panolo Privacy Policy

1 Who We Are

This Privacy Policy is issued by panolo ("panolo," "we," "us," "our"), the operator of the panolo online gaming platform accessible at panolo.net. panolo operates within the regulatory framework established by PAGCOR, the Philippine Amusement and Gaming Corporation, and is committed to protecting the personal data of all members and visitors in accordance with applicable Philippine data protection law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

For the purposes of this Privacy Policy, panolo acts as the Personal Information Controller in respect of the personal data of its members and website visitors. This means panolo determines the purposes and means of processing your personal data.

2 Personal Data We Collect

panolo collects the following categories of personal data from members and, in some cases, from visitors to the panolo website:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification document details (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, or other PAGCOR-accepted identification).
• Contact Data: Philippine mobile number, email address, and residential address (city/municipality, province, region).
• Account Data: panolo username, account registration date, account status, and account preferences.
• Financial Data: GCash or PayMaya / Maya account reference, bank account details (for bank transfer transactions), debit card details (card type and last four digits only — full card numbers are never stored by panolo), transaction history, deposit amounts, withdrawal amounts, and account balance history.
• Gaming Data: Game history, wager amounts, win/loss records, session duration, game preferences, and bonus usage history.
• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and session timestamps.
• Usage Data: Pages visited on the panolo website, features accessed, links clicked, and navigation patterns.
• Communications Data: Records of your communications with panolo support, including live chat transcripts and any documents or images you submit to panolo.
• Verification Data: Copies of identity documents and selfie photographs submitted for Know Your Customer ("KYC") verification purposes.

3 How We Collect Your Data

panolo collects personal data through the following means:

• Direct collection: Information you provide when registering a panolo account, completing KYC verification, making deposits or withdrawals, contacting panolo support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the panolo website or platform, through cookies, web beacons, and similar tracking technologies (see Section 7).
• Third-party sources: Identity verification data from third-party KYC and AML service providers; payment data from payment processors such as GCash, PayMaya / Maya, and partner banks; fraud prevention data from third-party fraud detection services.
• Regulatory sources: Data received from PAGCOR or other competent Philippine authorities in connection with regulatory compliance obligations.

4 Why We Use Your Personal Data

panolo uses your personal data for the following purposes:

• Account management: To register and maintain your panolo account, verify your identity, and manage your account preferences and settings.
• Service delivery: To provide access to panolo games, process deposits and withdrawals, credit bonuses, and deliver the core panolo gaming experience.
• Legal and regulatory compliance: To comply with PAGCOR licensing requirements, the Data Privacy Act of 2012, Anti-Money Laundering Act obligations, and other applicable Philippine laws and regulations. This includes KYC verification, transaction monitoring, and suspicious activity reporting.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other prohibited conduct on the panolo platform.
• Responsible gaming: To monitor gaming patterns and identify members who may be exhibiting signs of problem gambling, and to administer responsible gaming tools including deposit limits, loss limits, and self-exclusion.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing and promotions: To send you information about panolo promotions, bonuses, and new games — but only where you have consented to receive such communications. You may withdraw your marketing consent at any time through your panolo account settings.
• Platform improvement: To analyze usage patterns and improve the panolo platform, games, and user experience.

5 Legal Basis for Processing

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

• Contractual necessity: Processing necessary to perform the contract between you and panolo — i.e., to operate your panolo account and deliver the gaming services you have registered for.
• Legal obligation: Processing required to comply with panolo's legal and regulatory obligations under Philippine law, including PAGCOR licensing conditions, AML obligations, and data retention requirements.
• Legitimate interests: Processing necessary for panolo's legitimate interests in fraud prevention, platform security, and service improvement, where those interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Data Sharing & Disclosure

panolo does not sell your personal data to any third party. panolo 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 / Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers engaged by panolo to verify member identities and screen for sanctions and politically exposed persons.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission ("NPC"), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Technology service providers: Cloud hosting providers, game software providers, customer support platform providers, and cybersecurity service providers engaged by panolo to operate and maintain the panolo platform. All such providers are bound by data processing agreements requiring them to protect your data.
• Professional advisers: Lawyers, auditors, and accountants engaged by panolo, subject to professional confidentiality obligations.

