naga15 Casino Privacy Policy

1. Introduction

naga15 Casino operates the online gaming platform accessible at naga15.club (the "Platform"). As a data controller, naga15 determines the purposes and means of processing personal data collected through the Platform. We take our obligations under Philippine data privacy law seriously and have appointed a Data Protection Officer (DPO) to oversee compliance.

This Privacy Policy applies to all personal data collected from players, prospective players, and visitors to the naga15 Platform. It describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information. Please read this document carefully alongside our Terms & Conditions, which govern your use of the Platform.

If you have any questions about how naga15 handles your personal data, you may contact our Data Protection Officer at any time using the details provided in Section 14 of this Policy.

2. Scope & Application

This Privacy Policy applies to:

• All registered players and account holders on the naga15 Platform.
• Visitors who browse the naga15 website without registering.
• Individuals who contact naga15 customer support via live chat or email.
• Any person whose personal data is submitted to naga15 in connection with the Platform's services.

This Policy does not apply to third-party websites, services, or applications that may be linked to or from the naga15 Platform. naga15 is not responsible for the privacy practices of any third party, and we encourage you to review the privacy policies of any third-party services you access.

3. Personal Data We Collect

naga15 collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name
• Date of birth (for age verification — 21+ requirement)
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine passport, SSS/GSIS ID, PhilHealth ID, Voter's ID, Driver's License)
• Proof of address documents (e.g., utility bill, bank statement, barangay certificate)
• Proof of payment method (where required for withdrawal verification)
• Source-of-funds documentation (where required under AML regulations)

3.3 Financial & Transaction Data

• Deposit and withdrawal amounts and dates
• Payment method details (GCash number, Maya account, bank account details — stored in masked form)
• Transaction history and account balance records
• Bonus and promotional activity records

3.4 Gaming Activity Data

• Game history, bet amounts, and outcomes
• Session duration and login timestamps
• Responsible gaming tool usage (deposit limits, self-exclusion requests)
• Customer support interaction records

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Referring URL and pages visited on the Platform

4. How We Collect Your Data

naga15 collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment data from payment processors such as GCash, Maya, and partner banks.
• Regulatory sources: Data received from PAGCOR or other regulatory authorities in connection with licensing, compliance, or investigation requirements.

5. Purpose of Processing

naga15 processes your personal data for the following purposes:

6. Legal Basis for Processing

naga15 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improvement of our services, where such interests are not overridden by your rights.
• Consent: Processing for direct marketing communications, where we have obtained your explicit consent. You may withdraw consent at any time by contacting our support team or updating your account preferences.

7. Sharing Your Personal Data

naga15 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following circumstances:

• Service providers: Third-party vendors who assist us in operating the Platform, including KYC/identity verification providers, payment processors (GCash, Maya, partner banks), IT infrastructure providers, and customer support platforms. All service providers are bound by data processing agreements and may only use your data as instructed by naga15.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory directive.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a valid legal order, warrant, or subpoena.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of naga15's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.
• With your consent: Any other sharing of your personal data will only occur with your explicit prior consent.

8. Data Retention

naga15 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• KYC documents: Retained for a minimum of five (5) years after the end of the business relationship, or longer if required by regulatory directive.
• Gaming activity data: Retained for a minimum of three (3) years from the date of each gaming session.
• Marketing data: Retained until you withdraw consent or request deletion, whichever is earlier.
• Technical and device data: Retained for up to twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.

Upon expiry of the applicable retention period, naga15 will securely delete or anonymize your personal data in accordance with NPC-approved disposal methods.

9. Security Measures

naga15 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the naga15 Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including passwords and payment details, is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorized naga15 personnel on a strict need-to-know basis. All staff with access to personal data undergo regular data privacy training.
• Two-factor authentication: naga15 supports and encourages the use of two-factor authentication (2FA) for all player accounts to prevent unauthorized access.
• Regular security audits: The Platform undergoes regular penetration testing and security audits by independent third-party security firms.
• Incident response: naga15 maintains a documented data breach response plan. In the event of a personal data breach that poses a real risk to your rights and freedoms, we will notify the NPC and affected players within the timeframes prescribed by the Data Privacy Act.

10. Cookies & Tracking Technologies

naga15 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. A cookie is a small text file placed on your device when you visit the Platform.

Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences (such as language settings and responsible gaming limits) to provide a personalized experience.
• Analytics cookies: Collect anonymized data about how visitors use the Platform, helping us improve performance and user experience. No personally identifiable information is collected through analytics cookies.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. naga15 does not use cookies for third-party advertising or behavioral profiling.

11. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by naga15. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

naga15 will respond to all data privacy rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with notice provided to you.

12. Minors

The naga15 Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gambling regulations. naga15 does not knowingly collect personal data from persons under the age of 21.

If naga15 becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and return any deposited funds in accordance with applicable regulations.

If you are a parent or guardian and believe that your child has provided personal data to naga15, please contact our Data Protection Officer immediately using the details in Section 14 so that we can take appropriate action.

13. Changes to This Privacy Policy

naga15 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email and/or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The effective date at the top of this Policy will be updated whenever changes are made. Your continued use of the naga15 Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure in accordance with our Terms & Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how naga15 protects your personal data.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by naga15, please contact our Data Protection Officer:

• Data Protection Officer: naga15 Casino DPO
• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 on the naga15 Platform after login

All privacy-related inquiries will be acknowledged within forty-eight (48) hours and resolved within thirty (30) days. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.