paldofun Privacy Policy

This Privacy Policy ("Policy") describes how paldofun ("paldofun," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you," "Player," or "User") of the paldofun online gaming platform available at paldofun.com and its associated mobile interfaces and services (collectively, the "Platform").

paldofun is committed to protecting the privacy and personal data of all users in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. paldofun also complies with applicable data protection obligations arising from its PAGCOR license as a regulated online gaming operator.

By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the Platform.

paldofun acts as the Personal Information Controller (PIC) with respect to all personal data collected through the Platform, as defined under the Data Privacy Act of 2012. paldofun determines the purposes and means of processing your personal data and is responsible for ensuring that processing activities comply with applicable Philippine data protection law.

paldofun has appointed a Data Protection Officer (DPO) who oversees all privacy-related matters. Contact details for the DPO are provided in Section 14 of this Policy.

paldofun collects the following categories of personal data from users of the Platform:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification document numbers (e.g., Philippine passport number, UMID number, SSS ID number, driver's license number).
• Contact Data: Residential address in the Philippines, email address, and Philippine mobile number.
• Financial Data: GCash account details, PayMaya account details, bank account information (BPI, BDO, Metrobank, or other Philippine banks), transaction history, deposit amounts, withdrawal amounts, and wallet balances.
• Technical Data: IP address, device identifiers, browser type and version, operating system, session timestamps, geolocation data (city-level), and cookies.
• Gaming Data: Game history, bets placed, game outcomes, session duration, bonus usage, and loyalty program status.
• Communications Data: Records of correspondence with paldofun customer support, live chat transcripts, and feedback submissions.
• Verification Data: Photographs of government-issued identification documents and selfie photographs submitted for KYC (Know Your Customer) verification purposes.

paldofun collects personal data through the following means:

1. Direct Submission: Data you provide during account registration, KYC verification, deposit or withdrawal requests, contact form submissions, or customer support interactions.
2. Automated Collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies as described in Section 8.
3. Third-Party Sources: Identity verification data received from Philippine government database verification services used during KYC processing; transaction data received from GCash, PayMaya, and banking partners when you make deposits or withdrawals.
4. Regulatory Reporting: Data shared with paldofun by PAGCOR or other Philippine regulatory authorities in the exercise of their supervisory functions.

paldofun processes your personal data for the following purposes:

• Account Management: To create, maintain, verify, and manage your paldofun account, including identity verification and KYC compliance.
• Service Delivery: To provide access to games, process deposits and withdrawals, apply bonuses, and operate the Platform's features.
• Regulatory Compliance: To satisfy paldofun's obligations as a PAGCOR-licensed operator, including player identification, transaction reporting, anti-money laundering (AML) screening under Republic Act No. 9160 (as amended), and responsible gaming monitoring.
• Fraud Prevention and Security: To detect, investigate, and prevent unauthorized access, fraudulent transactions, collusion, and other prohibited activities on the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance with account and transaction matters.
• Communications: To send you transactional notifications (e.g., deposit confirmations, withdrawal processing updates, security alerts) and, where you have provided consent, promotional communications about paldofun offers and games.
• Platform Improvement: To analyze usage patterns, conduct internal research, and improve the functionality, performance, and user experience of the Platform.
• Responsible Gaming: To monitor gaming behavior and identify potential indicators of problem gambling in fulfillment of paldofun's PAGCOR-mandated responsible gaming obligations.

paldofun processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent, including consent to receive marketing communications.
• Contractual Necessity: Processing necessary for the performance of the agreement between you and paldofun (as set out in the Terms and Conditions), including account creation, game provision, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulatory requirements, AML laws, and the Data Privacy Act of 2012.
• Legitimate Interests: Processing necessary for paldofun's legitimate business interests, including fraud prevention, Platform security, and service improvement, where such interests are not overridden by your privacy rights.

paldofun does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients, strictly as necessary for the purposes described in this Policy:

• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or regulatory obligation.
• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay, for the processing of deposits and withdrawals.
• KYC Verification Providers: Third-party identity verification services engaged by paldofun to process and validate government-issued identification documents during account registration.
• Technology Service Providers: Cloud infrastructure providers, game content providers, customer support platform vendors, and cybersecurity service providers engaged by paldofun under strict data processing agreements that require them to process data only on paldofun's instructions.
• Law Enforcement: Where disclosure is required by a valid Philippine court order, subpoena, or lawful request by law enforcement authorities.

