Privacy Policy

1. Overview

paldo ("paldo," "we," "us," or "our") operates the online gaming platform accessible at paldo.club. We are committed to safeguarding the privacy and personal data of every player who registers and uses our services. This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in connection with the paldo Platform.

This Policy is issued in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). By creating a paldo account or using any part of our Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2. Personal Data We Collect

Depending on how you interact with the paldo Platform, we may collect the following categories of personal data:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, government-issued ID number	Account verification, age verification (21+), KYC compliance
Contact Data	Email address, Philippine mobile number, residential address	Account communications, support, transaction notifications
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank)	Processing deposits and withdrawals in PHP
Technical Data	IP address, device type, browser, operating system, session logs	Platform security, fraud prevention, performance optimization
Usage Data	Games played, wager amounts, session duration, bonus usage	Responsible gaming monitoring, personalization, analytics
Communications Data	Live chat transcripts, support emails, feedback submissions	Customer support, quality assurance, dispute resolution

3. How We Collect Your Data

paldo collects personal data through the following means:

• Direct interactions: When you register an account, complete identity verification, make a deposit or withdrawal, contact our support team, or participate in promotions.
• Automated technologies: As you navigate the Platform, we automatically collect technical and usage data through cookies, server logs, and similar tracking technologies. See Section 10 for our full Cookies Policy.
• Third-party sources: We may receive data from identity verification providers, payment processors (such as GCash and PayMaya), and fraud prevention services to supplement the information you provide directly.
• Regulatory sources: In certain circumstances, we may receive information from PAGCOR or other regulatory bodies as part of our compliance obligations.

4. How We Use Your Personal Data

paldo processes your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your paldo account, including verifying your identity and age (21+ requirement).
• Service delivery: Enabling you to access and play games, process financial transactions in Philippine Peso (PHP), and use all Platform features.
• Regulatory compliance: Meeting our obligations under PAGCOR licensing conditions, the Data Privacy Act of 2012, Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior and administering self-exclusion, deposit limits, and other player protection tools.
• Customer support: Responding to your inquiries, resolving disputes, and improving our support services.
• Platform improvement: Analyzing usage patterns to enhance game performance, user experience, and Platform features.
• Marketing communications: Sending you promotional offers, bonus notifications, and updates about paldo — only where you have provided consent or where we have a legitimate interest, and always with an easy opt-out option.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to fulfill our obligations under the paldo Terms & Conditions, including account management and payment processing.
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA requirements, NPC directives, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

paldo does not sell, rent, or trade your personal data to third parties. We may share your data only in the following limited circumstances:

• Service providers: Trusted third-party vendors who assist us in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, and customer support tools. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection laws.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where required by law or regulatory directive.
• Law enforcement: Where we are legally required to disclose information in response to a valid court order, subpoena, or other lawful request from Philippine law enforcement authorities.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of paldo's business, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

Any third party receiving your personal data is required to maintain its confidentiality and security, and to use it only for the specific purpose for which it was shared.

7. Data Retention

paldo retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine anti-money laundering regulations.
• Support communications: Retained for two (2) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.

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

8. Data Security

paldo implements robust technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the paldo Platform.
• Encryption at rest for sensitive personal and financial data stored on our servers.
• Multi-factor authentication options for player accounts to prevent unauthorized access.
• Access controls ensuring that only authorized paldo personnel with a legitimate need can access personal data.
• Regular security audits and penetration testing conducted by independent cybersecurity professionals.
• Incident response procedures to detect, contain, and notify affected individuals and the NPC of any personal data breach within the timeframes required by the DPA.

While paldo takes every reasonable precaution to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your paldo account credentials.

9. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by paldo:

• Right to be informed: The right to know what personal data paldo collects and how it is processed — which this Policy fulfills.
• Right of access: The right to request a copy of the personal data paldo 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 our legal retention obligations.
• Right to object: The right to object to the 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 format and to transmit it to another controller.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days in accordance with NPC guidelines.

10. Cookies Policy

paldo uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze Platform usage.

• Essential cookies: Required for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and game display options to personalize your experience.
• Analytics cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized.
• Marketing cookies: Used to deliver relevant promotional content about paldo. These are only set with your explicit consent.

You can manage your cookie preferences through your browser settings at any time. Note that disabling essential cookies may affect the functionality of the paldo Platform.

11. Minors and Age Restriction

The paldo Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing real-money gaming in the Philippines. paldo does not knowingly collect personal data from individuals under 21 years of age. If we become aware that a minor has provided us with personal data or has accessed the Platform, we will immediately suspend the account, delete the associated personal data, and return any deposited funds.

If you are a parent or guardian and believe your child has registered on paldo, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

paldo reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before taking effect. The "Last Updated" date at the top of this Policy will always reflect the most recent revision. Your continued use of the Platform following the effective date of any changes constitutes your acceptance of the revised Policy.

13. Contact & Data Protection Officer

paldo has appointed a Data Protection Officer ("DPO") in accordance with the requirements of the Data Privacy Act of 2012 and NPC regulations. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our DPO:

• Email: [email protected]
• Subject line: "Data Privacy Request – [Your Name]"
• Response time: Within fifteen (15) business days of receipt of your verified request.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through their official channels.