Privacy Policy

1. Data Controller

The data controller responsible for the personal data of panolo users is panolo Casino, operating the panolo.club platform. For all data privacy matters, you may contact panolo's designated Data Protection Officer (DPO) at support @ panolo.club. panolo is registered as a personal information controller with the National Privacy Commission of the Philippines in accordance with RA 10173.

2. Personal Data We Collect

panolo collects the following categories of personal data from registered Players and platform visitors:

3. How We Collect Your Data

panolo collects personal data through the following means:

• Direct Submission: Information you provide when registering your panolo account, completing KYC verification, making deposits or withdrawal requests, or contacting panolo support.
• Automated Collection: Technical and usage data collected automatically when you access the panolo platform, through cookies, server logs, and analytics tools.
• Payment Processors: Transaction confirmations and reference data received from GCash, Maya, and Philippine banking partners when processing deposits and withdrawals.
• Identity Verification Services: Identity verification outcomes from third-party KYC providers used to fulfill panolo's regulatory obligations.
• Third-Party Sources: Publicly available information or data from fraud prevention databases used to verify Player identity and detect suspicious activity.

4. How We Use Your Personal Data

panolo processes your personal data for the following purposes:

• To create, maintain, and manage your panolo account, including authentication and access control.
• To verify your identity and age (21+ requirement) in compliance with PAGCOR regulations and Philippine AML laws.
• To process deposits and withdrawals via GCash, Maya, and other accepted Philippine payment channels.
• To provide customer support in Filipino and English through panolo's 24/7 support team.
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities on the panolo platform.
• To monitor gaming activity for responsible gaming purposes, including identifying Players who may be at risk of problem gambling.
• To send you transactional communications — deposit confirmations, withdrawal status, OTP codes, and security alerts.
• To send promotional communications about panolo bonuses, new games, and offers, where you have consented to receive such communications.
• To comply with panolo's legal and regulatory obligations under Philippine law and PAGCOR requirements.
• To improve and personalize the panolo platform based on aggregated analytics and usage patterns.

5. Legal Bases for Processing

Under the Data Privacy Act of 2012 (RA 10173), panolo processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfill panolo's obligations to you under the Terms and Conditions, including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws, PAGCOR regulations, Anti-Money Laundering Act (AMLA) requirements, and court orders.
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests do not override your fundamental privacy rights.
• Consent: Processing for marketing communications and optional personalization features, where you have given explicit consent. You may withdraw consent at any time by contacting panolo support.

6. Data Sharing and Disclosure

panolo does not sell your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Processors: GCash (Mynt), Maya (Voyager Innovations), GrabPay, BPI, BDO, Metrobank, and other Philippine payment service providers, for the sole purpose of processing your transactions.
• Identity Verification Providers: Third-party KYC service providers engaged by panolo to perform identity and age verification as required by Philippine gaming regulations.
• Game Content Providers: Licensed game providers (such as JILI, PG Soft, Pragmatic Play, Evolution Gaming) receive necessary session data to deliver game content. These providers do not receive your financial or identity data.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law.
• Fraud Prevention Services: Shared industry fraud prevention databases, to the extent required to protect panolo and its Players from fraudulent activity.
• Professional Advisors: Lawyers, auditors, and accountants bound by confidentiality obligations, where required for legal or business compliance purposes.

All third-party recipients of panolo player data are required to maintain appropriate data protection standards consistent with RA 10173 and the processing purposes for which the data was shared.

7. GCash and Payment Data

When you deposit or withdraw via GCash, Maya, or any other payment method accepted by panolo, your payment credentials are processed directly by the relevant payment service provider through their own secure infrastructure. panolo does not store your full GCash PIN, Maya password, or complete bank account credentials on panolo's servers.

panolo retains transaction reference numbers, transaction amounts in PHP, and confirmation timestamps for the purposes of withdrawal processing, dispute resolution, and AML record-keeping as required under Philippine law. This financial transaction data is retained for a minimum of five (5) years in accordance with AMLA obligations.

8. KYC and Identity Verification Data

panolo is required to collect and verify identity documents from Players prior to processing withdrawals above specified thresholds, and in any case where panolo has reasonable grounds to verify a Player's identity. Accepted identity documents include Philippine government-issued IDs such as the PhilSys National ID, Passport, Driver's License, UMID, SSS ID, and Postal ID.

