paldoph Privacy Policy

paldoph ("we," "us," "our") is committed to protecting the privacy and personal data of all users ("you," "your") of the paldoph online gaming platform accessible at paldoph.app (the "Platform"). This Privacy Policy has been prepared in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy applies to all personal data collected by paldoph in connection with your registration, use of the Platform, participation in games, processing of financial transactions, and any communications you have with paldoph. By creating an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Privacy Policy should be read together with the paldoph Terms & Conditions. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters of data privacy, this Privacy Policy shall prevail.

paldoph collects the following categories of personal data in connection with the operation of the Platform:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification document.
• Date of birth (used to verify that you are at least 21 years of age).
• Residential address, city, and province within the Philippines.
• Email address and mobile number registered to your account.
• Government-issued identification document number and a copy of the document (for KYC verification).

2.2 Financial Data

• GCash or Maya (PayMaya) mobile wallet number linked to your account for deposits and withdrawals.
• Philippine bank account details (account name, account number, bank name) where bank transfer is used.
• Debit card details (card number, expiry date) where debit card payment is used — stored in tokenised form only.
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used.

2.3 Gaming and Activity Data

• Game participation history, including games played, bet amounts, outcomes, and session durations.
• Bonus and promotion usage history.
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion status).
• Customer support interaction records, including chat transcripts and email correspondence.

2.4 Technical and Device Data

• IP address and approximate geolocation (used to verify Philippine residency and detect fraud).
• Device type, operating system, and browser type.
• Mobile network operator (Globe, Smart, DITO, or other).
• Cookie identifiers and session tokens (see Section 8).
• Platform access logs, including login timestamps and pages visited.

paldoph collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Data collected automatically when you access the Platform, including through cookies, web beacons, and server logs (see Section 8).
• Third-party sources: Data received from KYC verification providers, payment processors (GCash, Maya, banks), and fraud detection services in connection with the operation of your account.
• Regulatory sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with compliance obligations.

paldoph processes your personal data for the following purposes and on the following legal bases under the Data Privacy Act of 2012:

• Account creation and management — necessary for the performance of the contract between you and paldoph.
• Identity verification (KYC) — required by Philippine anti-money laundering laws (AMLA) and PAGCOR regulations; processing is necessary for compliance with a legal obligation.
• Payment processing — necessary for the performance of the contract; required to facilitate deposits and withdrawals in Philippine Peso.
• Fraud prevention and security — necessary for the legitimate interests of paldoph in protecting the integrity of the Platform and the safety of all users.
• Responsible gaming compliance — required by PAGCOR guidelines; processing is necessary for compliance with a legal obligation and for the protection of your vital interests.
• Customer support — necessary for the performance of the contract and for the legitimate interests of paldoph in maintaining service quality.
• Marketing and promotions — based on your consent, where you have opted in to receive promotional communications from paldoph. You may withdraw consent at any time.
• Platform analytics and improvement — based on the legitimate interests of paldoph in improving the user experience and Platform performance.
• Regulatory reporting — required by applicable Philippine law, including AMLA reporting obligations and PAGCOR compliance requirements.

paldoph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following circumstances:

• Service providers: We share data with trusted third-party service providers who assist in operating the Platform, including KYC verification providers, payment processors (GCash, Maya, Philippine banks), IT infrastructure providers, and customer support platforms. These providers are contractually bound to process your data only on paldoph's instructions and in accordance with applicable Philippine data privacy law.
• Regulatory and law enforcement authorities: We disclose data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities where required by law, court order, or regulatory directive.
• Fraud prevention: We may share data with fraud detection and prevention services where we have reasonable grounds to suspect fraudulent activity, money laundering, or other criminal conduct.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of paldoph's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Privacy Policy. You will be notified of any such transfer via your registered email address.

paldoph 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, whichever is longer.

• Account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in accordance with PAGCOR record-keeping requirements and AMLA obligations.
• 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 documents: Retained for a minimum of five (5) years after the end of the business relationship, or longer if required by a regulatory directive or ongoing investigation.
• Customer support records: Retained for three (3) years from the date of the interaction.
• Marketing data: Retained until you withdraw consent or request deletion, whichever is earlier.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with NPC guidelines.

paldoph implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the paldoph Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Tokenisation of payment card details — paldoph does not store raw card numbers.
• Role-based access controls limiting access to personal data to authorised paldoph personnel on a strict need-to-know basis.
• Regular security assessments and vulnerability testing of Platform infrastructure.
• Staff training on data privacy obligations under the Data Privacy Act of 2012.

In the event of a personal data breach that is likely to result in serious harm to affected individuals, paldoph will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected users without undue delay, in accordance with NPC Circular 16-03.

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

paldoph uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. We use the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in and security cookies that help detect fraud. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations.
• Analytics cookies: Help us understand how users interact with the Platform — which pages are visited most, where users encounter errors, and how navigation flows are used. This data is aggregated and anonymised.
• Performance cookies: Monitor Platform load times and technical performance to help our engineering team identify and resolve issues quickly.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. paldoph does not use cookies to serve third-party advertising or to track your activity on other websites.

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by paldoph:

• Right to be informed: You have the right to be informed of how your personal data is collected, used, and shared — which is the purpose of this Privacy Policy.
• Right of access: You may request a copy of the personal data paldoph holds about you, along with information about how it is being processed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data held by paldoph. You may update basic account details directly through your account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to paldoph's legal retention obligations under AMLA and PAGCOR regulations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to paldoph's overriding legal obligations.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: If you believe paldoph has violated your data privacy rights, you may lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer at support@paldoph.app. We will respond to all verified requests within fifteen (15) business days. We may require you to verify your identity before processing your request.

The paldoph Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. paldoph does not knowingly collect personal data from individuals under 21 years of age.

If paldoph becomes aware that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, delete the personal data, and report the matter to PAGCOR as required. If you believe a minor has registered on the Platform, please notify us immediately at support@paldoph.app.

paldoph primarily processes and stores personal data within the Republic of the Philippines. Where it is necessary to transfer personal data to service providers located outside the Philippines — for example, cloud infrastructure providers or international KYC verification services — paldoph ensures that such transfers are subject to appropriate safeguards, including contractual data processing agreements that impose data protection standards equivalent to those required under the Data Privacy Act of 2012.

paldoph will not transfer your personal data to a foreign jurisdiction unless that jurisdiction provides an adequate level of protection for personal data, or appropriate contractual safeguards are in place, in accordance with NPC guidelines on cross-border data transfers.

paldoph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC issuances. Where changes are material, we will notify you by posting a prominent notice on the Platform or by sending an email to your registered address at least seven (7) days before the changes take effect.

Your continued use of the paldoph Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We recommend that you review this Privacy Policy periodically. The current version is always accessible on the Platform.

paldoph has designated a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO at:

We aim to acknowledge all privacy-related enquiries within two (2) business days and to provide a substantive response within fifteen (15) business days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.