business registration documents, tax returns, or bank statements)

Payment Information: When you deposit or withdraw funds, we collect:

• Payment method details (GCash number, Maya account name, bank account number, cryptocurrency wallet address)
• Transaction amounts, dates, and times
• Payment provider transaction reference numbers
• Billing information associated with your payment accounts

Communications: When you contact zpjili customer support, we collect:

• Content of your messages, emails, live chat conversations, and phone calls
• Customer service tickets and case histories
• Feedback, complaints, and survey responses
• Call recordings for quality assurance and training purposes (you will be notified when calls are recorded)

2.2 Information Collected Automatically

Technical and Usage Data: When you access zpjili Services, we automatically collect:

• IP address and approximate geographic location (city-level)
• Device information (device type, operating system, browser type and version, screen resolution)
• Unique device identifiers and mobile advertising IDs
• Log data (access times, pages viewed, click-through patterns, referring/exit URLs)
• Gaming activity (games played, bets placed, wins and losses, bonus usage, session duration)
• Login and logout times, account authentication events
• Network connection type and internet service provider information

Cookies and Similar Technologies: We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your browsing behavior and preferences. See Section 8 for detailed information about our use of cookies.

2.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment processors (GCash, Maya, banks) providing transaction verification and fraud detection services
• Identity verification services confirming the authenticity of submitted documents
• Game providers tracking gameplay statistics and jackpot contributions
• Marketing partners (where you have consented to sharing your information)
• PAGCOR's National Self-Exclusion Registry
• Credit reference agencies and fraud prevention databases

3. How We Use Your Information

zpjili uses the personal information we collect for the following purposes:

3.1 Service Provision and Account Management

• Creating and maintaining your zpjili account
• Verifying your identity, age, and eligibility to use gaming services
• Processing deposits, withdrawals, and other financial transactions
• Providing access to casino games, sports betting, and other gaming products
• Managing bonuses, promotions, and loyalty program rewards
• Processing refunds, resolving disputes, and handling customer inquiries
• Authenticating your login credentials and securing your account

3.2 Legal Compliance and Regulatory Obligations

• Complying with PAGCOR licensing requirements and gaming regulations
• Fulfilling Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) obligations under Philippine law
• Conducting Know Your Customer (KYC) due diligence and enhanced due diligence procedures
• Preventing underage gambling and enforcing age restrictions (21+ years)
• Implementing responsible gaming measures and identifying problem gambling behaviors
• Responding to legal requests from law enforcement, regulatory authorities, and courts
• Maintaining records as required by Philippine gaming and tax laws

3.3 Security and Fraud Prevention

• Detecting and preventing fraudulent activities, money laundering, and other illegal conduct
• Monitoring for suspicious betting patterns, collusion, and bonus abuse
• Protecting against unauthorized access, hacking, and cyber attacks
• Verifying the legitimacy of payment methods and transactions
• Enforcing our Terms and Conditions and acceptable use policies
• Investigating potential violations of gaming rules or platform policies

3.4 Platform Improvement and Analytics

• Analyzing usage patterns to improve website and mobile app functionality
• Conducting market research to understand player preferences
• Testing new features, games, and promotional offerings
• Optimizing user interface design and navigation
• Measuring the effectiveness of marketing campaigns
• Generating aggregated and anonymized statistics about platform usage

3.5 Marketing and Communications

• Sending promotional offers, bonuses, and exclusive deals (with your consent)
• Notifying you about new games, features, and platform updates
• Delivering personalized recommendations based on your gaming preferences
• Inviting participation in tournaments, competitions, and special events
• Sending transactional emails (account verification, password resets, withdrawal confirmations)
• Providing customer support notifications and service announcements

4. Legal Basis for Processing

Under the Philippine Data Privacy Act, zpjili processes your personal information based on the following legal grounds:

• Consent: You have provided explicit consent for specific processing activities such as marketing communications and optional data collection.
• Contract Performance: Processing is necessary to fulfill our contractual obligations to provide gaming services under our Terms and Conditions.
• Legal Obligation: Processing is required to comply with Philippine laws, PAGCOR regulations, AML/KYC requirements, and tax obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests in fraud prevention, security, platform improvement, and customer service, provided these interests do not override your fundamental rights and freedoms.
• Vital Interests: Processing is necessary to protect your vital interests or those of another person, such as in emergency situations requiring disclosure to medical or law enforcement authorities.

