Privacy Policy

1. Data Controller

panolo, operating the website at panolo.vip, is the Data Controller of your personal information as defined under the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. panolo holds a valid PAGCOR license authorizing it to offer online casino, bingo, slot, and sports betting services within the Republic of the Philippines.

As Data Controller, panolo determines the purposes and means of processing your personal data and is legally responsible for ensuring that such processing is carried out lawfully, fairly, and transparently. panolo's Data Protection Officer (DPO) is registered with the National Privacy Commission and can be reached at the contact details provided in Section 13 of this Policy.

2. Data We Collect

2.1 Identity and Contact Data

When you register a panolo account or complete Know Your Customer (KYC) verification, we collect: full legal name; date of birth; Philippine residential address; email address; and Philippine mobile number. For KYC purposes, we also collect copies of your government-issued Philippine identification documents, which may include your PhilSys National ID, driver's license, or passport.

2.2 Financial Data

panolo collects financial information necessary to process deposits and withdrawals, including GCash account reference numbers, PayMaya account details, and bank account numbers (BPI, BDO, Metrobank) as provided by you. panolo does not store full payment card numbers. Source of funds documentation may be collected from high-value account holders in compliance with the Anti-Money Laundering Act (AMLA) of the Philippines.

2.3 Transaction and Gaming Data

We collect records of all transactions on your panolo account — deposits, withdrawals, bonus credits, game bets placed, game outcomes, and session durations. This data is retained for regulatory compliance, dispute resolution, and responsible gaming monitoring purposes.

2.4 Technical and Usage Data

When you access the panolo Platform, our servers automatically collect technical data including: IP address; device type and operating system; browser type and version; pages visited and features accessed; session start and end times; and error logs. This data is used for security monitoring, fraud prevention, and platform improvement purposes.

2.5 Communications Data

We retain records of communications between you and panolo's customer support team, including live chat transcripts and email correspondence. These records are used to resolve disputes, improve service quality, and as evidence in regulatory inquiries where required.

3. How We Collect Your Data

panolo collects your personal data through the following channels:

• Direct provision: Information you actively provide during account registration, KYC verification, payment processing, customer support interactions, and responsible gaming tool setup;
• Automated collection: Technical and usage data collected automatically through cookies, server logs, and similar tracking technologies when you access the panolo Platform;
• Third-party sources: Identity verification data from accredited Philippine KYC providers; fraud screening data from payment processors; age verification confirmation from document verification services. All third-party data providers used by panolo are required to comply with applicable Philippine data protection law.

4. Purpose and Legal Basis for Processing

panolo processes your personal data only for specified, explicit, and legitimate purposes. The following table summarises our primary processing activities and their legal basis under the Data Privacy Act of 2012:

panolo does not sell, rent, or trade your personal data to third parties for their own marketing purposes under any circumstances.

5. Sharing Your Data

panolo shares your personal data only where necessary and only with the following categories of recipients:

• Payment processors: GCash (G-Xchange Inc.), PayMaya (PayMaya Philippines Inc.), BPI, BDO, and Metrobank — solely to process your deposit and withdrawal transactions;
• KYC and identity verification providers: Accredited third-party identity verification services used to satisfy PAGCOR and AMLA compliance requirements;
• PAGCOR and regulatory authorities: panolo is legally obligated to submit required player data reports to PAGCOR and, where mandated, to the Anti-Money Laundering Council (AMLC) and other relevant Philippine government agencies;
• Technology service providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged under binding Data Processing Agreements that prohibit any use of your data beyond the services provided to panolo;
• Legal and professional advisers: Where required for the resolution of legal claims, regulatory investigations, or professional compliance advice, subject to strict confidentiality obligations.

All third parties with whom panolo shares personal data are required to implement appropriate technical and organizational security measures and to process data only in accordance with panolo's instructions and applicable Philippine law.

6. Cookies and Tracking Technologies

panolo uses cookies and similar technologies on the panolo.vip website to enable core Platform functionality, maintain your session state after login, remember your preferences, and analyse aggregate usage patterns for Platform improvement.

The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your panolo account. They cannot be disabled without breaking core functionality.
• Functional Cookies: Remember your language and display preferences to improve your experience across sessions.
• Analytics Cookies: Collect anonymised data on page visits, session duration, and feature usage to help panolo understand how players use the Platform. panolo uses only analytics tools that process data within compliant privacy frameworks.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to log in and use the panolo Platform.

7. Data Retention

panolo retains your personal data for the period necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods imposed by applicable law:

• Account and identity data: Five (5) years from the date of account closure, as required by PAGCOR license conditions and the AMLA;
• Transaction and gaming records: Five (5) years from the date of the transaction;
• KYC documentation: Five (5) years from the date of verification or account closure, whichever is later;
• Customer support records: Three (3) years from the date of the communication.

Upon expiry of the applicable retention period, panolo will securely delete or anonymise your personal data in accordance with its data disposal procedures, unless further retention is required by court order, regulatory instruction, or ongoing legal proceedings.

8. Data Security

panolo implements a comprehensive information security programme to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Technical and organizational security measures maintained by panolo include:

• 256-bit TLS/SSL encryption for all data in transit between your device and panolo servers;
• Encryption at rest for all databases containing personal and financial data;
• Role-based access controls limiting employee access to personal data to those with a demonstrated operational need;
• Quarterly third-party penetration testing of the Platform and its infrastructure;
• Continuous 24/7 security monitoring and intrusion detection systems;
• Multi-factor authentication required for all internal systems accessing player data.

In the event of a personal data breach that poses a real risk of harm to affected players, panolo will notify the National Privacy Commission and affected individuals within seventy-two (72) hours of discovering the breach, as required by the NPC's Breach Notification Guidelines.

9. Your Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173), registered players whose personal data is held by panolo have the following rights:

To exercise any of the above rights, contact panolo's Data Protection Officer using the details in Section 13. panolo will respond to all verified data subject requests within fifteen (15) business days. If you believe your rights have not been adequately respected, you may file a complaint with the National Privacy Commission of the Philippines.

10. Minors

The panolo Platform is strictly prohibited for use by individuals under 21 years of age, in compliance with PAGCOR regulations and Philippine gambling law. panolo does not knowingly collect personal data from persons under 21. If panolo becomes aware that personal data has been submitted by an individual under 21, that Account will be immediately terminated, all associated data will be deleted except where regulatory retention obligations apply, and the matter will be reported to PAGCOR.

Parents and guardians who believe a minor may have registered on the panolo Platform are urged to contact our support team immediately at [email protected].

11. Third-Party Links

The panolo Platform does not contain links to third-party websites. Where payment provider names (such as GCash or PayMaya) are referenced within this Policy or elsewhere on the panolo Platform, such references are for informational purposes only and do not constitute endorsement or affiliation beyond the payment processing relationship described above. panolo is not responsible for the privacy practices of any third-party payment providers; players are encouraged to review the privacy policies of those providers separately.

12. Changes to This Privacy Policy

panolo reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our processing activities. Material changes will be notified to registered players via in-Platform notification or email to the registered account address at least fourteen (14) days before the revised Policy takes effect. The date of the most recent update is displayed at the top of this page. Continued use of the panolo Platform following the effective date of any revision constitutes acceptance of the updated Privacy Policy.

13. Contact & Data Protection Officer

For all privacy-related enquiries, data subject access requests, or complaints regarding panolo's handling of your personal data, please contact: