apldo Privacy Policy

Introduction

apldo ("apldo," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the apldo online gaming platform available at apldo.net and any associated mobile applications or services (collectively, the "Platform"). This Privacy Policy ("Policy") describes how apldo collects, uses, stores, shares, and protects your personal data when you access or use the Platform.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission ("NPC"). apldo also operates in accordance with the data protection requirements of the Philippine Amusement and Gaming Corporation ("PAGCOR").

This Policy should be read together with apldo's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, apldo is the personal information controller responsible for your personal data collected through the Platform. apldo determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable data protection law.

apldo has designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection legislation. If you have any questions or concerns about how apldo handles your personal data, you may contact the DPO using the contact details provided in Section 15 of this Policy.

Personal Data We Collect

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

apldo does not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive personal information is collected (such as government ID numbers), it is handled with heightened security measures and processed only for the specific purposes for which it was obtained.

How We Collect Your Data

apldo collects personal data through the following means:

• Direct collection: Information you provide when registering for an account, completing identity verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and use the Platform, including through cookies, web beacons, and similar tracking technologies as described in Section 8.
• Third-party sources: Information received from payment processors (GCash, Maya, Philippine banks), identity verification service providers, and fraud prevention partners where necessary to comply with our legal obligations.
• Publicly available sources: Information from public registries or databases where required for regulatory compliance or fraud prevention purposes.

How We Use Your Personal Data

apldo uses your personal data for the following purposes:

• To create, verify, and manage your apldo account, including age verification to enforce the 21+ requirement.
• To process deposits and withdrawals via GCash, Maya, bank transfer, and other supported Philippine payment methods.
• To comply with anti-money laundering (AML) obligations under Philippine law, including the Anti-Money Laundering Act (AMLA) and its amendments.
• To detect, investigate, and prevent fraud, cheating, collusion, and other prohibited conduct on the Platform.
• To provide customer support and resolve disputes or complaints.
• To send you transactional communications, including account notifications, deposit confirmations, and security alerts.
• To send you promotional communications and personalised offers, where you have consented to receive such communications. You may withdraw this consent at any time.
• To monitor your gaming activity for responsible gaming purposes, including identifying patterns that may indicate problem gambling behaviour.
• To improve the Platform, develop new features, and conduct internal analytics and research.
• To comply with applicable Philippine laws, PAGCOR regulations, and any lawful requests from competent authorities.

Legal Basis for Processing

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

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving promotional communications.
• Contractual necessity: Where processing is necessary to perform the contract between you and apldo (i.e., the Terms & Conditions), including account management and payment processing.
• Legal obligation: Where processing is necessary for apldo to comply with a legal obligation under Philippine law, including AML reporting, PAGCOR regulatory requirements, and tax obligations.
• Legitimate interests: Where processing is necessary for apldo's legitimate interests, such as fraud prevention, platform security, and improving our services, provided that such interests are not overridden by your rights and freedoms.

Where apldo relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Sharing Your Personal Data

apldo may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other Philippine payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers engaged by apldo to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention and security providers: Third-party services that assist apldo in detecting and preventing fraud, money laundering, and other prohibited conduct.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulation.
• Law enforcement: Philippine law enforcement agencies, where apldo is legally required or permitted to disclose your data in connection with a criminal investigation or legal proceeding.
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers engaged by apldo to operate the Platform, subject to strict contractual data protection obligations.

Where apldo engages third-party processors located outside the Philippines, apldo ensures that appropriate safeguards are in place to protect your personal data in accordance with the DPA and NPC guidelines on cross-border data transfers.

Cookies and Tracking Technologies

apldo uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain session security, and collect analytics data. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences and settings, such as language preferences and display options, to personalise your experience on the Platform.
• Analytics cookies: Collect anonymised data about how users interact with the Platform, including pages visited, time spent, and features used, to help apldo improve the Platform.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and other security threats on the Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. apldo does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

Data Security

apldo implements a comprehensive set of 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 apldo Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform.
• Multi-factor authentication for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, apldo will notify the National Privacy Commission and affected data subjects in accordance with the timeframes and requirements prescribed by the DPA and NPC regulations.

While apldo takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. apldo cannot guarantee absolute security and encourages you to use a strong, unique password for your apldo account and to enable two-factor authentication where available.

Data Retention

apldo retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, as described in this Policy, or as required by applicable Philippine law and PAGCOR regulatory requirements. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, in compliance with the Anti-Money Laundering Act and PAGCOR regulations.
• Communications data: Retained for up to three (3) years from the date of the communication, or longer if required for the resolution of an ongoing dispute or legal proceeding.
• Technical and usage data: Retained for up to two (2) years from collection, unless required for longer periods for security or fraud investigation purposes.

Upon expiry of the applicable retention period, apldo will securely delete or anonymise your personal data in accordance with its data disposal procedures. Where anonymisation is not technically feasible, apldo will ensure that the data is rendered inaccessible.

Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by apldo:

To exercise any of these rights, please contact apldo's Data Protection Officer using the contact details in Section 15. apldo will respond to your request within thirty (30) days of receipt, in accordance with NPC guidelines. apldo may request proof of identity before processing your request.

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

Children's Privacy

The apldo Platform is strictly intended for users aged 21 years and above. apldo does not knowingly collect personal data from individuals under the age of 21. The minimum legal age for casino-style gambling in the Philippines is 21 years, as prescribed under applicable PAGCOR regulations.

apldo employs age verification measures during the registration process and may request documentary proof of age at any time. Parents and guardians are encouraged to use parental control tools to prevent minors from accessing online gambling platforms.

Third-Party Links

The apldo Platform may contain links to third-party websites or services for informational purposes. apldo is not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies solely to the apldo Platform and does not extend to any third-party sites you may access via links on the Platform.

apldo encourages you to review the privacy policies of any third-party websites you visit. apldo has no control over and assumes no responsibility for the content, privacy policies, or practices of third-party sites or services.

Changes to This Privacy Policy

apldo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, apldo will notify registered users via email or through a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. Your continued use of the apldo Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform.

apldo encourages you to review this Policy periodically to stay informed about how we protect your personal data.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or apldo's data processing practices, please contact our Data Protection Officer through the following channels: