panolo Privacy Policy

panolo ("panolo," "we," "us," or "our") is committed to protecting the privacy and personal data of every individual who visits, registers with, or otherwise interacts with the panolo online casino and sports betting platform accessible at panolo.org (the "Platform"). This Privacy Policy explains how we collect, use, store, share, and protect personal data in connection with the Platform and our services.

This Privacy Policy applies to all users of the panolo Platform, including registered account holders, visitors who browse without registering, and any individual whose personal data is processed by panolo in connection with the provision of its services. It applies to data collected through the Platform, via our customer support channels, and through any other means by which you interact with panolo.

Please read this Privacy Policy carefully. If you do not agree with the practices described in this document, you should not use the panolo Platform or provide us with any personal data. Your continued use of the Platform constitutes your acceptance of this Privacy Policy as updated from time to time.

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, panolo is the personal information controller in respect of the personal data collected through the Platform. We determine the purposes and means of processing personal data that players and visitors share with us, and we are responsible for ensuring that such processing is lawful, fair, and transparent.

Certain processing activities — such as payment processing, identity verification, and game provision — are carried out on our behalf by carefully selected third-party service providers. These providers act as personal information processors and are contractually bound to handle personal data only in accordance with our instructions and applicable data protection law.

panolo serves Filipino players across the Philippines, including in Manila, Cebu, Davao, Quezon City, and Makati. Our Platform is operated for the Philippine market, and data protection practices are designed to meet the standards required under Philippine law.

panolo collects personal data that is necessary for the lawful provision of our services. The categories of personal data we collect include the following:

panolo does not intentionally collect sensitive personal data (as defined under the Data Privacy Act of 2012) beyond what is strictly necessary for identity verification and responsible gaming compliance. We do not collect biometric data except where a selfie photograph is required for identity verification purposes.

panolo collects personal data through the following means:

• Directly from you: When you register a panolo account, complete KYC verification, make a deposit or withdrawal, contact our support team, respond to a promotion, or update your account settings.
• Automatically through the Platform: When you access or use the panolo Platform, we automatically collect technical and usage data through server logs, cookies, and similar tracking technologies (see Section 8 for details).
• From third-party payment processors: When you make a deposit or withdrawal through GCash, PayMaya, BPI, BDO, Metrobank, or card networks, we receive transaction confirmation and associated account reference data from those payment providers.
• From identity verification providers: When KYC verification is conducted through a third-party verification service, we receive the outcome and associated identity data from that provider.
• From fraud prevention and security services: We may receive data from third-party fraud screening services that assists us in identifying and preventing fraudulent activity on the Platform.

panolo uses personal data for the following specific purposes:

• Account creation and management: To register your panolo account, verify your identity, maintain your account, process login events, and communicate essential account information to you.
• Payment processing: To process deposits and withdrawals via your chosen payment method (GCash, PayMaya, bank transfer, card), and to maintain accurate financial records.
• Service provision: To enable your access to games, live casino tables, sports betting, sabong, bingo, and all other features available on the panolo Platform.
• Identity verification and KYC compliance: To verify your age (21+ requirement), identity, and payment method ownership as required by applicable regulations.
• Security and fraud prevention: To monitor login activity, detect suspicious patterns, prevent unauthorised access, investigate potential fraud, and protect the integrity of the Platform and its players.
• Responsible gaming: To administer deposit limits, session time reminders, self-exclusion arrangements, and other responsible gaming tools, and to comply with obligations to identify and assist players who may be experiencing problem gambling.
• Customer support: To respond to your queries, complaints, and requests via live chat and email.
• Legal and regulatory compliance: To fulfil obligations under Philippine law, including the Data Privacy Act, anti-money laundering regulations, and requirements applicable to online gaming platforms operating in the Philippines.
• Platform improvement: To analyse usage patterns, troubleshoot technical issues, and develop improvements to the Platform's features and performance.
• Marketing communications: To send you promotional offers, bonus notifications, and product updates, where you have consented to receive such communications. You may withdraw consent at any time through your account settings.