All third parties with whom paldofun shares personal data are required to maintain appropriate technical and organizational security measures consistent with the Data Privacy Act of 2012.

paldofun uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function correctly, including session management, login authentication, and security. These cookies cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect aggregated data about how users interact with the Platform, to help paldofun improve usability and performance. Analytics data is processed in anonymized or pseudonymized form where possible.
• Preference Cookies: Used to remember your language preferences, game settings, and display preferences across sessions.
• Security Cookies: Used to detect and prevent fraudulent login attempts, bot activity, and other security threats.

You may manage cookie preferences through your browser settings. Please note that disabling essential cookies will impair your ability to use the Platform. paldofun does not use cookies to serve third-party advertising.

paldofun retains personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following retention principles:

• Account data and KYC documentation are retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and Philippine AML law.
• Transaction records are retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications are retained for three (3) years from the date of closure of the relevant support case.
• Technical and session logs are retained for twelve (12) months and then securely deleted or anonymized.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with paldofun's data disposal procedures.

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and paldofun servers.
• Encryption of sensitive data at rest, including identification documents and financial account details.
• Role-based access controls ensuring that personal data is accessible only to paldofun personnel with a legitimate need to process it.
• Multi-factor authentication requirements for internal system access by paldofun staff.
• Regular security vulnerability assessments and penetration testing of the Platform.
• A documented data breach response procedure, including NPC notification within seventy-two (72) hours of becoming aware of a breach likely to result in harm, as required by the Data Privacy Act of 2012.

While paldofun takes reasonable and appropriate security precautions, no data transmission over the internet can be guaranteed to be completely secure. You are responsible for maintaining the confidentiality of your account credentials.

Under the Data Privacy Act of 2012, you hold the following rights with respect to your personal data processed by paldofun:

• Right to be Informed: The right to know whether paldofun holds personal data about you and to receive a copy of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data paldofun holds about you, including information on how it is being used.
• Right to Correction: The right to request correction of inaccurate, incomplete, or outdated personal data in your account.
• Right to Erasure: The right to request deletion of your personal data, subject to paldofun's legal retention obligations under PAGCOR licensing requirements and AML law.
• Right to Object: The right to object to processing of your personal data based on legitimate interests, including direct marketing communications.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• 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 paldofun's Data Protection Officer at the contact details provided in Section 14. paldofun will respond to verified data subject requests within fifteen (15) business days.

The paldofun Platform is strictly for persons aged 21 years or older, consistent with PAGCOR licensing requirements for real-money online gaming in the Philippines. paldofun does not knowingly collect or process personal data from persons under 21 years of age. If paldofun becomes aware that it has collected personal data from an underage individual, the account will be immediately suspended and all personal data associated with the account will be securely deleted.

If you have reason to believe that an underage person has registered on paldofun, please notify us immediately at the contact address in Section 14.

paldofun may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory requirements, or paldofun's data processing practices. Material changes will be communicated to registered users via the email address on file at least fourteen (14) days before the amended Policy takes effect. The "Last updated" date at the top of this Policy will be revised with each update.

Continued use of the Platform after the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically.

For questions, concerns, or requests regarding this Privacy Policy or paldofun's personal data processing practices, please contact paldofun's Data Protection Officer:

Email: [email protected]
Subject line: Data Privacy Request – [Your Full Name]
Response time: Within 15 business days of receipt of a verified request.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights under Republic Act No. 10173 have been violated.