apaldo Privacy Policy

1 Scope and Data Controller

This Privacy Policy applies to all personal data collected, processed, and stored by apaldo in connection with the operation of the apaldo online casino and sports betting platform, including all sub-pages, mobile browser interfaces, customer support channels, and promotional communications associated with the platform.

apaldo acts as the data controller with respect to the personal data of registered Players and platform visitors. As data controller, apaldo determines the purposes and means of processing personal data in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations.

This Privacy Policy should be read in conjunction with the apaldo Terms and Conditions, which form part of the overall agreement between you and apaldo.

2 Personal Data We Collect

2.1 Registration and Account Data

When you create an apaldo Account, we collect the following information that you provide directly:

• Full legal name (first name, middle name, last name)
• Date of birth (to verify the 21+ age requirement under Philippine law)
• Valid email address
• Philippine mobile number
• Username and encrypted account password
• Preferred currency (PHP)
• Residential address (province, city/municipality, barangay)

2.2 Identity Verification (KYC) Data

To comply with Philippine anti-money laundering regulations and to verify your identity prior to processing withdrawals, apaldo collects:

• Scanned copies or photographs of government-issued photo ID (e.g., PhilSys National ID, Philippine passport, driver's license, UMID, voter's ID, PRC ID, SSS ID)
• Selfie photograph for facial verification against your ID document
• Proof of payment method ownership (e.g., screenshot of GCash or Maya account registered in your name) where required
• Proof of address documents where requested for enhanced due diligence

2.3 Financial and Transactional Data

apaldo records all financial transactions associated with your Account, including deposit amounts and payment method references (e.g., GCash reference numbers, bank transaction IDs), withdrawal requests and processing records, bonus credits and wagering activity, and account balance history. Full payment card numbers and bank account credentials are never stored on apaldo systems; these are handled exclusively by your payment provider.

2.4 Gameplay and Platform Activity Data

We collect records of your gaming activity on the platform, including games played, bet amounts and outcomes, session timestamps, sports betting selections, and responsible gaming tool usage (e.g., deposit limit changes, self-exclusion requests). This data is used for regulatory compliance, dispute resolution, responsible gaming monitoring, and platform improvement.

2.5 Technical and Device Data

When you access the apaldo platform, our systems automatically collect certain technical information, including your IP address, browser type and version, operating system, device type and identifiers, referring URL, and session duration. This data is used for fraud detection, security monitoring, and analytics.

2.6 Communications Data

When you contact apaldo customer support via live chat or email, we retain records of those communications, including the content of messages, timestamps, and any attachments you provide. These records are used to resolve disputes, improve service quality, and maintain a history of support interactions.

3 How We Collect Your Data

apaldo collects personal data through the following means:

• Direct collection: Information you actively provide during registration, KYC submission, deposit or withdrawal requests, completion of the apaldo Login, participation in promotions, and communications with support.
• Automated collection: Technical and device data collected automatically through server logs, cookies, and similar technologies when you access or interact with the platform.
• Third-party sources: Identity verification data returned by our KYC service provider following document validation; fraud risk signals from payment processors; and publicly available information used for enhanced due diligence where legally required.

4 Purpose and Legal Basis for Processing

apaldo processes your personal data for the following purposes and on the following legal bases under the Data Privacy Act of 2012:

Where processing is based on consent, you may withdraw that consent at any time by updating your communication preferences in your account settings or by contacting apaldo support. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

5 Sharing Your Personal Data

5.1 Service Providers and Processors

apaldo shares personal data with carefully selected third-party service providers who process data on our behalf and under our instructions, bound by data processing agreements that require them to maintain appropriate confidentiality and security standards. These include:

• Payment processors and e-wallet providers (GCash, Maya, GrabPay, BPI, BDO, Metrobank, Coins.ph) for deposit and withdrawal processing
• Identity verification (KYC) and age verification service providers
• Fraud detection and anti-money laundering screening providers
• Game content suppliers who operate the casino games available on the apaldo platform
• Customer support platform providers
• Cloud hosting and infrastructure providers

5.2 Regulatory and Legal Disclosure

apaldo may disclose your personal data to Philippine government agencies, regulatory bodies, law enforcement authorities, and courts where required by applicable law, including but not limited to: the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other agencies with lawful authority to request such disclosure. apaldo will not disclose more data than is strictly required to satisfy the legal obligation.

5.3 No Sale of Personal Data

apaldo does not sell, rent, lease, or otherwise transfer your personal data to third parties for their own commercial or marketing purposes. Any sharing of data is limited to the circumstances described in this Section 5.

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving apaldo, your personal data may be transferred to the successor entity. You will be notified of such a transfer and any material changes to data processing practices before the transfer takes effect, and you will retain the right to request Account closure and deletion of non-mandatory data.

6 Cookies and Tracking Technologies

6.1 Types of Cookies Used

apaldo uses the following categories of cookies on the platform:

• Strictly Necessary Cookies: Required for the platform to function. These include session cookies that maintain your logged-in state after the apaldo Login, security tokens, and load-balancing cookies. These cannot be disabled without disrupting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, responsible gaming limits display, and game lobby view. These improve your experience but are not essential.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate and use the platform — such as which pages are visited most frequently and where errors occur. This data is used to improve platform performance and user experience.

