Privacy Policy

This Privacy Policy is issued by paldo 77 (referred to in this document as "paldo 77", "we", "us", or "our"), the operator of the online gaming platform accessible at paldo-77.org. paldo 77 acts as the personal information controller in respect of the personal data collected from players and visitors to the platform.

As a personal information controller under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA"), paldo 77 is responsible for determining the purposes and means of processing your personal data. We have appointed a Data Protection Officer (DPO) who oversees our data privacy compliance program and serves as the primary point of contact for data privacy matters.

This Privacy Policy applies to all personal data collected through the paldo 77 website, any associated mobile applications, customer support channels, and any other touchpoints through which you interact with paldo 77. By using the paldo 77 platform, you acknowledge that you have read and understood this Privacy Policy.

paldo 77 collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected and processed. The categories of personal data we collect include:

Identity and Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify that you meet the 21+ age requirement)
• Email address (primary communication channel)
• Mobile phone number
• Residential address, including city (e.g., Manila, Cebu, Davao, Quezon City, Makati) and province
• Nationality and country of residence

Identity Verification (KYC) Data

• Copies of government-issued photo identification (Philippine passport, driver's license, SSS/UMID card, or equivalent)
• Proof of address documents (utility bills, bank statements, or similar)
• Selfie photographs submitted for identity verification purposes
• Source of funds documentation where required by anti-money laundering regulations

Financial Data

• Payment method details (GCash account number, PayMaya account, BPI/BDO/Metrobank account details — stored only to the extent necessary for transaction processing)
• Transaction history, including deposit amounts, withdrawal amounts, and dates
• Bonus and promotional activity records

Gaming Activity Data

• Game session records, including games played, bet amounts, win/loss outcomes, and session duration
• Responsible gaming tool settings (deposit limits, session reminders, self-exclusion status)
• Account balance history

Technical and Usage Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Pages visited on the paldo 77 platform and time spent on each page
• Referring website or source through which you arrived at paldo 77
• Cookie identifiers and similar tracking data (see Section 07)

Communications Data

• Records of your communications with paldo 77 customer support, including email correspondence and live chat transcripts
• Feedback, complaints, and dispute records

paldo 77 collects personal data through the following means:

• Direct collection: Data 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 paldo 77 platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud service providers; payment transaction data from payment processors (GCash, PayMaya, BPI, BDO, Metrobank); and publicly available information where relevant to regulatory compliance.

Where paldo 77 collects personal data from third-party sources, we ensure that such collection is lawful and that the third party has the appropriate authority to share the data with us.

paldo 77 uses your personal data for the following purposes:

Under the Philippine Data Privacy Act of 2012, paldo 77 processes your personal data on the following legal bases:

• Contractual necessity: Processing that is necessary to perform the contract between you and paldo 77 — including account registration, payment processing, and the provision of gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering laws (Republic Act No. 9160, as amended), PAGCOR licensing requirements, and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for the legitimate interests of paldo 77, including fraud prevention, platform security, and improving our services — provided that such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications. You may withdraw your consent at any time by contacting us at [email protected] or by updating your communication preferences in your account settings.

paldo 77 does not sell, rent, or trade your personal data. We share your personal data only in the following limited circumstances:

Service Providers (Personal Information Processors)

paldo 77 engages trusted third-party service providers who process personal data on our behalf and under our instructions. These include:

• KYC and identity verification providers — to verify your identity and age in compliance with regulatory requirements.
• Payment processors — including GCash, PayMaya, BPI, BDO, and Metrobank — to process your deposits and withdrawals.
• Fraud prevention and AML screening providers — to detect and prevent fraudulent activity and money laundering.
• Cloud hosting and IT infrastructure providers — to host and maintain the paldo 77 platform securely.
• Customer support platform providers — to facilitate our customer support operations.
• Analytics providers — to help us understand how the platform is used and to improve our services (using anonymized or aggregated data where possible).

All service providers engaged by paldo 77 are required to process personal data only in accordance with our instructions and to implement appropriate security measures. We do not permit our service providers to use your personal data for their own purposes.

Regulatory and Law Enforcement Authorities

paldo 77 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other government authorities where required to do so by applicable Philippine law, court order, or regulatory requirement.

Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of the assets of paldo 77, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and of any material changes to this Privacy Policy that result from it.

