Privacy Policy

1. Introduction

1.1 sportzino is committed to protecting the privacy and personal data of all players on its Platform. This Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

1.2 This Policy applies to all personal data collected through the sportzino website, mobile-optimised site, customer support channels, and any other touchpoint through which you interact with sportzino.

1.3 Please read this Policy carefully. If you have questions about how sportzino handles your personal data, contact our Data Protection Officer using the details in Section 15.

2. Data Controller

2.1 sportzino is the data controller responsible for the personal data collected through the Platform. As data controller, sportzino determines the purposes and means of processing your personal data.

2.2 sportzino has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 15.

3. Data We Collect

3.1 sportzino collects the following categories of personal data:

Category	Examples	Source
Identity Data	Full name, date of birth, government-issued ID number, nationality	Provided by you at registration or KYC
Contact Data	Email address, mobile number, residential address (city, province)	Provided by you at registration
Financial Data	GCash number, bank account details (BPI, BDO, Metrobank), PayMaya account, transaction history	Provided by you during deposit/withdrawal
Technical Data	IP address, browser type and version, device type, operating system, time zone, screen resolution	Collected automatically when you access the Platform
Usage Data	Pages visited, games played, session duration, click paths, search queries within the Platform	Collected automatically via cookies and server logs
Gameplay Data	Wager amounts, game outcomes, bonus usage, win/loss history, responsible gaming tool usage	Generated automatically through Platform activity
Communications Data	Live chat transcripts, support ticket content, email correspondence with sportzino	Provided by you when contacting support

3.2 sportzino does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where health-related information is voluntarily provided in the context of a responsible gaming self-exclusion request.

3.3 Where you choose not to provide personal data that sportzino requires to fulfil a legal obligation or to perform a contract with you (such as identity verification), sportzino may be unable to provide certain services or may be required to restrict or close your account.

4. How We Use Your Data

4.1 sportzino uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your sportzino account, including verifying your identity and age (21+ requirement) in compliance with Philippine gaming regulations.
• Service delivery: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods; to provide access to games including slots, bingo, keno, and live casino; and to deliver customer support.
• Legal compliance: To comply with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, PAGCOR reporting obligations, and other applicable Philippine laws and regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorised account access, bonus abuse, and other prohibited conduct.
• Responsible gaming: To monitor gameplay patterns for signs of problem gambling, to administer deposit limits, cooling-off periods, and self-exclusion requests, and to fulfil our duty of care obligations.
• Platform improvement: To analyse usage patterns, conduct A/B testing, and improve the functionality, performance, and user experience of the sportzino Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent or where we have a legitimate interest in doing so. You may opt out at any time.
• Dispute resolution: To investigate and resolve disputes, complaints, and chargebacks relating to your sportzino account.

5. Legal Basis for Processing

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

• Contractual necessity: Processing is necessary to perform the contract between you and sportzino — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, PAGCOR licensing requirements, and NPC guidelines.
• Legitimate interests: Processing is necessary for sportzino's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and non-essential cookies, sportzino relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 sportzino does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

6.2 sportzino may share your personal data with the following categories of recipients:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, solely to facilitate deposits and withdrawals on your behalf.
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory obligations.
• Fraud prevention and security services: Providers of fraud detection, device fingerprinting, and cybersecurity services that help protect the integrity of the Platform.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies, where disclosure is required by law or court order.
• Professional advisers: Lawyers, auditors, and accountants engaged by sportzino, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of sportzino's business assets, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

6.3 All third-party service providers engaged by sportzino are contractually required to process your personal data only on sportzino's instructions and in accordance with applicable data protection laws.

7. International Data Transfers

7.1 Some of sportzino's service providers may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection, sportzino will implement appropriate safeguards — such as standard contractual clauses approved by the National Privacy Commission — to ensure your data remains protected.

7.2 By using the sportzino Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described in this section.

8. Cookies and Tracking Technologies

8.1 sportzino uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your sportzino account. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the Platform, helping sportzino identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Marketing cookies: Used to deliver relevant promotional content within the Platform. These are only set with your consent.

