Privacy Policy

01 Introduction

This Privacy Policy (the "Policy") is issued by zonafilm21 (the "Platform", "we", "us", or "our"), the operator of the online casino and sports betting service accessible at https://zonafilm21.cam. This Policy sets out the basis on which we process personal data that we collect from our users ("Players", "you", or "your") in connection with the use of the Platform and its associated services.

We are committed to protecting your personal data and to processing it in a manner that is fair, transparent, and consistent with applicable data protection law. We encourage you to read this Policy carefully and in its entirety before using the Platform. By registering an account or using any part of the zonafilm21 Platform, you acknowledge that you have read and understood this Policy.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, all of which govern your relationship with zonafilm21.

02 Definitions

In this Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person — i.e., a Player whose identity can be determined directly or indirectly.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, erasure, or destruction.
• "Data Controller" means zonafilm21, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third-party entity that processes Personal Data on behalf of zonafilm21, subject to a data processing agreement.
• "Cookies" means small text files placed on your device by the Platform for functionality, security, and analytics purposes.
• "KYC" means Know Your Customer — the identity verification process that we are required to conduct to comply with anti-money-laundering and age verification obligations.
• "Sensitive Data" means a special category of Personal Data requiring heightened protection, such as biometric data used for identity verification or data relating to health or gambling behaviour.

03 Personal Data We Collect

zonafilm21 collects and processes the following categories of personal data in connection with your use of the Platform:

We do not intentionally collect Sensitive Data beyond what is necessary for KYC purposes. We do not collect information about racial or ethnic origin, political opinions, religious beliefs, trade union membership, or health conditions except where specifically required by applicable regulation.

04 How We Collect Your Data

zonafilm21 collects personal data through the following channels and mechanisms:

• Direct Interactions: Data you provide when registering an account, completing KYC verification, making a deposit, submitting a withdrawal request, contacting support via live chat or email, or participating in surveys or promotions.
• Automated Technical Collection: Data collected automatically when you access the Platform, including your IP address, device identifiers, browser characteristics, and navigation behaviour, collected via server logs and first-party cookies.
• Payment Processors: Transaction data shared with us by payment service providers including Touch 'n Go eWallet, Boost, GrabPay, DuitNow/FPX partner banks (Maybank, CIMB, Public Bank, Hong Leong), and cryptocurrency wallet services (USDT TRC20), to the extent necessary to confirm and process your transactions.
• Identity Verification Partners: KYC-specific data collected and verified through our identity verification service providers as part of the account verification process.
• Third-Party Game Providers: Gameplay data from our licensed game providers (slot studios, live dealer operators, sportsbook data feeds) to the extent required for dispute resolution and responsible gambling monitoring.

05 Purposes of Processing

We process your personal data for the following specific purposes:

• Account Management: To register, maintain, and administer your Player Account, including authentication and profile management.
• Transaction Processing: To process deposits and withdrawals in MYR and cryptocurrency, reconcile accounts, and maintain financial records.
• KYC & Regulatory Compliance: To verify your identity and age (minimum 21 years), comply with anti-money-laundering (AML) obligations, and satisfy reporting requirements to our licensing authority.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, collusion, and other prohibited conduct.
• Responsible Gambling: To monitor gameplay patterns for indicators of problem gambling, enforce deposit limits and self-exclusion restrictions, and support player protection programmes.
• Customer Support: To respond to your enquiries, resolve disputes, and improve the quality of our support services.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve Platform performance, usability, and feature development.
• Marketing Communications: To send you promotional communications about zonafilm21 products, bonuses, and events, subject to your marketing preferences. You may opt out at any time.
• Legal Obligations: To comply with applicable laws, court orders, regulatory requests, or other legal obligations that require us to process or disclose your data.

06 Legal Basis for Processing

Each category of data processing carried out by zonafilm21 rests on one or more of the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and zonafilm21 — i.e., the Terms and Conditions you accepted upon registration. This covers account management, transaction processing, and support.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML, KYC, age verification, and licensing authority requirements.
• Legitimate Interests: Processing pursued for our legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring, and anonymised analytics — provided those interests are not overridden by your fundamental privacy rights.
• Consent: Processing based on your express, informed, and freely given consent — specifically in relation to optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

07 Data Sharing & Third Parties

zonafilm21 does not sell, rent, or trade your personal data to third-party marketers or data brokers under any circumstances. We share personal data only with the following categories of recipients, and only to the extent strictly necessary:

• Payment Service Providers: Touch 'n Go eWallet, Boost, GrabPay, DuitNow/FPX bank partners, and cryptocurrency processors — for the sole purpose of completing your transactions.
• Identity Verification Providers: Third-party KYC and document verification services engaged to fulfil our age verification and AML obligations.
• Game Content Providers: Licensed game studios and live dealer operators who provide content on our Platform, to the extent required for gameplay operation and dispute resolution.
• Cloud & Infrastructure Providers: Hosting, database, and network security providers operating under contractual data processing agreements.
• Regulatory & Legal Authorities: Our licensing authority, law enforcement agencies, financial intelligence units, or courts, where disclosure is required by law or order.
• Professional Advisers: Legal, audit, or compliance professionals engaged under strict confidentiality obligations.

