PaldoWin Privacy Policy

1 Introduction

PaldoWin ("PaldoWin," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our platform. This Privacy Policy describes how PaldoWin collects, uses, stores, shares, and protects personal information in connection with the PaldoWin website at paldowin.app, the PaldoWin mobile application, and all associated services (collectively, the "Platform").

This Privacy Policy applies to all registered players, visitors to the Platform, and any individual whose personal data is processed by PaldoWin in connection with the provision of our services. It should be read alongside PaldoWin's Terms & Conditions and Responsible Gaming Policy.

P aldoWin reserves the right to update this Privacy Policy from time to time. Any material changes will be communicated to registered players via email or a prominent notice on the Platform. The date of the most recent revision is indicated at the top of this page.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), PaldoWin acts as the Personal Information Controller in respect of the personal data collected through the Platform. This means PaldoWin determines the purposes and means by which your personal data is processed.

PaldoWin has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection laws and handling data-related inquiries and complaints. You may contact the DPO at the address provided in Section 14 of this Policy.

3 Data We Collect

PaldoWin collects personal data that is necessary to provide our services, verify player identity, process financial transactions, and comply with applicable Philippine regulatory requirements. The categories of personal data we collect include:

4 How We Use Your Data

PaldoWin uses your personal data for the following purposes:

• Account Registration & Verification: To create and manage your PaldoWin account, verify your identity, and confirm that you meet the 21+ age requirement mandated by Philippine gaming regulations.
• Service Delivery: To provide access to PaldoWin games including Boxing, Fishing Disco, Super Keno, Mines Grand, King of Fishing, Darts, and all other Platform features.
• Financial Transactions: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other approved Philippine payment channels, and to maintain accurate transaction records.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Philippine Data Privacy Act, and any other applicable laws and regulations.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other security threats to the Platform and its players.
• Responsible Gaming: To monitor gaming behaviour, enforce deposit and session limits, process self-exclusion requests, and identify players who may be at risk of gambling-related harm.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyse usage patterns, conduct internal research, and improve the features, performance, and user experience of the PaldoWin platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time.

5 Legal Basis for Processing

PaldoWin processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and PaldoWin, including providing access to the Platform, processing transactions, and managing your account.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests: Processing is necessary for PaldoWin's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities, such as marketing communications and the use of non-essential cookies, PaldoWin relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

PaldoWin does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary and for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other approved Philippine payment service providers, for the purpose of processing deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and identity verification service providers engaged to assist with age verification and fraud prevention.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory obligation.
• Technology Service Providers: Cloud hosting providers, cybersecurity firms, and software vendors engaged to support the operation and security of the Platform, all of whom are bound by appropriate data processing agreements.
• Professional Advisers: Legal counsel, auditors, and compliance consultants, where necessary for the conduct of PaldoWin's business.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other lawful process.

7 Cookies & Tracking Technologies

PaldoWin uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session security, and gather analytics data. The types of cookies we use include:

• Essential Cookies: Strictly necessary for the Platform to function. These cookies enable core features such as account login, session management, and security. They cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players interact with the Platform, including pages visited, time spent, and features used. This data helps PaldoWin improve the Platform experience.
• Preference Cookies: Used to remember your settings and preferences, such as language selection and display options, so you do not need to re-enter them on each visit.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot traffic and account takeover attempts.

You may manage your cookie preferences through your browser settings. Please note that disabling essential cookies may impair your ability to use certain features of the Platform. PaldoWin does not use third-party advertising cookies or cross-site tracking technologies.

8 Data Retention

PaldoWin retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLA record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC & Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer Support Records: Retained for a minimum of two (2) years from the date of the last interaction, or longer if required for ongoing dispute resolution.
• Technical & Usage Logs: Retained for up to twelve (12) months, unless a longer retention period is required for security investigation or legal proceedings.

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

9 Data Security

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

• SSL/TLS Encryption: All data transmitted between your device and PaldoWin's servers is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Secure Data Storage: Personal and financial data is stored on secure, access-controlled servers with encryption at rest.
• Access Controls: Access to personal data is restricted to authorised PaldoWin personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-Factor Authentication: PaldoWin supports and encourages the use of two-factor authentication (2FA) to protect player accounts from unauthorised access.
• Regular Security Audits: PaldoWin conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in the Platform.
• Incident Response: PaldoWin maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, PaldoWin will notify the National Privacy Commission and affected players in accordance with applicable law.

10 Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by PaldoWin:

• Right to Be Informed: The right to be informed of how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data PaldoWin holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data PaldoWin holds about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to PaldoWin's legal and regulatory 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 legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe PaldoWin has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact PaldoWin's Data Protection Officer using the contact details provided in Section 14. PaldoWin will respond to all valid requests within thirty (30) days of receipt, in accordance with the Data Privacy Act.

11 Children's Privacy

PaldoWin's Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. PaldoWin does not knowingly collect personal data from individuals under the age of 21.

If PaldoWin becomes aware that personal data has been collected from a person under 21, the relevant account will be immediately suspended, all associated data will be deleted, and any deposits will be returned to the source payment method where possible.

If you are a parent or guardian and believe that your child has registered on PaldoWin, please contact us immediately at the details provided in Section 14 so that we can take prompt action.

12 Cross-Border Data Transfers

PaldoWin primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed from servers or service providers located outside the Philippines, for example in connection with cloud hosting or cybersecurity services.

Where such cross-border transfers occur, PaldoWin ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission.
• Implementing contractual clauses with overseas service providers that require them to protect your personal data to standards equivalent to those required under Philippine law.
• Conducting due diligence on all overseas data processors to verify their data security practices prior to engagement.

13 Policy Updates

PaldoWin may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, PaldoWin will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how PaldoWin protects your personal data. Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the changes.

14 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way PaldoWin handles your personal data, please contact our Data Protection Officer:

Data Protection Officer, PaldoWin
Email: [email protected]

For general support inquiries, you may also reach our customer support team at [email protected]. Email addresses on this page are provided as plain text for reference only and are not clickable links.

If you are not satisfied with PaldoWin's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC and its complaint process is publicly available through official Philippine government channels.