Privacy Policy — Paldo PH

1. Introduction

1.1 Paldo PH is committed to protecting the privacy and personal data of every Filipino player who uses our online gaming platform. This Policy sets out in clear terms how we collect, use, store, share, and protect your personal information in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC").

1.2 This Policy applies to all personal data processed by Paldo PH in connection with your use of the paldo-ph.net website, the Paldo PH mobile application, customer support interactions, and any other services we provide to registered players and visitors.

1.3 Please read this Policy carefully. If you do not agree with any part of this Policy, you should not register for or continue to use the Paldo PH platform. Questions about this Policy may be directed to our Data Protection Officer using the contact details provided in Section 14.

2. Personal Data We Collect

2.1 Paldo PH collects only the personal data that is necessary to provide you with a safe, fair, and compliant online gaming experience. The categories of personal data we collect include:

2.1 Identity Data

• Full legal name as it appears on your Philippine government-issued identification;
• Date of birth (used to verify that you are 21 years of age or older);
• Gender;
• Nationality and country of residence;
• Government-issued ID number (e.g., PhilSys National ID, passport, driver's licence).

2.2 Contact Data

• Email address;
• Mobile phone number;
• Residential address (city, province, postal code).

2.3 Account Data

• Paldo PH username and encrypted password;
• Account registration date and history;
• Preferred language and communication settings;
• Responsible gaming preferences and limit settings.

2.4 Financial Data

• GCash or PayMaya mobile wallet reference details;
• BPI, BDO, or Metrobank account name and number (last four digits only, for verification);
• Deposit and withdrawal transaction history;
• Account balance and bonus credit history.

2.5 Gaming Activity Data

• Games played, wager amounts, and game outcomes;
• Session duration and login timestamps;
• Bonus and promotion usage history;
• Responsible gaming tool usage (deposit limits, self-exclusion requests).

2.6 Technical Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Cookie identifiers and session tokens;
• Platform interaction logs and error reports.

3. How We Collect Your Data

3.1 Directly from you — when you register a Paldo PH account, complete identity verification, make a deposit or withdrawal, contact our support team, or update your account settings.

3.2 Automatically — when you access the Paldo PH website or mobile application, we automatically collect technical data such as your IP address, device information, and browsing behaviour through cookies and similar tracking technologies. See Section 7 for full details on our cookie practices.

3.3 From third parties — Paldo PH may receive identity verification data from third-party Know Your Customer (KYC) service providers, fraud prevention services, and payment processors such as GCash and PayMaya, solely for the purpose of verifying your identity and processing transactions securely.

4. How We Use Your Personal Data

4.1 Paldo PH uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Identity, contact, account data
Age and identity verification (21+ compliance)	Identity data, government ID
Processing deposits and withdrawals	Financial data, identity data
Providing and improving gaming services	Gaming activity, technical data
Fraud prevention and security monitoring	Technical, financial, identity data
Responsible gaming monitoring and support	Gaming activity, account data
Customer support and dispute resolution	All relevant data categories
Regulatory reporting to PAGCOR and NPC	Identity, financial, gaming data
Sending service notifications and updates	Contact data, account data
Platform analytics and performance improvement	Technical data, gaming activity

4.2 Paldo PH will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by Philippine law.

5. Legal Basis for Processing

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

• Contractual necessity — processing required to fulfil our obligations to you as a registered Paldo PH player, including account management, payment processing, and game provision;
• Legal obligation — processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, anti-money laundering obligations, and NPC reporting requirements;
• Legitimate interests — processing necessary for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights and freedoms;
• Consent — processing based on your freely given, specific, and informed consent, such as for optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 We do not sell your data. Paldo PH does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. Full stop.

6.2 Paldo PH may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors — GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing your deposits and withdrawals;
• Identity verification providers — third-party KYC service providers engaged to verify your identity and age in compliance with Philippine regulatory requirements;
• Fraud prevention services — providers that help Paldo PH detect and prevent fraudulent activity, money laundering, and account abuse;
• Regulatory authorities — PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and Philippine law enforcement agencies, where disclosure is required by law or regulatory obligation;
• IT and hosting providers — third-party service providers that host and maintain the Paldo PH platform infrastructure, subject to strict data processing agreements;
• Professional advisers — lawyers, auditors, and consultants engaged by Paldo PH, subject to professional confidentiality obligations.