8.2 You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the sportzino Platform.

8.3 sportzino does not use cross-site tracking cookies or share cookie data with third-party advertisers outside the Platform.

9. Data Security

9.1 sportzino implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS encryption for all data in transit between your device and sportzino's servers;
• AES-256 encryption for sensitive data stored at rest;
• Multi-factor authentication for sportzino staff accessing internal systems;
• Regular penetration testing and vulnerability assessments;
• Strict role-based access controls limiting data access to authorised personnel only;
• Incident response procedures for detecting and responding to data breaches.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, sportzino will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where required by law.

9.3 While sportzino takes all reasonable steps to protect your data, no internet transmission is completely secure. You are responsible for keeping your sportzino login credentials confidential and for notifying sportzino immediately if you suspect unauthorised access to your account.

10. Data Retention

10.1 sportzino retains your personal data for as long as your account remains active and for a minimum period after account closure as required by applicable law. The following retention periods apply:

• Account and identity data: Retained for a minimum of five years after account closure, in compliance with Philippine AML regulations.
• Transaction records: Retained for a minimum of five years, and potentially longer where required by PAGCOR or AMLC regulations.
• Customer support communications: Retained for three years from the date of the last interaction.
• Technical and usage data: Retained for up to 24 months in identifiable form, after which it is anonymised or deleted.
• Marketing consent records: Retained for the duration of your account and for three years after withdrawal of consent.

10.2 Where sportzino is required to retain data beyond these periods due to a legal dispute, regulatory investigation, or court order, the data will be retained until the matter is resolved.

11. Your Data Rights

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

• Right to be informed: You have the right to be informed about how sportzino collects and uses your personal data, as set out in this Policy.
• Right of access: You may request a copy of the personal data sportzino holds about you, along with information about how it is being processed.
• Right to rectification: You may request correction of inaccurate or incomplete personal data. You can update basic account information directly through your sportzino account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to sportzino's legal retention obligations.
• Right to object: You may object to processing based on legitimate interests, including direct marketing. Where you object to marketing, sportzino will cease processing your data for that purpose immediately.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe sportzino has violated your data privacy rights.

11.2 To exercise any of these rights, please contact sportzino's Data Protection Officer using the details in Section 15. sportzino will respond to all verified requests within 30 days. In complex cases, this period may be extended by a further 30 days, and you will be notified accordingly.

11.3 sportzino may need to verify your identity before processing a data rights request to ensure that personal data is not disclosed to an unauthorised party.

12. Children and Minors

12.1 The sportzino Platform is strictly for users aged 21 years and above. sportzino does not knowingly collect personal data from individuals under the age of 21.

12.2 If sportzino becomes aware that personal data has been collected from a person under 21 years of age, the associated account will be immediately closed, all data will be deleted or anonymised to the extent permitted by law, and any deposits will be returned to the originating payment method where possible.

12.3 If you believe that a minor has registered on the sportzino Platform, please contact our support team immediately so that appropriate action can be taken.

13. Third-Party Links

13.1 The sportzino Platform may contain links to third-party websites or services for informational purposes. sportzino is not responsible for the privacy practices of any third-party website. We encourage you to review the privacy policy of any external site you visit.

13.2 The inclusion of a link to a third-party site does not constitute an endorsement by sportzino of that site or its content.

14. Updates to This Policy

14.1 sportzino may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or Platform features. The date of the most recent revision is displayed at the top of this page.

14.2 Where changes are material, sportzino will notify registered players via the email address on file or via a prominent notice on the Platform at least 14 days before the changes take effect.

14.3 Your continued use of the sportzino Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not accept the updated Policy, you must close your account before the effective date.

15. Contact and Complaints

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or sportzino's data practices, please contact our Data Protection Officer:

Data Protection Officer — sportzino
Email: [email protected]
General Support: [email protected]

15.2 sportzino will acknowledge your request within five business days and provide a substantive response within 30 days.

15.3 If you are not satisfied with sportzino's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC can be reached through its official government channels.