Under the Data Privacy Act of 2012, panolo processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil the contract between you and panolo — i.e., the provision of the Platform services and the processing of transactions — is necessary for the performance of that contract.
• Legal obligation: Processing required to comply with applicable Philippine laws, including identity verification requirements, anti-money laundering obligations, age verification requirements, and record-keeping obligations.
• Legitimate interests: Processing carried out for panolo's legitimate business interests, including fraud prevention, Platform security, responsible gaming monitoring, and service improvement — where such interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily in the context of optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

panolo does not sell, rent, or trade your personal data to third parties for advertising or commercial profiling purposes. We share personal data only in the following circumstances and with the following categories of recipient:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other payment processors who require relevant data to authorise and process your transactions.
• Identity and KYC verification providers: Third-party identity verification services engaged by panolo to verify player identity and age in accordance with regulatory requirements.
• Game content providers: Licensed game studios and content providers whose games are available on the panolo Platform. These providers may receive anonymised or pseudonymised gaming session data for technical and audit purposes.
• Fraud prevention and security services: Third-party providers engaged to assist with detecting and preventing fraudulent activity on the Platform.
• Cloud infrastructure and hosting providers: Service providers who host the panolo Platform and associated data systems on secure server infrastructure.
• Customer support platforms: Third-party customer support software providers used to facilitate our live chat and communication services.
• Regulatory and law enforcement authorities: Where required by law, court order, or regulatory directive, panolo will disclose personal data to government bodies, law enforcement agencies, the National Privacy Commission, or other competent authorities in the Philippines.
• Successors in interest: In the event of a merger, acquisition, or transfer of business assets involving panolo, personal data may be transferred to the acquiring entity, subject to appropriate data protection safeguards.

panolo uses cookies and similar tracking technologies to operate the Platform, maintain your session, and analyse usage patterns. A cookie is a small text file placed on your device by a website server. Cookies cannot execute programs or deliver viruses to your device.

panolo uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that maintain your logged-in state, security tokens, and cookies that remember your language and region settings. These cookies cannot be disabled without impairing the Platform's functionality.
• Performance and analytics cookies: Used to collect anonymised information about how players use the Platform — pages visited, time spent, errors encountered. This data helps us identify and resolve performance issues and improve the Platform.
• Functional cookies: Used to remember your preferences and personalisation choices, such as game lobby display settings and notification preferences.
• Responsible gaming cookies: Used to maintain and enforce session time limits, deposit limit settings, and self-exclusion status across your sessions on the Platform.

Most web browsers allow you to control cookie settings through the browser menu. Disabling strictly necessary cookies will impair the functionality of the panolo Platform and may prevent you from accessing your account. Disabling other cookie categories will limit Platform functionality but will not prevent basic access.

panolo retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the duration of your active panolo account and for a period of five (5) years following account closure, in accordance with applicable record-keeping obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required under applicable anti-money laundering and tax regulations in the Philippines.
• Identity verification documents: Retained for a minimum of five (5) years from account closure or the date of verification, whichever is later, as required by applicable KYC regulations.
• Customer support records: Support correspondence and chat transcripts are retained for three (3) years from the date of the interaction, unless retention beyond that period is required for dispute resolution or legal proceedings.
• Marketing consent records: Records of your marketing consent are retained for as long as you remain opted in, plus five (5) years thereafter to demonstrate compliance.
• Technical and log data: Server logs and technical data are retained for up to twelve (12) months from collection, unless retention is required for a specific security investigation.