KYC documents submitted to panolo are stored securely with access restricted to authorized panolo personnel and designated KYC service providers. KYC data is retained for the duration of your panolo account and for a minimum of five (5) years following account closure, as required by Philippine AML regulations. Submitted identity documents will not be used for any purpose other than identity verification and regulatory compliance.

9. Cookies and Tracking Technologies

The panolo platform uses cookies and similar tracking technologies to enable core platform functionality, maintain your login session, detect fraud, and analyze platform usage. The following categories of cookies are used by panolo:

• Strictly Necessary Cookies: Required for the panolo platform to function. These cannot be disabled and include session authentication tokens and security cookies.
• Functional Cookies: Remember your preferences such as language settings and game lobby configuration.
• Analytics Cookies: Collect anonymized data about how Players use the panolo platform to help us improve the experience. Data is aggregated and not linked to individual identities.
• Security Cookies: Used to detect and prevent fraudulent access attempts, bot activity, and account takeover attempts on the panolo login system.

You may manage non-essential cookies through your browser settings. Disabling strictly necessary cookies will impair your ability to use the panolo platform.

10. Data Security

panolo implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or alteration. These measures include:

• SSL/TLS encryption for all data in transit between your device and panolo's servers.
• Encryption at rest for sensitive data including identity documents and financial records.
• Role-based access controls ensuring that personal data is accessible only to authorized panolo personnel who require it for their job function.
• Regular security audits and penetration testing of the panolo platform.
• Two-factor authentication (OTP via SMS) for panolo account login.
• Intrusion detection systems and 24/7 security monitoring of panolo's infrastructure.

11. Data Retention

panolo retains your personal data for as long as your panolo account is active, and for such additional periods as required by Philippine law. The following retention periods apply:

• Account Data (identity, contact): Duration of account plus 5 years after account closure.
• Financial Transaction Records: Minimum 5 years from the date of each transaction, as required by AMLA.
• KYC Documents: Duration of account plus 5 years after closure.
• Gaming Activity Records: Duration of account plus 3 years after closure.
• Customer Support Communications: 3 years from the date of the most recent communication.
• Analytics and Usage Data: Aggregated and anonymized after 24 months; anonymized data may be retained indefinitely.

Upon expiry of the applicable retention period, panolo will securely delete or irreversibly anonymize your personal data in accordance with NPC-approved disposal procedures.

12. Your Data Subject Rights

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

• Right to be Informed: You have the right to be informed of how your personal data is being collected, used, and processed by panolo.
• Right to Access: You may request a copy of the personal data panolo holds about you, along with information about how it is being used.
• Right to Correction: You may request correction of any inaccurate or incomplete personal data held in your panolo account.
• 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 panolo's legal retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes. You may also object to other processing based on legitimate interests, subject to panolo's overriding legitimate purposes.
• Right to Data Portability: You may request your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: If you believe panolo has breached your privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, contact panolo's Data Protection Officer at support @ panolo.club. panolo will respond to verified requests within 15 business days as required under RA 10173.

13. Children's Privacy

The panolo platform is strictly for adults aged 21 years and above, in accordance with PAGCOR's minimum age requirement for online gaming in the Philippines. panolo does not knowingly collect personal data from individuals under 21 years of age. If panolo becomes aware that a Player under 21 has registered an account or provided personal data, the account will be immediately suspended and all associated data deleted. If you believe a minor has provided personal data to panolo, please contact our support team immediately.

14. Cross-Border Data Transfers

Some of panolo's service providers and game content partners operate servers located outside the Philippines. Where personal data is transferred to recipients in jurisdictions outside the Philippines, panolo ensures that adequate safeguards are in place consistent with the requirements of RA 10173, including contractual data processing agreements that impose obligations equivalent to those required under Philippine data protection law. By using the panolo platform, you acknowledge that your data may be transferred to, processed in, and stored in countries outside the Philippines for the purposes described in this Privacy Policy.

15. Changes to This Privacy Policy

panolo reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform features. Material changes will be communicated to registered panolo Players via SMS or email to the contact details associated with their account. The date of the most recent revision is displayed at the top of this page. Your continued use of the panolo platform after publication of a revised Privacy Policy constitutes your acceptance of the revised terms.

16. Contact and Data Protection Officer

For all data privacy inquiries, requests to exercise your data subject rights, or concerns about panolo's handling of your personal data, please contact panolo's designated Data Protection Officer:

If you are not satisfied with panolo's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (privacy.gov.ph).