6.2 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the apaldo platform. Strictly necessary cookies cannot be disabled through browser settings while you remain logged in. Detailed instructions for managing cookies in major browsers (Chrome, Firefox, Safari, Edge) are available in each browser's help documentation.

6.3 No Third-Party Advertising Trackers

apaldo does not deploy advertising pixels, retargeting cookies, or tracking technologies from third-party advertising networks on the platform. Your browsing behaviour on apaldo is not shared with or sold to advertising platforms.

7 Data Security

apaldo implements a multi-layered security framework to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and apaldo servers
• Encryption at rest for sensitive data fields including identity documents and payment references
• Cryptographic hashing for all account passwords — passwords are never stored in plaintext
• Role-based access controls ensuring only authorised apaldo personnel can access personal data, and only to the extent required by their role
• Regular penetration testing and vulnerability assessments by independent security specialists
• 24/7 intrusion detection and monitoring systems
• Payment tokenisation — full payment credentials are handled exclusively by your payment provider and are never stored on apaldo systems

In the event of a personal data breach that is reasonably likely to result in serious harm to affected data subjects, apaldo will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected Players without undue delay, in accordance with the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

8 Data Retention

apaldo retains your personal data for the following periods:

• Active Account data: Retained for the duration of your Account's active status.
• Post-closure retention: Following Account closure, transactional records, KYC documents, and gameplay history are retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act (RA 9160, as amended) and applicable PAGCOR record-keeping directives.
• Support communications: Retained for three (3) years from the date of each interaction for dispute resolution purposes.
• Cookie and analytics data: Aggregated analytics data is retained for a maximum of twenty-four (24) months. Session cookies are deleted when you close your browser or complete the logout process.

After the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification. You may request early deletion of non-mandatory data as described in Section 9 below.

9 Exercising Your Data Rights

To exercise any of your rights under the Data Privacy Act of 2012 — including the rights to access, rectification, erasure, data portability, objection, or withdrawal of consent — please submit a written request to the apaldo Data Protection Officer via the email address listed in Section 14. Please include your full name, registered email address, and a description of the right you wish to exercise and the data it relates to.

apaldo will acknowledge your request within five (5) business days of receipt and will endeavour to resolve it within thirty (30) calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days, in which case you will be notified of the extension and the reason for it.

apaldo will not charge a fee for reasonable data subject requests. Where requests are manifestly unfounded or excessive, apaldo reserves the right to charge a reasonable administrative fee or to refuse the request, providing written reasons for any refusal.

If you are not satisfied with apaldo's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

10 Children and Minors

The apaldo platform is strictly intended for persons aged twenty-one (21) years and above, in accordance with Philippine gambling regulations. 21+ apaldo does not knowingly collect personal data from persons under the age of 21. If we become aware that a person under the age of 21 has provided personal data to us, we will immediately close the associated Account, void any transactions, and securely delete the personal data collected from that individual.

If you are a parent or guardian and believe that a minor has registered an Account on apaldo, please contact us immediately at the details provided in Section 14 so that we can take prompt action.

11 Cross-Border Data Transfers

Some of apaldo's service providers — including cloud infrastructure providers, game content suppliers, and KYC verification partners — may process personal data outside the Philippines. Where such transfers occur, apaldo ensures that appropriate safeguards are in place to protect your data at a standard equivalent to the protections afforded under the Data Privacy Act of 2012. These safeguards may include contractual clauses, binding corporate rules, or the adequacy of the recipient country's data protection framework.

By using the apaldo platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the provision of the services described in this Privacy Policy, subject always to the safeguards described above.

12 Third-Party Links

The apaldo platform does not contain links to third-party websites outside the apaldo domain. All navigation links on the platform direct to pages within apaldo's own website. Accordingly, apaldo is not responsible for the privacy practices of any external website. If you independently navigate to an external website, we encourage you to review that website's privacy policy before providing any personal information.

13 Amendments to This Privacy Policy

apaldo 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. Where changes are material, apaldo will notify registered Players by email or by posting a prominent notice on the platform no less than seven (7) days before the amended policy takes effect.

The "Last Updated" date at the top of this page will be revised whenever the policy is amended. Your continued use of the apaldo platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the amended policy, you may request Account closure in accordance with the Terms and Conditions.

14 Contact and Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or apaldo's data processing practices, or if you wish to exercise any of your rights under the Data Privacy Act of 2012, please contact the apaldo Data Protection Officer through the following channels:

• Live Chat: Available 24/7 directly on the apaldo platform after completing the apaldo Login — the fastest way to reach us.
• Email (Data Protection Officer): [email protected] — please include "Privacy Request" in your subject line.

apaldo aims to acknowledge all privacy-related inquiries within two (2) business days and to provide a full response within thirty (30) calendar days of receipt. If you remain dissatisfied with our response, you may lodge a formal complaint with the National Privacy Commission of the Philippines.