When personal data is no longer required and retention obligations have expired, panolo will securely delete, anonymise, or destroy the data using appropriate technical measures.

panolo implements a range of technical and organisational security measures designed to protect personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include, but are not limited to:

• SSL/TLS encryption: All data transmitted between your device and panolo's servers is encrypted in transit using industry-standard SSL/TLS protocols — the same standard used by Philippine banks and major e-wallet providers.
• Encryption at rest: Sensitive personal data, including financial details and identity documents, is encrypted at rest on panolo's servers using strong encryption standards.
• Access controls: Access to personal data within panolo's systems is restricted on a strict need-to-know basis. Staff access rights are regularly reviewed and revoked when no longer required.
• Password hashing: Account passwords are stored as one-way cryptographic hashes. panolo never stores plaintext passwords and cannot retrieve your password — only reset it via a verified identity process.
• OTP verification: Login from unrecognised devices requires OTP verification via your registered Philippine mobile number, providing an additional layer of account security.
• Intrusion detection and monitoring: panolo's infrastructure is monitored for unusual activity, potential intrusions, and security incidents on a continuous basis.
• Incident response: panolo maintains a formal data breach incident response procedure. In the event of a breach that poses a risk to player rights, we will notify affected players and the National Privacy Commission in accordance with the Data Privacy Act of 2012.

While panolo takes all reasonable precautions to protect personal data, no internet transmission or electronic storage system is completely secure. You are responsible for keeping your own account credentials confidential and for ensuring that no unauthorised person accesses your panolo account through your device.

Under the Data Privacy Act of 2012, you have the following rights in relation to personal data that panolo holds about you. These rights may be subject to certain limitations and exceptions under applicable law.

To exercise any of these rights, please contact panolo's support team via 24/7 live chat accessible from your logged-in account, or via email at [email protected]. panolo will respond to verified requests within thirty (30) calendar days of receipt. Complex requests may require an extension of up to an additional thirty (30) days, in which case we will notify you of the extension and the reason.

panolo may request proof of identity before processing a data rights request to ensure that we are not disclosing or modifying data at the request of an unauthorised person. If you are dissatisfied with panolo's response to a data rights request, you have the right to file a complaint with the National Privacy Commission of the Philippines.

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

If panolo becomes aware or has reasonable grounds to suspect that personal data has been collected from a person under 21 years of age, we will take immediate steps to close the relevant account, return any deposited funds (net of any winnings), and delete the associated personal data from our systems as promptly as is reasonably practicable.

If you believe that a person under 21 has registered on the panolo Platform, please contact our support team immediately so that we can investigate and take appropriate action.

panolo's primary data processing infrastructure is operated in connection with the Philippine market. However, certain service providers engaged by panolo — including cloud hosting providers, game studios, and fraud prevention services — may process personal data in server locations outside the Philippines.

Where personal data is transferred to recipients outside the Philippines, panolo ensures that such transfers are conducted in accordance with the requirements of the Data Privacy Act of 2012 and its implementing rules. This includes ensuring that appropriate safeguards are in place — such as contractual data transfer clauses — to provide a level of data protection substantially equivalent to that available under Philippine law.

panolo does not permit any international transfer of personal data to jurisdictions that do not provide adequate levels of data protection without first implementing appropriate technical and contractual safeguards.

panolo reserves the right to update or amend this Privacy Policy at any time. The current version of the Privacy Policy will always be accessible at panolo.org/privacy-policy and will display the effective date of the most recent revision at the top of the document.

Where a material change is made to this Privacy Policy, panolo will use reasonable efforts to notify active account holders via their registered contact information (e.g., SMS to the mobile number registered with the panolo account) before the change takes effect.

Your continued use of the panolo Platform following the effective date of any revision constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you should stop using the Platform and request closure of your account by contacting our support team before the effective date of the revision.

If you have any questions, concerns, or requests relating to this Privacy Policy or panolo's data protection practices, please contact us through the following channels:

• Live Chat: Available 24/7 through your logged-in panolo account dashboard. This is the fastest channel for data rights requests and privacy-related enquiries.
• Email: [email protected] — for privacy-related matters, please include "Privacy Request" in the subject line of your message for prompt routing to the appropriate team.
• Platform: All support options are accessible at panolo.org once you have completed the panolo Login.

panolo has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. Data rights requests, privacy complaints, and DPO correspondence should be directed to [email protected] with the subject line "Data Protection Officer."

If you are not satisfied with panolo's response to a privacy concern or data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines, the regulatory authority responsible for data privacy enforcement in the Philippines.