The paldo 77 platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and gather analytics data. A cookie is a small text file placed on your device when you visit a website.

Types of Cookies We Use

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that keep you logged in during your visit. These cookies cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences (such as language settings and responsible gaming tool configurations) to provide a more personalized experience.
• Analytics cookies: Help us understand how players use the paldo 77 platform — which pages are visited most, where users encounter difficulties, and how we can improve the overall experience. Data collected by analytics cookies is aggregated and anonymized where possible.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and other security threats.

Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is set. Please note that disabling certain cookies may affect the functionality of the paldo 77 platform — in particular, disabling strictly necessary cookies will prevent you from logging in or maintaining a session.

For detailed instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

paldo 77 retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

Upon expiry of the applicable retention period, paldo 77 will securely delete or anonymize your personal data. Where anonymization is applied, the resulting data can no longer be linked to you and is no longer subject to this Privacy Policy.

paldo 77 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• Encryption in transit: All data transmitted between your device and the paldo 77 platform is encrypted using TLS (Transport Layer Security) protocols.
• Encryption at rest: Sensitive personal data stored on paldo 77 servers is encrypted at rest using industry-standard encryption algorithms.
• Access controls: Access to personal data is restricted to paldo 77 personnel and service providers who have a legitimate need to access it. All access is logged and monitored.
• Two-factor authentication: paldo 77 supports and encourages the use of two-factor authentication (2FA) on player accounts to provide an additional layer of security.
• Regular security assessments: paldo 77 conducts regular security assessments and penetration testing to identify and address potential vulnerabilities in our systems.
• Staff training: All paldo 77 personnel who handle personal data receive regular data privacy and security training.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, paldo 77 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the requirements of the Data Privacy Act.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by paldo 77:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right to access: You have the right to request a copy of the personal data that paldo 77 holds about you, along with information about how it is being processed.
• Right to correction: You have the right to request that inaccurate or incomplete personal data held by paldo 77 be corrected or updated.
• Right to erasure (right to be forgotten): You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful — subject to paldo 77's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data where paldo 77 relies on legitimate interests as the legal basis for processing, or where your data is being processed for direct marketing purposes.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another personal information controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that paldo 77 has violated your data privacy rights. The NPC can be contacted at privacy.gov.ph.

To exercise any of the rights listed above, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Rights Request". paldo 77 will respond to your request within 15 business days of receipt. We may need to verify your identity before processing your request.

The paldo 77 platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. paldo 77 does not knowingly collect personal data from individuals under the age of 21.

During the registration process, paldo 77 requires all applicants to confirm that they are at least 21 years of age and to provide date of birth information that is verified through our KYC process. Any account found to have been registered by a person under 21 years of age will be immediately closed and all associated data will be deleted, except where retention is required by law.

If you believe that paldo 77 has inadvertently collected personal data from a person under the age of 21, please contact us immediately at [email protected] so that we can take appropriate action.

paldo 77 primarily processes personal data within the Philippines. However, some of our service providers — including cloud hosting providers, KYC verification services, and analytics platforms — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, paldo 77 ensures that appropriate safeguards are in place to protect your data, in accordance with the requirements of the Data Privacy Act and the regulations of the National Privacy Commission. These safeguards may include:

• Contractual clauses that require the recipient to protect your personal data to a standard equivalent to that required under Philippine law.
• Transfers to jurisdictions that have been assessed as providing an adequate level of data protection.
• Binding corporate rules where the recipient is part of the same corporate group as paldo 77.

You may request information about the specific safeguards in place for any international transfer of your personal data by contacting our Data Protection Officer at support @paldo-77.org.

paldo 77 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Privacy Policy, we will notify you by:

• Posting a prominent notice on the paldo 77 platform;
• Sending a notification to the email address associated with your account; and/or
• Updating the "Last Updated" date at the top of this Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how paldo 77 protects your personal data. Your continued use of the paldo 77 platform after the effective date of any updated Privacy Policy constitutes your acceptance of the changes, to the extent permitted by applicable law.

Where changes to this Privacy Policy require your consent under applicable law, paldo 77 will seek your consent before the changes take effect.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way paldo 77 processes your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Subject line: "Data Privacy Inquiry" or "Data Privacy Rights Request"
• Response time: Within 15 business days of receipt

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, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.