panolo Privacy Policy

panolo ("we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the panolo platform at panolo.app. This Privacy Policy has been prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

This Privacy Policy applies to all personal data collected, processed, stored, and shared by panolo in connection with your use of the panolo website, mobile site, and all associated services, features, and content (collectively, the "Platform"). It applies to all registered players, visitors, and any other individuals whose personal data panolo processes.

By registering for a panolo account, accessing the Platform, or otherwise providing your personal data to panolo, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

For the purposes of the Data Privacy Act of 2012, panolo is the personal information controller in respect of the personal data collected through the Platform. This means panolo determines the purposes and means by which your personal data is processed.

panolo has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection law. Contact details for the DPO are provided in Section 16 of this Policy.

Where panolo engages third-party service providers to process personal data on its behalf (for example, payment processors, KYC verification providers, or cloud hosting services), those providers act as personal information processors and are bound by data processing agreements that require them to process personal data only on panolo's instructions and in accordance with applicable law.

panolo collects the following categories of personal data, depending on how you interact with the Platform:

panolo collects personal data through the following means:

• Direct Collection: Information you provide when registering for a panolo account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies (see Section 9).
• Third-Party Sources: Identity and fraud-check data received from KYC verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), and fraud prevention services, where you have authorized such sharing or where panolo is required to conduct such checks by law.
• Publicly Available Sources: In limited circumstances, panolo may verify information against publicly available records, such as government databases, where required for compliance purposes.

panolo uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your panolo account, including verifying your identity and age (21+ requirement) and processing your login credentials.
• Service Delivery: To provide access to all panolo games and features, process deposits and withdrawals in Philippine Peso (₱), and deliver the core gaming experience.
• KYC & Regulatory Compliance: To verify your identity in accordance with PAGCOR requirements and Philippine anti-money laundering (AML) regulations, including the Anti-Money Laundering Act (AMLA) and its amendments.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the Platform.
• Responsible Gaming: To monitor gaming patterns and identify indicators of problem gambling, and to administer responsible gaming tools such as deposit limits, loss limits, and self-exclusion.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Communications: To send you account-related notifications, security alerts, transaction confirmations, and — where you have opted in — promotional communications about panolo offers and new games.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the performance, features, and user experience of the panolo Platform.
• Legal Obligations: To comply with applicable Philippine laws, regulations, court orders, and lawful requests from government authorities.

Under the Data Privacy Act of 2012, panolo processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and panolo — that is, to operate your account, process transactions, and deliver gaming services.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including KYC obligations, AML reporting requirements, and PAGCOR regulatory requirements.
• Legitimate Interests: Processing necessary for panolo's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and business analytics — provided these interests are not overridden by your rights and interests.
• Consent: Where panolo relies on your consent as the legal basis for processing (for example, for optional marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

panolo does not sell, rent, or trade your personal data to third parties for their own marketing purposes. panolo may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, InstaPay, PESONet, and other Philippine payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services engaged by panolo to conduct mandatory KYC checks in compliance with Philippine regulations.
• Game Content Providers: Third-party game studios and content providers whose games are available on the panolo Platform, to the extent necessary to deliver the gaming experience and resolve game-related disputes.
• Cloud & Infrastructure Providers: Cloud hosting, data storage, and IT infrastructure providers who process data on panolo's behalf under strict data processing agreements.
• Fraud Prevention & Security Services: Third-party fraud detection and cybersecurity providers engaged to protect the Platform and its players.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bangko Sentral ng Pilipinas (BSP), and other Philippine government authorities, where panolo is required by law to disclose information.
• Law Enforcement: Philippine law enforcement agencies, where panolo is required by a valid court order, subpoena, or other lawful process to disclose information.
• Professional Advisers: Lawyers, auditors, and accountants engaged by panolo, subject to professional confidentiality obligations.

panolo takes the security of your financial information with the utmost seriousness. All payment transactions on the panolo Platform are processed through regulated Philippine payment channels in compliance with Bangko Sentral ng Pilipinas (BSP) regulations.