7 Cookies & Tracking Technologies

The panolo website uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyze usage patterns. The following types of cookies are used:

• Strictly necessary cookies: Essential for the panolo platform to function. These include session cookies that keep you logged in during your visit. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences such as language settings, display preferences, and responsible gaming tool settings.
• Analytics cookies: Used to collect anonymized data about how visitors use the panolo website, helping panolo improve the platform. Analytics data is aggregated and does not identify individual users.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the panolo platform. Strictly necessary and security cookies cannot be disabled without preventing access to the platform.

8 Data Retention

panolo retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and identity data: Retained for a minimum of five (5) years from the date of account closure, in accordance with PAGCOR licensing requirements and AML obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with the Anti-Money Laundering Act.
• Gaming records: Retained for a minimum of three (3) years from the date of each gaming session.
• KYC verification documents: Retained for a minimum of five (5) years from the date of account closure.
• Support communications: Retained for a minimum of two (2) years from the date of the communication.

After the applicable retention period, personal data is securely deleted or anonymized in accordance with panolo's data disposal procedures.

9 Data Security

panolo implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the panolo platform.
• Encryption at rest for sensitive personal and financial data stored on panolo servers.
• Access controls: Strict role-based access controls limiting panolo staff access to personal data on a need-to-know basis.
• Multi-factor authentication for panolo staff accessing internal systems containing personal data.
• Regular security audits and penetration testing conducted by independent cybersecurity specialists.
• Incident response procedures: panolo maintains a documented data breach response plan. In the event of a personal data breach affecting your rights and freedoms, panolo will notify you and the National Privacy Commission within the timeframes required by the Data Privacy Act.

While panolo takes all reasonable steps to protect your data, no internet transmission is 100% secure. You are responsible for maintaining the confidentiality of your panolo login credentials and for ensuring that your device is adequately secured.

10 Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by panolo:

• Right to be informed: The right to be informed about how panolo collects and uses your personal data — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data panolo holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to panolo's legal retention obligations.
• Right to object: The right to object to panolo's processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe panolo has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact panolo's Data Protection Officer via live chat or by email at [email protected]. panolo will respond to all data rights requests within thirty (30) calendar days of receipt.

11 Children's Privacy

The panolo platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming law and PAGCOR regulations. panolo does not knowingly collect personal data from individuals under 21 years of age.

If panolo becomes aware that personal data has been collected from an individual under 21 years of age, panolo will immediately suspend the associated account, delete the personal data, and report the incident to the relevant regulatory authorities as required. If you believe that a minor has registered a panolo account, please contact panolo support immediately.

12 International Data Transfers

panolo's primary data processing infrastructure is located within the Philippines. In some cases, personal data may be transferred to and processed by panolo's service providers in other countries — for example, cloud infrastructure providers or game software providers with servers outside the Philippines.

Where personal data is transferred outside the Philippines, panolo ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses that require the recipient to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. panolo will not transfer your personal data to a country that does not provide an adequate level of data protection without your explicit consent or without appropriate contractual safeguards.

13 Updates to This Privacy Policy

panolo may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, panolo will notify registered members via the contact details associated with their account and will display a prominent notice on the panolo platform.

The "Last updated" date at the top of this page indicates when this Privacy Policy was most recently revised. Your continued use of the panolo platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree with any update, you must cease using the panolo platform and may request account closure in accordance with the panolo Terms & Conditions.

14 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or panolo's handling of your personal data, please contact panolo's Data Protection Officer through any of the following channels:

• Live Chat: Available 24/7 directly from the panolo platform — the fastest way to reach the support team for any privacy-related concern.
• Email: [email protected] — please include "Privacy Request" in the subject line so your message is routed to the Data Protection Officer promptly.

panolo's support team operates in Filipino-English and is available around the clock, every day of the year. All privacy-related requests will be acknowledged within 72 hours and resolved within thirty (30) calendar days of receipt.

If you are not satisfied with panolo's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.