All third-party Data Processors engaged by zonafilm21 are subject to binding contractual obligations requiring them to process your data only for specified purposes, to maintain appropriate security measures, and to comply with applicable data protection law.

08 International Data Transfers

zonafilm21 operates internationally and may transfer your personal data to countries outside of Malaysia in connection with the operation of the Platform. Where such transfers occur, we ensure that appropriate safeguards are in place, including:

• Transfers to countries recognised as providing an adequate level of data protection by applicable standards.
• Use of standard contractual clauses or equivalent data transfer mechanisms with the receiving entity.
• Implementation of supplementary technical and organisational measures where required to ensure equivalent protection.

If you require further information about the safeguards in place for any specific international data transfer, please contact us at the details provided in Section 16 of this Policy.

09 Data Retention

We retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your active account relationship with zonafilm21.
• Post-Closure Account Data: Following account closure (voluntary or enforced), we retain account records, identity documents, and transaction histories for a minimum of five (5) years to comply with AML and licensing authority obligations.
• KYC Documents: Retained for a minimum of five (5) years from the date of submission, in accordance with applicable financial regulation.
• Gameplay & Transaction Records: Retained for a minimum of five (5) years for dispute resolution, regulatory audit, and responsible gambling monitoring purposes.
• Support & Communication Logs: Retained for up to three (3) years for quality assurance and dispute resolution purposes.
• Anonymised Analytics Data: May be retained indefinitely, as it does not constitute personal data once appropriately anonymised.

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

10 Security Measures

zonafilm21 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure:

• Encryption in Transit: All communications between your device and our servers are protected by TLS 1.2/1.3 (256-bit SSL encryption).
• Encryption at Rest: Sensitive data fields including financial information, identity documents, and authentication credentials are encrypted at rest using AES-256 or equivalent encryption standards.
• Access Controls: Strict role-based access control limits employee access to personal data on a strict need-to-know basis. All internal access is logged and audited.
• Intrusion Detection: Automated monitoring systems detect and alert on anomalous access patterns, potential data exfiltration, and security incidents in real time.
• Penetration Testing: Our Platform undergoes regular independent security assessments and penetration testing to identify and remediate vulnerabilities.
• Incident Response: We maintain a documented data breach response procedure. In the event of a breach affecting your personal data, we will notify affected players and relevant authorities within the timeframes required by applicable law.

11 Cookies & Tracking Technologies

zonafilm21 uses cookies and similar tracking technologies on the Platform for the following strictly defined purposes:

• Strictly Necessary Cookies: Required for the Platform to function correctly. These include session authentication tokens, security cookies, and load-balancing identifiers. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Store your preferences such as language settings, game display preferences, and responsible gambling tool configurations to improve your experience on return visits.
• Performance & Analytics Cookies: First-party cookies that collect anonymised information about how you navigate the Platform — pages visited, time on page, error events — to help us improve Platform performance. No personally identifiable information is included in this data.

zonafilm21 does not use third-party advertising cookies, cross-site tracking pixels, or social media tracking technologies. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair your ability to use the Platform.

12 Minors & Age Verification

The zonafilm21 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. Age verification is a mandatory component of our KYC process and is conducted before a Player Account becomes fully active.

If we become aware that personal data has been collected from an individual under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has accessed the Platform or provided personal data to us, please contact our support team immediately at the email address provided in Section 16 of this Policy.

13 Your Data Rights

Subject to applicable data protection law and any overriding legal obligations (including our AML and KYC retention requirements), you have the following rights in respect of your personal data held by zonafilm21:

To exercise any of the above rights, please contact our Data Privacy team via the live support channel or by email. We will respond to all valid requests within thirty (30) calendar days. We may request proof of identity before processing certain requests to protect against unauthorised data access.

Please note that certain rights may be limited or overridden by our obligations under AML, KYC, and gaming licensing regulations, which require us to retain specific data for defined minimum periods regardless of a deletion or restriction request.

14 Complaints & Dispute Resolution

If you believe that zonafilm21 has processed your personal data in a manner that does not comply with this Policy or applicable data protection law, you have the right to submit a complaint. We encourage you to contact us directly in the first instance so that we can address your concern promptly:

• Via live chat support available 24/7 on the Platform (preferred for time-sensitive matters).
• Via email to [email protected] (plain text — not a clickable link).

We will acknowledge your complaint within five (5) business days and aim to provide a substantive response within thirty (30) calendar days. If your complaint is not resolved to your satisfaction, you may have the right to escalate it to the data protection supervisory authority in the jurisdiction where you reside.

15 Policy Amendments

zonafilm21 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform functionality. Material changes that affect how we use your personal data will be communicated to registered Players via the Platform or by email notification to the address on file, with a minimum of fourteen (14) days' notice before the changes take effect.

We recommend that you review this Policy periodically. The "Last Updated" date at the top of this page reflects the most recent revision. Continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

16 Contact Us

For any privacy-related queries, data rights requests, or complaints concerning this Privacy Policy or the processing of your personal data, please contact us through the following channels: