PH Laro Privacy Policy

1 Introduction

PH Laro is committed to protecting the privacy and personal data of all users of our Platform. We understand that when you share your personal information with us, you are placing trust in us to handle it responsibly. This Privacy Policy sets out clearly and transparently how we fulfill that responsibility.

This Privacy Policy applies to all personal data collected by PH Laro in connection with your use of the Platform, including data collected through our website, mobile application, customer support channels, and any other means by which you interact with us. It should be read together with our Terms & Conditions and Responsible Gaming Policy.

PH Laro processes personal data in accordance 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). We are also guided by applicable PAGCOR regulations concerning player data and anti-money laundering compliance.

2 Data Controller

For the purposes of the Philippine Data Privacy Act, PH Laro is the personal information controller in respect of the personal data you provide when using the Platform. This means we determine the purposes and means of processing your personal data.

If you have any questions or concerns about how PH Laro processes your personal data, or if you wish to exercise any of your rights under the Data Privacy Act, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 15 of this Privacy Policy.

3 Personal Data We Collect

PH Laro collects the following categories of personal data from users of the Platform:

Identity & Contact Data:

• Full legal name, date of birth, and gender
• Residential address (including city, province, and postal code)
• Email address and mobile phone number
• Government-issued identification document details (e.g., passport number, driver's license number, PhilSys ID number)

Account & Transaction Data:

• Username, password (stored in encrypted form), and account preferences
• Deposit and withdrawal history, transaction amounts, and payment method details
• Betting history, game activity, and wagering records
• Bonus and promotion usage records

Technical & Usage Data:

• IP address, device type, operating system, and browser type
• Pages visited, features used, and time spent on the Platform
• Login timestamps and session duration
• Geolocation data (where permitted and relevant to regulatory compliance)

Communications Data:

• Records of your communications with our customer support team
• Feedback, survey responses, and complaints submitted to PH Laro
• Marketing communication preferences and opt-in/opt-out records

4 How We Collect Your Data

PH Laro collects personal data through the following means:

• Direct collection: Information you provide when registering an 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 and use the Platform, including through cookies, web beacons, and similar tracking technologies (see Section 9).
• Third-party sources: Identity verification and fraud prevention data from KYC service providers; payment and transaction data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank; and compliance data from regulatory databases where required by law.

We collect only the personal data that is necessary for the purposes described in this Privacy Policy. We do not collect personal data that is excessive or irrelevant to those purposes.

5 How We Use Your Personal Data

PH Laro uses the personal data we collect for the following purposes:

PH Laro does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have given explicit consent.

6 Legal Basis for Processing

Under the Philippine Data Privacy Act, PH Laro processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including account management, transaction processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws and regulations, including PAGCOR requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for PH Laro's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications and certain cookie uses. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

PH Laro does not sell, rent, or trade your personal data to third parties. We 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 your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers engaged to verify your identity and comply with regulatory requirements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulation.
• Technology and service providers: Cloud hosting providers, IT security firms, analytics providers, and customer support platform providers engaged by PH Laro to operate and maintain the Platform, subject to strict data processing agreements.
• Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by PH Laro, where necessary for legal compliance or dispute resolution.
• Law enforcement: Where required by a valid court order, subpoena, or other lawful legal process.

8 Data Retention

PH Laro retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account and identity 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 requirements.
• Transaction and betting records: Retained for a minimum of five (5) years from the date of the transaction, as required by anti-money laundering regulations.
• Customer support communications: Retained for three (3) years from the date of the communication, or longer if related to an ongoing dispute or legal matter.
• Marketing preferences: Retained until you withdraw consent or request deletion, subject to any overriding legal retention obligations.
• Technical and usage data: Retained for up to two (2) years from collection, unless required for longer for security or fraud prevention purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

9 Cookies & Tracking Technologies

PH Laro uses cookies and similar tracking technologies (such as web beacons and pixel tags) on our Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and improve your experience on the Platform.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Used to remember your preferences and settings, such as language preferences and display options, to provide a more personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data about how users interact with the Platform, helping us understand usage patterns and improve our services.
• Marketing cookies: Used to deliver relevant promotional content to you based on your interests and activity on the Platform, where you have given consent.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

10 Data Security

PH Laro implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including passwords and financial information.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of our systems.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While we take all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

11 Your Data Privacy Rights

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

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data PH Laro 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 we hold 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 our legal retention obligations.
• Right to object: The right to object to the processing of your personal data where we rely on legitimate interests as the legal basis, or where your data is used for direct marketing.
• 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 your data privacy rights have been violated.

12 Children's Privacy

PH Laro is strictly an adult platform. In accordance with Philippine gaming regulations and our Terms & Conditions, users must be at least 21 years of age to register and use the Platform. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on PH Laro, please contact our support team immediately using the details in Section 15.

13 International Data Transfers

PH Laro primarily stores and processes 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 technology partners operating in other jurisdictions.

Where such transfers occur, PH Laro ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses consistent with the requirements of the Philippine Data Privacy Act and NPC regulations. We will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without implementing appropriate safeguards.

14 Updates to This Privacy Policy

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

Where we make material changes to this Privacy Policy, we will notify registered users via email or through a prominent notice on the Platform prior to the changes taking effect. We encourage you to review this Privacy Policy periodically to stay informed about how PH Laro protects your personal data.

Your continued use of the Platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated Privacy Policy, you should cease using the Platform and may request account closure in accordance with our Terms & Conditions.

15 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by PH Laro, please contact our Data Protection Officer. We are committed to addressing all data privacy inquiries promptly and transparently.

We aim to respond to all data privacy requests within thirty (30) calendar days of receipt. In complex cases, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. For general platform support, account queries, or responsible gaming assistance, please visit our FAQ page or our Responsible Gaming page.