Privacy Policy

Section 01

Introduction

This Privacy Policy ("Policy") describes how panalo Casino ("panalo," "we," "us," or "our") collects, uses, stores, shares, and protects the personal data of individuals ("you," "the Player," or "the Data Subject") who access or use the panalo platform available at panalo.one, including any associated web or mobile interfaces.

panalo is committed to handling your personal data responsibly and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). By registering a panalo account or using the panalo platform in any capacity, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read alongside panalo's Terms & Conditions, which govern the overall relationship between panalo and its players. In the event of any conflict between this Policy and the Terms & Conditions on a privacy-related matter, this Policy shall prevail.

Section 02

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, panalo Casino is the Personal Information Controller (PIC) in respect of the personal data collected through the panalo platform. As PIC, panalo determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

panalo has designated a Data Protection Officer (DPO) who is responsible for overseeing the platform's data protection practices and serving as the primary point of contact for data privacy inquiries and complaints. You may contact the panalo DPO directly using the contact details provided in Section 15 of this Policy.

                Data Protection Officer: panalo's DPO is responsible for ensuring compliance with the Data Privacy Act of 2012 and all NPC issuances. All data privacy concerns, access requests, and complaints should be directed to the DPO in the first instance.
              

Section 03

Data We Collect

panalo collects the following categories of personal data in connection with the operation of the panalo platform:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, nationality, government-issued ID number (PhilSys, passport, driver's license, SSS/GSIS, voter's ID)	Account registration, KYC verification, age verification (21+)
Contact Data	Philippine mobile number, email address, residential address (city/province)	Account communication, OTP delivery, support correspondence
Financial Data	GCash number, PayMaya number, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records	Payment processing, withdrawal verification, AML compliance
Gaming Data	Game history, wager amounts, win/loss records, session duration, bonus usage, responsible gaming settings	Platform operation, responsible gaming monitoring, dispute resolution
Technical Data	IP address, device type, browser type and version, operating system, session tokens, login timestamps	Security monitoring, fraud detection, platform optimization
Usage Data	Pages visited, features used, click patterns, referral source, time spent on platform	Platform improvement, personalization, marketing analytics
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Customer support, quality assurance, dispute resolution

panalo does not intentionally collect sensitive personal information as defined under the Data Privacy Act of 2012 (such as health data, religious beliefs, or political affiliations) unless specifically required for regulatory compliance purposes, in which case you will be notified and your explicit consent will be obtained.

Section 04

How We Collect Your Data

panalo collects personal data through the following channels:

Direct collection: Information you provide when registering a panalo account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions.
Automated collection: Technical and usage data collected automatically when you access the panalo platform, including through cookies, web beacons, and server logs. See Section 8 for more detail on cookies.
Third-party sources: Identity verification data from KYC service providers; fraud signals from payment processors such as GCash and PayMaya; device fingerprinting data from security service providers. panalo only receives data from third parties where you have consented to that sharing or where panalo has a legitimate interest or legal obligation to obtain it.
Regulatory sources: In limited circumstances, panalo may receive data from PAGCOR or other Philippine regulatory bodies in connection with its licensing obligations.

Section 05

Legal Basis for Processing

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

Contractual necessity: Processing required to perform the contract between panalo and the player — including account management, payment processing, game delivery, and customer support.
Legal obligation: Processing required to comply with applicable Philippine law, including PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, and NPC data privacy regulations.
Legitimate interests: Processing carried out for panalo's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided such interests are not overridden by your rights and freedoms.
Consent: Processing based on your freely given, specific, informed, and unambiguous consent — including for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Section 06

How We Use Your Data

panalo uses the personal data it collects for the following purposes:

To create, verify, and manage your panalo account, including age verification (21+) and KYC compliance
To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels
To deliver the games and features available on the panalo platform, including slots, live dealer tables, bingo, and arcade games
To detect, investigate, and prevent fraud, money laundering, bonus abuse, and other prohibited conduct as described in the panalo Terms & Conditions
To comply with PAGCOR licensing requirements, AMLA reporting obligations, and other applicable Philippine regulatory requirements
To monitor responsible gaming indicators and to apply responsible gaming tools (deposit limits, self-exclusion, session reminders) where appropriate
To provide customer support and to resolve disputes or complaints
To send you transactional communications (account notifications, deposit confirmations, withdrawal updates, OTPs) via SMS or email
To send you promotional communications about panalo bonuses, new games, and special offers — only where you have opted in to receive such communications
To analyze platform usage and improve the panalo user experience
To personalize your panalo experience, including game recommendations and promotional offers tailored to your gaming preferences

                Marketing Opt-Out: You may opt out of promotional communications from panalo at any time by updating your notification preferences in your panalo account settings, or by contacting panalo support. Opting out of marketing communications will not affect your receipt of essential transactional messages.
              

Section 07

Data Sharing & Disclosure

panalo does not sell, rent, or trade your personal data to third parties for their own marketing purposes. panalo 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, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
KYC and identity verification providers: Third-party identity verification services used to confirm your identity and age in compliance with PAGCOR and AMLA requirements.
Game content providers: Third-party game studios whose games are available on the panalo platform may receive limited technical data (such as session tokens and game results) necessary to deliver their games.
Fraud prevention and security providers: Third-party services used to detect and prevent fraud, money laundering, and unauthorized account access.
Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law or regulatory obligation.
Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by panalo, subject to professional confidentiality obligations.
Business successors: In the event of a merger, acquisition, or sale of panalo's business or assets, your personal data may be transferred to the acquiring entity, subject to the same data protection standards described in this Policy.

                All third-party service providers engaged by panalo are required to process your personal data only for the specific purposes for which they were engaged, and to maintain appropriate technical and organizational security measures. panalo remains responsible for ensuring that third-party processors comply with applicable data privacy obligations.
              

Section 08

Cookies & Tracking Technologies

The panalo platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze platform usage. A cookie is a small text file placed on your device when you visit a website. panalo uses the following categories of cookies:

Cookie Type	Purpose	Consent Required
Strictly Necessary	Session management, login authentication, security tokens, fraud prevention	No — essential for platform operation
Functional	Remembering your language preferences, game settings, and responsible gaming configurations	No — necessary for core functionality
Analytics	Understanding how players use the panalo platform, identifying popular games and features, measuring page performance	Yes — opt-in required
Marketing	Delivering personalized promotional content and measuring the effectiveness of panalo marketing campaigns	Yes — opt-in required

You may manage your cookie preferences at any time through your browser settings. Please note that disabling strictly necessary or functional cookies may affect the performance and security of your panalo account. Disabling analytics or marketing cookies will not affect your ability to play games or access your account.

Section 09

Data Retention

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

Account and identity data: Retained for the duration of your panalo account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AMLA record-keeping obligations.
Financial and transaction data: Retained for a minimum of five (5) years following the date of each transaction, in compliance with AMLA and BIR requirements.
Gaming data: Retained for a minimum of three (3) years following the relevant gaming session, for dispute resolution and regulatory audit purposes.
Communications data: Support correspondence and chat transcripts are retained for two (2) years following the closure of the relevant support ticket.
Technical and usage data: Retained for up to twelve (12) months, after which it is aggregated and anonymized for analytics purposes.

Where panalo is required by law to retain data for a longer period, the statutory retention period will apply. Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with panalo's data disposal procedures.

Section 10

Data Security

panalo implements appropriate 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 for all data transmitted between your device and the panalo platform
Encryption of sensitive data at rest, including financial data and government ID information
Two-factor authentication (2FA) for player account access
Role-based access controls limiting panalo staff access to personal data on a strict need-to-know basis
Real-time fraud detection and anomaly monitoring systems
Regular security assessments and penetration testing of the panalo platform
Secure data disposal procedures for expired personal data

While panalo takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your panalo account credentials and for notifying panalo immediately if you suspect unauthorized access to your account.

