apalado Privacy Policy

1 Who We Are

This Privacy Policy is issued by apalado ("apalado", "we", "us", "our"), the operator of the online gaming platform accessible at https://apalado.net (the "Platform"). For the purposes of Philippine data protection law, apalado acts as the Personal Information Controller (PIC) with respect to the personal data it collects from registered players, prospective players, and visitors to the Platform.

This Privacy Policy should be read alongside apalado's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. By registering on the apalado Platform or by continuing to use it after the effective date of this Policy, you acknowledge that you have read and understood its contents.

2 Personal Data We Collect

apalado collects personal data that falls into the following categories. We collect only what is reasonably necessary for the purposes described in Section 4 of this Policy.

Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for 21+ age verification in accordance with PAGCOR regulations);
• Residential address, including barangay, city/municipality, province, and zip code;
• Email address and mobile phone number;
• Copies of government-issued identification documents submitted during KYC verification (e.g., Philippine National ID, UMID, passport, driver's licence, voter's ID, PRC ID, SSS ID, GSIS ID).

Financial Data

• GCash or Maya mobile wallet reference numbers and registered mobile numbers;
• Bank account details where bank transfer methods (BPI, BDO, Metrobank) are used for deposits or withdrawals;
• Transaction history including deposits, withdrawals, wager amounts, and bonus claims;
• Source of funds documentation where required for AML compliance.

Gaming & Behavioural Data

• Game session records including game type, duration, wager amounts, and outcomes;
• Responsible gaming settings selected (deposit limits, session reminders, self-exclusion requests);
• Bonus and promotion activity, including acceptance and wagering progress;
• Customer support interaction records including live chat transcripts and support ticket history.

Technical & Device Data

• IP address and approximate geolocation at the time of login and play;
• Device type, operating system, and browser version;
• Session timestamps and login history;
• Cookie identifiers and similar tracking data as described in Section 9.

3 How We Collect Your Data

apalado collects your personal data through the following channels:

• Directly from you — when you register an apalado account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a promotion;
• Automatically — through cookies, web beacons, and server logs when you access or interact with the apalado Platform (see Section 9);
• From third-party payment providers — GCash, Maya, GrabPay, BPI, BDO, Metrobank, and other payment processors may share transaction confirmation data with apalado as part of the payment verification process;
• From identity verification services — apalado may use regulated third-party KYC and AML screening services to verify the authenticity of your government-issued identification documents;
• From regulatory authorities — PAGCOR or other competent Philippine authorities may provide information relevant to account compliance reviews.

4 Why We Use Your Personal Data

apalado uses the personal data it collects for the following purposes:

apalado does not use your personal data for unsolicited third-party marketing. If you have opted in to receive promotional communications from apalado directly, you may withdraw that consent at any time by updating your notification preferences in your account dashboard or by contacting our support team.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, apalado processes your personal data on the following legal grounds:

• Contractual necessity — processing is required to fulfil our obligations under the Terms & Conditions you agreed to at registration, including account management, payment processing, and game delivery;
• Legal obligation — processing is required for apalado to comply with its obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine law;
• Legitimate interests — processing is necessary for the legitimate interests of apalado, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where those interests are not overridden by your fundamental rights;
• Consent — for processing activities that go beyond the above grounds, such as optional marketing communications, apalado will seek your explicit consent, which you may withdraw at any time without detriment to your account.

6 Sharing Your Personal Data

apalado does not sell, rent, or trade your personal data to third parties. We share your data only in the following limited circumstances and only to the extent necessary:

Service Providers & Data Processors

apalado engages carefully selected third-party service providers who process personal data on our behalf and under our written instructions as Personal Information Processors (PIPs). These include payment processors (GCash, Maya, GrabPay, BPI, BDO, Metrobank), KYC and identity verification services, cloud hosting and infrastructure providers, customer support platforms, and responsible gaming monitoring tools. All such providers are contractually bound to process your data only for the purposes specified by apalado and in compliance with the Data Privacy Act.

Regulatory & Law Enforcement Authorities

apalado may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other competent Philippine authorities where required to do so by law, court order, or regulatory directive. Such disclosures are made only to the extent required and will be handled in accordance with applicable legal procedures.

Business Transfers

In the event of a merger, acquisition, or sale of all or a substantial part of apalado's assets, your personal data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and of any material change to the way your data is processed as a result.