5. Data Sharing and Disclosure

zpjili does not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your information only in the following limited circumstances:

5.1 Service Providers and Business Partners

We share information with trusted third-party service providers who perform services on our behalf, including:

• Payment Processors: GCash, Maya, banks, and cryptocurrency payment gateways processing deposits and withdrawals
• Identity Verification Services: Third-party providers conducting document verification and biometric authentication
• Game Providers: Software developers and game studios powering our slot games, live casino, and sports betting products
• Cloud Hosting Services: Data centers and cloud infrastructure providers storing and processing information
• Customer Support Platforms: Live chat, email, and ticketing systems facilitating player communications
• Marketing and Analytics Tools: Platforms measuring campaign performance and user engagement (with your consent)
• Fraud Prevention Services: Third-party systems detecting suspicious activities and preventing fraudulent transactions

All service providers are contractually bound to protect your data, use it only for the specified purposes, and comply with applicable data protection laws.

5.2 Regulatory Authorities and Law Enforcement

We may disclose your information to government agencies, regulators, and law enforcement when required by law or when we believe in good faith that disclosure is necessary to:

• Comply with PAGCOR regulatory requirements and gaming license conditions
• Respond to court orders, subpoenas, or legal process
• Cooperate with law enforcement investigations into suspected illegal activities
• Report suspicious transactions under AML/CTF obligations
• Protect the rights, property, and safety of zpjili, our players, or the public
• Enforce our Terms and Conditions and prevent fraud or abuse

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor company. We will notify you of any such change in ownership and provide you with choices regarding your information.

5.4 With Your Consent

We may share your information with third parties when you have provided explicit consent for such sharing, such as when you authorize us to share information with marketing partners or participate in third-party promotions.

6. Data Security Measures

zpjili implements comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction:

6.1 Technical Security

• Encryption: All data transmissions between your device and our servers are protected by 256-bit SSL/TLS encryption
• Secure Storage: Personal information is stored in encrypted databases with access controls and regular security audits
• Firewall Protection: Multi-layer firewall systems prevent unauthorized network access
• Intrusion Detection: Real-time monitoring systems detect and respond to potential security breaches
• Two-Factor Authentication: Optional 2FA adds an extra layer of account protection
• Regular Security Testing: Penetration testing and vulnerability assessments conducted quarterly

6.2 Administrative Security

• Access Controls: Strict need-to-know policies limit employee access to personal information
• Staff Training: Regular training on data protection, privacy, and security best practices
• Background Checks: Screening of employees with access to sensitive data
• Confidentiality Agreements: All staff sign non-disclosure agreements protecting player information
• Incident Response Plan: Documented procedures for responding to data breaches or security incidents

6.3 Physical Security

• Data centers with 24/7 physical security, access controls, and surveillance
• Redundant power supplies and backup systems ensuring data availability
• Regular data backups stored in geographically separate secure locations

While we implement industry-standard security measures, no method of transmission over the internet or electronic storage is 100% secure. You also have a responsibility to protect your account by choosing a strong password, keeping it confidential, and logging out when using shared devices.

7. Your Privacy Rights

Under the Philippine Data Privacy Act, you have the following rights regarding your personal information:

7.1 Right to Be Informed

You have the right to be informed about the collection, use, and disclosure of your personal data. This Privacy Policy serves to inform you of our data processing activities.

7.2 Right to Access

You have the right to obtain from zpjili confirmation of whether we are processing your personal data and, if so, to request access to that data. You can view much of your information directly in your account dashboard.

7.3 Right to Object

You have the right to object to the processing of your personal data on grounds relating to your particular situation. You also have the absolute right to object to direct marketing at any time by using the unsubscribe link in emails or contacting customer support.

7.4 Right to Erasure or Blocking

You have the right to request erasure or blocking of your personal data when it is no longer necessary for the purposes collected, you withdraw consent, you object to processing, or the data was unlawfully processed. Note that we may retain certain information to comply with legal obligations or for legitimate business purposes.