                Data Breach Notification: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, panalo will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with NPC Circular No. 16-03.
              

Section 11

Your Data Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by panalo:

Right to Access

Request a copy of the personal data panalo holds about you and information about how it is processed.

Right to Rectification

Request correction of inaccurate or incomplete personal data held in your panalo account.

Right to Erasure

Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.

Right to Object

Object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.

Right to Block

Request that panalo suspend processing of your personal data pending resolution of a rectification or objection request.

Right to Portability

Request a copy of your personal data in a structured, commonly used, machine-readable format for transfer to another service provider.

Right to Damages

Claim compensation for damages sustained as a result of inaccurate, incomplete, outdated, or unlawfully obtained personal data.

Right to Complain

Lodge a complaint with the National Privacy Commission (NPC) if you believe panalo has violated your data privacy rights.

To exercise any of the above rights, please contact panalo's Data Protection Officer using the details in Section 15. panalo will respond to all data subject requests within fifteen (15) calendar days of receipt. Where a request is complex or involves a large volume of data, panalo may extend this period by a further thirty (30) days, with prior notice to you.

panalo may request proof of identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized parties.

Section 12

Children & Minors

The panalo platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine law governing online gambling. panalo does not knowingly collect personal data from any person under the age of 21.

If panalo discovers or has reason to believe that personal data has been collected from a person under 21 years of age, panalo will immediately suspend the relevant account, delete the associated personal data, and return any deposited funds to the payment method used, subject to verification. If you believe that a minor may have registered a panalo account, please contact panalo support immediately.

                21+ Only: panalo enforces strict age verification during registration and KYC. Parents and guardians are encouraged to use device-level parental controls to prevent minors from accessing online gambling platforms. If you are under 21, you must not attempt to register or use the panalo platform.
              

Section 13

Cross-Border Data Transfers

In certain circumstances, panalo may transfer your personal data to recipients located outside the Philippines — for example, to third-party game studios, cloud infrastructure providers, or fraud prevention services that operate internationally. Any such cross-border transfer of personal data will only be carried out where:

The recipient country has been recognized by the NPC as providing an adequate level of data protection; or
panalo has implemented appropriate safeguards, such as contractual clauses approved by the NPC, to ensure that your personal data receives an equivalent level of protection to that afforded under Philippine law; or
The transfer is necessary for the performance of the contract between panalo and the player (for example, to process a payment through an international payment network); or
You have given your explicit consent to the transfer after being informed of the possible risks.

panalo will not transfer your personal data to any jurisdiction that does not provide adequate data protection safeguards without your prior consent, except where required by Philippine law or regulatory obligation.

Section 14

Changes to This Policy

panalo reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, NPC guidance, panalo's data processing practices, or the features and services available on the panalo platform. When material changes are made, panalo will notify registered players via the contact details associated with their account and will publish the updated Policy on this page with a revised "Last Updated" date.

Your continued use of the panalo platform after the effective date of any amendment constitutes your acknowledgment of the updated Policy. If you do not agree with the changes, you may request voluntary account closure as described in the panalo Terms & Conditions. The most current version of this Policy will always be available at panalo.one/privacy-policy.

Section 15

Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or panalo's handling of your personal data, please contact panalo's Data Protection Officer. All data privacy inquiries will be acknowledged within two (2) business days and resolved within fifteen (15) calendar days where possible.

Data Protection Officer — panalo Casino
[email protected]
Please include "Data Privacy Request" in your subject line and provide your registered panalo account email address or mobile number so we can locate your records. For urgent security concerns, please also contact our 24/7 support team via live chat on the panalo platform.

If you are not satisfied with panalo's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for administering and enforcing the Data Privacy Act of 2012 in the Philippines.

For general support inquiries unrelated to data privacy, please contact panalo's customer support team, available 24 hours a day, 7 days a week via live chat on the panalo platform or by email at [email protected].