paldo Privacy Policy

paldo ("we", "us", "our") is committed to protecting the privacy and personal data of every player who uses the paldo online gaming platform at paldo.lat. This Privacy Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable guidelines issued by the National Privacy Commission (NPC) of the Philippines.

This Policy applies to all personal information that paldo processes in connection with your use of the Platform — from the moment you register an Account through to the closure of your Account and beyond, as required by applicable law and our regulatory obligations to PAGCOR.

By registering a paldo Account or otherwise using the paldo Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal data as described herein. If you do not agree with this Policy, please do not use the paldo Platform.

For the purposes of the Philippine Data Privacy Act of 2012, paldo is the Personal Information Controller (PIC) in respect of all personal data collected and processed through the paldo Platform.

paldo has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection laws and this Privacy Policy. The paldo DPO may be contacted at:

• Email: [email protected] (subject line: "Data Protection / DPO Enquiry")
• Response Time: Within ten (10) business days of receipt

paldo operates its online gaming services under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR). Certain data processing activities are undertaken by paldo as a result of its obligations as a PAGCOR-licensed operator and are non-negotiable from a legal compliance perspective.

paldo collects personal data that is necessary for operating a regulated online gaming platform. The categories of data we collect, and the reasons for collecting them, are set out in the table below:

paldo does not intentionally collect sensitive personal information beyond what is strictly required for age verification, identity verification, and AML compliance purposes under Philippine law and PAGCOR regulations.

paldo collects personal data through the following channels:

• Direct Submission: Information you provide directly when registering your paldo Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or setting responsible gaming preferences.
• Automated Technical Collection: Technical and usage data automatically collected when you access and navigate the paldo Platform, including IP address, device identifiers, session data, and cookies. See Section 8 for details on cookies.
• Gaming Activity Logs: Records generated automatically by the Platform as a result of your gameplay activity, including game session records, wagering history, and bonus redemption activity.
• Third-Party Verification Providers: Identity and document verification data received from KYC service providers engaged by paldo to assist with PAGCOR-mandated identity verification obligations.
• Payment Processors: Transaction confirmation and status information received from GCash, Maya, and other payment processing partners when you make deposits or withdrawals.

Under the Philippine Data Privacy Act of 2012, paldo processes your personal data on the following legal grounds:

• Contractual Necessity: Processing necessary to perform the contract between you and paldo (i.e., to operate your Account, process your wagers, and pay out your winnings). Without this processing, paldo cannot provide its gaming services to you.
• Legal Obligation: Processing required to comply with paldo's legal obligations under Philippine law — particularly the Anti-Money Laundering Act (AMLA), the Data Privacy Act, PAGCOR licensing conditions, and other applicable regulations. This includes KYC identity verification, transaction monitoring, and suspicious activity reporting.
• Legitimate Interest: Processing carried out in pursuit of paldo's legitimate business interests where those interests are not overridden by your privacy rights — including fraud prevention, platform security, responsible gaming monitoring, and service quality improvement.
• Consent: Where required by applicable law, paldo obtains your explicit consent before processing your personal data — for example, before sending direct marketing communications. You may withdraw consent at any time by updating your Account notification preferences or by contacting our DPO.

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

• Account Creation and Management: Registering and maintaining your paldo Account, including authentication and access control.
• Age and Identity Verification: Verifying that you are aged 21 years or older and that your identity matches the details provided at registration, in compliance with PAGCOR and Philippine AML requirements.
• Payment Processing: Processing deposits into and withdrawals from your paldo Wallet via your nominated Philippine payment channel.
• Gaming Service Delivery: Enabling access to bingo, slots, live casino, fishing games, and other games available on the paldo Platform.
• Responsible Gaming: Monitoring gaming activity to identify potentially harmful patterns, administering self-imposed spending limits and exclusion requests, and complying with PAGCOR's responsible gaming requirements.
• Fraud and Security: Detecting and preventing fraudulent transactions, account abuse, money laundering, and other prohibited activities on the Platform.
• Customer Support: Responding to your enquiries, complaints, and support requests.
• Regulatory Compliance: Fulfilling reporting and record-keeping obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve Platform performance, fix technical issues, and develop new features.
• Marketing Communications: Sending you relevant promotional offers and updates about paldo, where you have not opted out of such communications. You may unsubscribe at any time through your Account settings.

paldo may share your personal data with third parties only in the circumstances described below and always subject to appropriate data protection safeguards:

• PAGCOR and Regulatory Authorities: paldo is legally required to share player account and transaction data with PAGCOR as a condition of its online gaming license. paldo may also be required to disclose data to the Anti-Money Laundering Council (AMLC) or other competent Philippine government authorities pursuant to lawful legal process.
• KYC and Identity Verification Providers: paldo engages reputable third-party identity verification service providers to assist with PAGCOR-mandated KYC processes. These providers act as Personal Information Processors under written agreements that restrict their use of your data to the specific verification purpose.
• Payment Processors: Payment processing partners (including GCash, Maya, and banking partners) receive the data necessary to process your deposit and withdrawal transactions. These partners are independently regulated financial institutions subject to their own data protection obligations under Philippine law.
• Game Software Providers: Third-party game studios whose games are offered on the paldo Platform may receive anonymised session data for game performance and integrity purposes. No directly identifying information is shared with game providers beyond what is required for game session initiation.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and technical infrastructure providers who process data on paldo's behalf under strict data processing agreements.
• Corporate Transactions: In the event of a merger, acquisition, or restructuring of paldo's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection standards and advance notice to affected players.

paldo does not transfer your personal data outside the Philippines except where strictly necessary for the service delivery purposes described above and where appropriate safeguards are in place consistent with the Data Privacy Act of 2012.

paldo uses cookies and similar tracking technologies on the paldo Platform to deliver a functional, secure, and personalised experience. The following categories of cookies are used:

• Essential Cookies: Strictly necessary cookies that enable core Platform functionality — including maintaining your logged-in session, security tokens, and load balancing. These cookies cannot be disabled without preventing you from using the Platform.
• Security Cookies: Cookies used to detect and prevent fraudulent access, session hijacking, and bot activity on the paldo Platform. These are non-negotiable for account security.
• Preference Cookies: Cookies that remember your Platform preferences — such as game lobby sorting, language settings, and notification preferences — to improve your experience on return visits.
• Analytics Cookies: First-party analytics cookies that help paldo understand how players navigate and interact with the Platform, used to identify and fix usability issues and improve page performance. Analytics data is processed in aggregated, anonymised form.

paldo does not place third-party advertising cookies or cross-site tracking cookies on the Platform. Your browsing activity on paldo is not shared with advertising networks or social media platforms.

paldo retains personal data for as long as is necessary for the purposes for which it was collected and as required by applicable Philippine law. The following general retention periods apply:

• Active Account Data: Retained for the duration of your paldo Account and for a period of at least five (5) years following Account closure, in compliance with PAGCOR licensing requirements and AMLA record-keeping obligations.
• Transaction Records: Deposit, withdrawal, and wagering records are retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following Account closure or the date of the most recent transaction (whichever is later).
• Customer Support Records: Correspondence and complaint records are retained for three (3) years from the date of the last communication, or longer where required by an ongoing dispute or regulatory investigation.
• Technical Logs: Security and access logs are retained for a rolling period of twelve (12) months, unless retention for a longer period is required in connection with a security investigation.

Where personal data is no longer required for any legitimate purpose, paldo will securely delete or permanently anonymise it. Anonymised, aggregated data may be retained indefinitely for statistical and service improvement purposes.

paldo implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Key security measures include:

• Encryption in Transit: All data transmitted between your device and the paldo Platform is encrypted using TLS (Transport Layer Security) protocol. HTTPS is enforced on all Platform pages.
• Encryption at Rest: Sensitive personal data — including identity documents, financial information, and KYC records — is encrypted at rest using AES-256 or equivalent industry-standard algorithms.
• Access Controls: Access to personal data within paldo's systems is restricted on a need-to-know basis. All staff with access to personal data undergo background screening and regular data protection training.
• OTP Authentication: Account login and sensitive account actions require verification via a one-time password (OTP) sent to your registered Philippine mobile number.
• Intrusion Detection: paldo operates continuous security monitoring and intrusion detection systems to identify and respond to security threats in real time.
• Third-Party Security Audits: paldo's platform security is subject to periodic third-party security assessments and penetration testing.

While paldo takes robust security measures, no online platform can guarantee absolute security. You also play an important role in keeping your data safe by maintaining a strong, unique password for your paldo Account and never sharing your login credentials or OTP codes with anyone.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by paldo. To exercise any of these rights, please contact our DPO at [email protected] with the subject line "Data Rights Request":

• Right to Be Informed: You have the right to be informed of how your personal data is being collected and processed. This Privacy Policy is paldo's primary mechanism for fulfilling this obligation.
• Right of Access: You have the right to request a copy of the personal data paldo holds about you, along with information about how it is used and with whom it is shared.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data held by paldo. Basic account information may be updated directly within your paldo Account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected and where no legal obligation requires continued retention. Please note that PAGCOR licensing and AML requirements mandate retention of certain records for a minimum of five (5) years.
• Right to Data Portability: You have the right to receive a copy of personal data you have provided to paldo in a structured, commonly used, machine-readable format, where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may exercise this right by updating your notification preferences in your Account settings.
• Right to Lodge a Complaint: If you believe that paldo has breached your data protection rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.

paldo will respond to verified data rights requests within thirty (30) calendar days. In complex cases, paldo may extend this period by a further thirty (30) days with notification to you. Identity verification may be required before paldo processes a data rights request.

The paldo Platform is strictly intended for use by adults aged twenty-one (21) years and older, in compliance with PAGCOR online gaming regulations for the Philippines. paldo does not knowingly collect, process, or retain personal data from individuals under the age of 21.

If paldo discovers or is notified that it has inadvertently collected personal data from a person under 21 years of age, it will promptly suspend the relevant Account, delete all associated personal data to the extent permitted by law, and report the matter in accordance with applicable PAGCOR regulatory requirements.

paldo reserves the right to update or amend this Privacy Policy at any time to reflect changes in Philippine law, NPC guidelines, PAGCOR regulatory requirements, our data processing practices, or the nature of our Platform services.

When material changes are made to this Policy, paldo will publish the updated version on this page with a revised "Last Updated" date and, where practicable, notify registered users via their registered mobile number or in-Platform notification. The effective date of the current version is displayed at the top of this page.

Your continued use of the paldo Platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated Policy. If you disagree with any changes, you should discontinue use of the Platform and may request Account closure as described in paldo's Terms and Conditions.

For any queries, concerns, or requests relating to this Privacy Policy or paldo's data protection practices, please contact our Data Protection Officer through the following channels:

• Email: [email protected] — use subject line "Privacy Policy" or "DPO Enquiry"
• In-App Chat: Available 24/7 within your logged-in paldo Account
• Acknowledgement: All privacy enquiries will be acknowledged within twenty-four (24) hours
• Response: Substantive responses provided within ten (10) business days; complex requests within thirty (30) calendar days

If you wish to exercise your rights under the Data Privacy Act of 2012 or escalate an unresolved privacy complaint, you may also contact the National Privacy Commission of the Philippines. Contact details for the NPC are publicly available at the NPC's official website.