7 Data Retention

apalado retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account and KYC records — retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Financial transaction records — retained for a minimum of five (5) years from the date of each transaction in accordance with AMLA and BIR requirements;
• Gaming session records — retained for a minimum of three (3) years from the date of each session;
• Customer support records — retained for two (2) years from the date of each interaction;
• Marketing consent records — retained for the duration of your consent and for two (2) years thereafter as evidence of compliance;
• Self-exclusion records — retained indefinitely to prevent re-registration during an active exclusion period and for regulatory audit purposes.

When personal data is no longer required and the applicable retention period has expired, apalado will securely delete or anonymise it in a manner that prevents reconstruction of the original data.

8 Security Measures

apalado implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, disclosure, or destruction. These measures include:

• Encryption in transit — all data transmitted between your device and the apalado Platform is encrypted using TLS 1.3 protocol;
• Encryption at rest — sensitive data stored on apalado servers, including KYC documents and financial records, is encrypted using AES-256 encryption;
• Access controls — access to personal data within apalado is restricted on a need-to-know basis, with role-based permissions, multi-factor authentication for administrative access, and full access logging;
• Network security — apalado's infrastructure is protected by firewalls, intrusion detection systems, and regular vulnerability assessments;
• Incident response — apalado maintains a documented data breach response procedure and will notify affected players and the National Privacy Commission within seventy-two (72) hours of discovering a breach that poses a real risk to your rights, in accordance with NPC Circular 16-03.

While apalado takes all reasonable steps to protect your personal data, no system is entirely immune to risk. You play an important role in keeping your account secure — please ensure your apalado login credentials are strong, unique, and not shared with anyone.

9 Cookies & Tracking Technologies

apalado 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 apalado website. The following categories of cookies are used:

Strictly Necessary Cookies

These cookies are essential for the Platform to function. They enable core features such as session management, login authentication, and fraud prevention. These cookies cannot be disabled without breaking the functionality of the Platform.

Functional Cookies

These cookies remember your preferences — such as your preferred language, responsible gaming settings, and display configurations — so that your experience is consistent across sessions.

Analytics Cookies

apalado uses first-party analytics cookies to understand how players interact with the Platform — including which games are most popular, which pages are visited most frequently, and where technical errors occur. This data is used in aggregate form to improve the Platform and is not used to identify individual players.

Managing Your Cookie Preferences

You may manage non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality and performance of the apalado Platform. Strictly necessary cookies cannot be opted out of while using the service.

10 Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by apalado. You may exercise any of these rights by contacting our Data Protection Officer through the channels described in Section 14.

11 Children & Minors

apalado implements age verification controls at the point of registration to prevent minors from accessing the Platform. If apalado discovers that personal data has been collected from a person under 21, that account will be immediately suspended, all associated data will be securely deleted (subject to any mandatory regulatory reporting obligations), and the matter will be reported to PAGCOR as required.

If you are a parent or guardian and believe that a minor in your care has registered on the apalado Platform, please contact our support team immediately via live chat or by email so that we can take prompt action.

12 Third-Party Links

The apalado Platform does not contain links to third-party websites for commercial or advertising purposes. Any links that appear on the Platform are limited to apalado's own internal pages. apalado is not responsible for the privacy practices of any third-party websites that you may access independently outside of the apalado Platform. We recommend reviewing the privacy policies of any external websites you visit.

13 Changes to This Privacy Policy

apalado reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. The updated Policy will always display the effective date at the top of this page.

Where changes are material — meaning they significantly affect how we collect or use your personal data — apalado will notify registered players by posting a prominent notice on the Platform and, where practicable, by sending a notification to your registered email address or mobile number at least seven (7) days before the changes take effect.

Your continued use of the apalado Platform after the effective date of any revised Privacy Policy constitutes your acknowledgement of the changes. If you do not accept the updated Policy, please cease using the Platform and contact our support team to close your account and request deletion of your data where permissible.

14 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how apalado handles your personal data, please contact our Data Protection Officer through any of the following channels:

• Live Chat: Available 24/7 through your apalado account dashboard after logging in at apalado Login;
• Email: [email protected]

apalado will acknowledge your privacy-related enquiry within forty-eight (48) hours and will resolve it within thirty (30) calendar days of receipt. If you are not satisfied with apalado's response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.