• panolo does not store full payment card numbers, CVV codes, or complete bank account credentials on its own servers. Payment data is tokenized and handled directly by the relevant payment processor (GCash, PayMaya, BPI, BDO, Metrobank, etc.).
• All financial transactions are conducted in Philippine Peso (PHP / ₱) and are subject to the transaction limits and security protocols of the relevant payment provider.
• panolo maintains records of transaction amounts, dates, payment methods used, and transaction reference numbers for regulatory compliance, AML monitoring, and dispute resolution purposes.
• In accordance with AMLA requirements, panolo is obligated to report covered transactions (single transactions of ₱500,000 or more) and suspicious transactions to the Anti-Money Laundering Council (AMLC).
• panolo may place a temporary hold on withdrawal requests pending identity verification or AML review. During such holds, your funds remain in your panolo wallet and are not at risk.

panolo uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the Platform. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in to your panolo account and security cookies that help detect fraudulent activity. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences, such as your preferred language, display settings, and responsible gaming limits. These improve your experience on the Platform.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform — such as which games are most popular and how long sessions last. This data helps panolo improve the Platform.
• Security Cookies: Used to detect and prevent fraudulent logins, bot activity, and other security threats to your panolo account.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the panolo Platform, including your ability to stay logged in or access certain features.

panolo retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account Data: Retained for the duration of your panolo account and for a minimum of five (5) years after account closure, in accordance with PAGCOR and AMLA record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years after the end of the business relationship, in accordance with AMLA requirements.
• Gaming History: Game logs and betting records are retained for a minimum of three (3) years for dispute resolution and regulatory compliance purposes.
• Support Communications: Customer support records are retained for two (2) years from the date of the last interaction.
• Technical Logs: Server logs and security logs are retained for up to twelve (12) months, after which they are securely deleted or anonymized.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with panolo's data disposal procedures. Where data cannot be immediately deleted due to technical constraints, it will be isolated and protected from further processing until deletion is possible.

panolo 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:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and the panolo Platform is encrypted using industry-standard 256-bit SSL/TLS encryption.
• Encryption at Rest: Sensitive personal data stored on panolo's servers is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to panolo personnel and authorized service providers who have a legitimate need to access it. All access is logged and audited.
• Two-Factor Authentication: panolo supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security.
• Regular Security Audits: panolo conducts regular security assessments and penetration testing to identify and address vulnerabilities in the Platform.
• Data Breach Response: panolo maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, panolo will notify the National Privacy Commission and affected players within the timeframes required by the Data Privacy Act.
• Staff Training: All panolo personnel who handle personal data receive regular training on data protection obligations and security best practices.

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by panolo:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed — which is the purpose of this Privacy Policy.
• Right to Access: The right to request a copy of the personal data panolo holds about you, along with information about how it is being processed.
• Right to Correction: The right to request correction of any inaccurate, incomplete, or outdated personal data in your panolo account.
• Right to Erasure or Blocking: The right to request the deletion or blocking of your personal data where panolo no longer has a lawful basis to retain it, subject to panolo's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on panolo's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller.
• Right to Damages: The right to claim compensation for any damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe panolo has violated your data privacy rights.

To exercise any of these rights, please contact panolo's Data Protection Officer using the contact details in Section 16. panolo will respond to all data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified of any extension.

The panolo Platform is strictly intended for adults aged 21 years and older. panolo does not knowingly collect personal data from any person under the age of 21. This restriction is consistent with Philippine law governing access to casino-style gaming.

If panolo discovers or has reason to believe that personal data has been collected from a person under the age of 21, panolo will immediately close the associated account, delete all personal data collected from that individual, and — where required — report the matter to the appropriate Philippine authorities.

If you are a parent or guardian and believe that your child under the age of 21 has registered for a panolo account or provided personal data to panolo, please contact our Data Protection Officer immediately using the contact details in Section 16.

panolo primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or game content providers with servers in other jurisdictions.

Where such cross-border transfers occur, panolo ensures that appropriate safeguards are in place to protect your personal data, in accordance with Section 21 of the Data Privacy Act of 2012 and the NPC's guidelines on cross-border data transfers. These safeguards may include:

• Data processing agreements with receiving parties that impose data protection obligations equivalent to those under Philippine law.
• Transfers to countries or organizations that the NPC has determined provide an adequate level of data protection.
• Standard contractual clauses approved by the NPC for cross-border data transfers.

By using the panolo Platform, you acknowledge and consent to the transfer of your personal data to other jurisdictions where necessary for the operation of the Platform, subject to the safeguards described above.

panolo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this Privacy Policy, panolo will notify registered players by email to their registered address and/or by displaying a prominent notice on the Platform prior to the changes taking effect. For non-material changes, the updated Policy will be posted on this page without separate notification.

Your continued use of the panolo Platform after the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the updated Policy, you should stop using the Platform and contact panolo to close your account.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by panolo, please contact our Data Protection Officer (DPO):

• Data Protection Officer: panolo DPO
• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available within your panolo account after login at panolo Login
• Response Time: panolo aims to acknowledge all privacy-related inquiries within 72 hours and to provide a substantive response within 30 days.

If you are not satisfied with panolo's response to your privacy inquiry or believe that panolo has violated your data privacy rights under the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC can be reached through its official website and offices in Quezon City, Metro Manila.