6.3 All third parties with whom Paldo PH shares personal data are required to process that data in accordance with applicable Philippine data protection law and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

7. Cookies and Tracking Technologies

7.1 The Paldo PH website and mobile application use cookies and similar tracking technologies to enhance your experience, maintain your session, and analyse platform usage. The types of cookies we use include:

• Strictly necessary cookies — essential for the Paldo PH platform to function. These cannot be disabled as they are required for login sessions, security, and core platform features;
• Functional cookies — used to remember your preferences, such as language settings and responsible gaming limits;
• Analytics cookies — used to collect anonymised data about how Filipino players use the Paldo PH platform, helping us improve performance and user experience;
• Security cookies — used to detect and prevent fraudulent activity, bot access, and unauthorised account access.

7.2 You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Paldo PH platform. Strictly necessary cookies cannot be disabled without preventing access to the platform.

7.3 Paldo PH does not use third-party advertising cookies or allow external advertising networks to place cookies on the Paldo PH platform.

8. Data Retention

8.1 Paldo PH retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law and regulatory obligations. Specific retention periods include:

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC requirements;
• Financial transaction data — retained for a minimum of five (5) years from the date of each transaction, as required by Philippine anti-money laundering regulations;
• Gaming activity data — retained for three (3) years from the date of each gaming session;
• Technical and log data — retained for up to twelve (12) months from the date of collection;
• Customer support records — retained for three (3) years from the date of the last interaction.

8.2 Upon expiry of the applicable retention period, Paldo PH will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9. Data Security

9.1 Paldo PH implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the Paldo PH platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Multi-factor authentication options for player accounts;
• Regular security assessments and penetration testing of the Paldo PH platform;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Staff training on data protection obligations and security best practices.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Paldo PH will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012.

10. Your Data Rights

10.1 Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by Paldo PH:

• Right to be informed — the right to know what personal data Paldo PH collects about you and how it is used, as set out in this Policy;
• Right of access — the right to request a copy of the personal data Paldo PH 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 Paldo PH's legal retention obligations;
• Right to object — the right to object to certain types of data processing, including processing based on legitimate interests;
• Right to data portability — the right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint — the right to file a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

10.2 To exercise any of the rights listed above, please contact Paldo PH's Data Protection Officer using the details provided in Section 14. We will respond to all verified requests within thirty (30) days of receipt, in accordance with NPC guidelines.

10.3 Paldo PH may need to verify your identity before processing a data rights request to ensure that personal data is not disclosed to an unauthorised person.

11. Children and Minors

11.1 The Paldo PH platform is strictly intended for persons who are twenty-one (21) years of age or older. Paldo PH does not knowingly collect personal data from persons under the age of 21.

11.2 If Paldo PH becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Paldo PH platform, please contact our support team immediately.

11.3 Age verification is conducted as part of the Paldo PH registration and KYC process. Players who cannot provide satisfactory proof of age will not be permitted to deposit, play, or withdraw on the platform.

12. International Data Transfers

12.1 Paldo PH primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines, Paldo PH will ensure that such transfers are conducted in accordance with the Data Privacy Act of 2012 and that appropriate safeguards are in place to protect your personal data.

12.2 Appropriate safeguards for international transfers may include contractual clauses approved by the National Privacy Commission, binding corporate rules, or transfers to countries that have been assessed as providing an adequate level of data protection.

13. Changes to This Privacy Policy

13.1 Paldo PH reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

13.2 Where changes to this Policy are material, Paldo PH will notify registered players via the email address on file or through a prominent notice on the platform prior to the changes taking effect. Your continued use of the Paldo PH platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

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

14. Contact and Complaints

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the way Paldo PH handles your personal data, please contact our Data Protection Officer. Our contact details are available in the footer of this page.

14.2 Paldo PH takes all privacy concerns seriously and will respond to your enquiry within a reasonable timeframe. For formal data rights requests, please clearly state the nature of your request and provide sufficient information to allow us to verify your identity.

14.3 If you are not satisfied with Paldo PH's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012 in the Philippines.