phllago Privacy Policy

1 Who We Are

phllago ("we," "us," "our") operates the online casino and sports betting platform accessible at phllago.org. phllago serves Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Iloilo, and beyond.

For the purposes of this Privacy Policy, phllago is the data controller responsible for the personal data you provide when you register, deposit, play, or otherwise interact with the phllago platform. If you have any questions about how phllago handles your personal data, please contact us at [email protected].

This Privacy Policy applies to all personal data collected through the phllago website, mobile interface, customer support channels, and any other touchpoint through which you interact with phllago. By registering for a phllago account or using the platform, you acknowledge that you have read and understood this Privacy Policy.

2 Personal Data We Collect

phllago collects personal data in the following categories:

phllago does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by applicable law (for example, information related to responsible gaming self-exclusion requests).

3 How We Use Your Personal Data

phllago uses the personal data we collect for the following purposes:

• Account Management: To create, verify, and maintain your phllago account, including identity verification (KYC) as required by applicable regulations.
• Service Delivery: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank; to provide access to games; and to deliver customer support.
• Regulatory Compliance: To comply with anti-money laundering (AML) obligations, PAGCOR guidelines, and other applicable Philippine laws and regulations.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, to enforce deposit and loss limits you have set, and to process self-exclusion requests.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, account abuse, and other illegal activity on the phllago platform.
• Platform Improvement: To analyse usage patterns, diagnose technical issues, and improve the performance and features of the phllago platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your consent or where we have a legitimate interest to do so. You may opt out at any time.
• Legal Claims: To establish, exercise, or defend legal claims involving phllago.

phllago will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

4 Legal Basis for Processing

phllago processes your personal data on the following legal bases:

• Contractual Necessity: Processing that is necessary to perform the contract between you and phllago — including account creation, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including AML regulations, PAGCOR requirements, and tax obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights and interests.
• Consent: Processing for marketing communications and non-essential cookies, where you have given your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Sharing Your Personal Data

phllago does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory requirements.
• Game Providers: Software providers whose games are available on the phllago platform, to the extent necessary to deliver those games and resolve disputes.
• Technology Service Providers: Cloud hosting, analytics, and security service providers who process data on phllago's behalf under strict data processing agreements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or regulation.
• Legal Advisers: Where necessary to obtain legal advice or to establish, exercise, or defend legal claims.

All third parties with whom phllago shares personal data are required to handle that data in accordance with applicable privacy laws and phllago's data protection standards.

6 Cookies & Tracking Technologies

phllago 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 phllago website. We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming limits you have set.
• Analytics Cookies: Help us understand how players use the phllago platform so we can improve performance and user experience. Data collected is aggregated and anonymised where possible.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the phllago platform.

7 Data Retention

phllago retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general guide:

• Account and identity data is retained for a minimum of five (5) years after account closure, as required by Philippine AML regulations.
• Transaction and financial data is retained for a minimum of five (5) years from the date of the transaction.
• Gaming history data is retained for three (3) years from the date of the gaming session.
• Customer support communications are retained for two (2) years from the date of the last interaction.
• Marketing consent records are retained for as long as you remain a registered phllago player, plus two (2) years after account closure.

When personal data is no longer required, phllago will securely delete or anonymise it in accordance with our data retention procedures.

8 Security of Your Personal Data

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

• SSL/TLS encryption for all data transmitted between your device and the phllago platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Access controls ensuring that only authorised phllago personnel can access personal data, on a strict need-to-know basis.
• Regular security assessments and penetration testing of the phllago platform.
• Segregation of player funds from operational funds.

While phllago takes data security seriously, no method of transmission over the internet or electronic storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, phllago will notify you and the relevant Philippine authorities as required by applicable law.

9 Your Privacy Rights

As a phllago player, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us at [email protected]. phllago will respond to all valid requests within thirty (30) days.

• Right of Access: You have the right to request a copy of the personal data phllago holds about you.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have the right to request deletion of your personal data, subject to our legal obligations to retain certain data.
• Right to Restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Please note that some rights are subject to limitations under applicable Philippine law. For example, phllago may be required to retain certain data to comply with AML regulations even if you request erasure. Where we are unable to fulfil a request in full, we will explain the reason.

10 Children & Minors

The phllago platform is strictly for persons aged 21 years and above. phllago does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not register for or use the phllago platform.

If phllago becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the phllago platform, please contact us immediately at [email protected].

Parents and guardians are encouraged to use parental control tools to prevent minors from accessing online gambling platforms. phllago supports responsible gaming at the household level and takes the protection of minors seriously.

11 Changes to This Privacy Policy

phllago reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, phllago will notify registered players via email or a prominent notice on the platform prior to the changes taking effect.

The revised Privacy Policy will be effective from the date of publication on the phllago website. Your continued use of the phllago platform after the effective date of any revised Privacy Policy constitutes your acknowledgement of the changes. We encourage you to review this page periodically to stay informed about how phllago protects your personal data.

12 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way phllago handles your personal data, please contact our Data Privacy team:

Email: [email protected]

Our support team is available 24 hours a day, 7 days a week. We aim to acknowledge all privacy-related enquiries within 48 hours and to resolve them within 30 days. For complex requests, we may require additional time and will keep you informed of progress.

For further information about your rights under Philippine data privacy law, you may also contact the National Privacy Commission (NPC) of the Philippines.