7.5 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. You can update many details directly in your account settings or by contacting customer support.

7.6 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller where technically feasible.

7.7 Right to Damages

You have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.

7.8 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with "Privacy Rights Request" in the subject line. We will respond to your request within fifteen (15) business days as required by Philippine law. We may request additional information to verify your identity before processing your request.

8. Cookies and Tracking Technologies

zpjili uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content.

8.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for basic website functionality, account authentication, and security. Cannot be disabled.	Session or 1 year
Performance Cookies	Collect information about how you use our website to improve performance and user experience.	1-2 years
Functionality Cookies	Remember your preferences such as language, currency, and game favorites.	1 year
Marketing Cookies	Track visits across websites to deliver relevant advertisements and measure campaign effectiveness.	1-2 years

8.2 Managing Cookie Preferences

You can control cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or receive notification before cookies are stored. Note that disabling essential cookies may prevent you from using certain features of zpjili Services.

To opt out of marketing cookies, you can adjust your preferences in our cookie banner or contact customer support. Opting out of marketing cookies does not prevent you from seeing advertisements; it means the ads you see will be less relevant to your interests.

9. Data Retention

zpjili retains your personal information for as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

9.1 Account Data

Active account information is retained for the duration of your relationship with zpjili. If you close your account, we will retain your data for a minimum of seven (7) years to comply with PAGCOR regulatory requirements, tax laws, and AML obligations.

9.2 Transaction Records

Financial transaction records (deposits, withdrawals, bets, wins) are retained for a minimum of seven (7) years in compliance with Philippine gaming regulations and tax laws.

9.3 Identity Verification Documents

KYC documents and identity verification records are retained for seven (7) years after account closure or the last transaction, whichever is later, to comply with AML/CTF obligations.

9.4 Marketing and Communications Data

Marketing preferences and communication history are retained until you withdraw consent or for two (2) years after your last interaction with zpjili, whichever comes first.

9.5 Technical and Log Data

System logs, IP addresses, and technical data are typically retained for one (1) to two (2) years for security monitoring and fraud prevention purposes.

After the applicable retention period expires, personal information is securely deleted or anonymized so that it can no longer be associated with you.

10. International Data Transfers

zpjili primarily processes and stores data within the Republic of the Philippines. However, some of our service providers and technology partners may be located outside the Philippines, including in countries that may not have data protection laws equivalent to Philippine standards.

When we transfer personal information internationally, we implement appropriate safeguards to protect your data, including:

• Standard contractual clauses approved by data protection authorities
• Ensuring service providers maintain adequate data protection standards
• Limiting data transfers to what is necessary for service provision
• Conducting due diligence on the privacy practices of international partners

By using zpjili Services, you consent to the transfer of your information to jurisdictions outside the Philippines where necessary to provide our services, subject to the safeguards described in this Policy.

11. Children's Privacy

zpjili Services are not intended for individuals under twenty-one (21) years of age. We do not knowingly collect personal information from minors. Our age verification procedures are designed to prevent underage access to gaming services.

If we become aware that we have inadvertently collected personal information from a person under 21 years of age, we will take immediate steps to delete such information and permanently close the account. Parents or guardians who believe their child has provided personal information to zpjili should contact us immediately at [email protected].

We encourage parents and guardians to monitor their children's internet usage and use parental control tools to prevent minors from accessing online gaming websites.

12. Changes to This Privacy Policy

zpjili reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated to you through:

• Email notification to your registered email address
• Prominent notice on our website homepage
• Pop-up notification upon login to your account
• Update to the "Last Reviewed" date at the top of this Policy

Your continued use of zpjili Services after any changes to this Policy constitutes acceptance of the revised terms. If you do not agree with the updated Policy, you must discontinue use of our Services and may close your account by contacting customer support.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

13. Contact Information

If you have questions, concerns, or complaints regarding this Privacy Policy or our data processing practices, please contact us:

If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines:

National Privacy Commission
5th Floor, Philippine International Convention Center (PICC),
Vicente Sotto Street, Pasay City, Metro Manila, Philippines
Website: privacy.gov.ph
Email: [email protected]
Hotline: (02) 8234-2228