ggpanlo Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how ggpanlo ("Company", "we", "us", "our") collects, uses, stores, shares, and protects personal data belonging to users ("Player", "User", "you") of the ggpanlo website at ggpanlo.net and all associated services, games, and features (collectively, the "Service").

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), as administered by the National Privacy Commission (NPC) of the Philippines. It also reflects our obligations under applicable anti-money laundering regulations and Philippine online gaming regulatory requirements.

This Policy forms part of our Terms and Conditions. Defined terms used but not defined in this Policy have the meanings given to them in the Terms and Conditions. In the event of any conflict between this Policy and the Terms and Conditions, the Terms and Conditions shall prevail.

02 Data Controller

ggpanlo is the personal information controller (as defined under RA 10173) responsible for your personal data. This means we determine the purposes and means by which your personal data is processed in connection with your use of the Service.

Where we engage third-party service providers to process personal data on our behalf (for example, payment processors, KYC verification services, and cloud infrastructure providers), those parties act as personal information processors under our instruction and are bound by data processing agreements that require them to maintain standards consistent with RA 10173.

03 Personal Data We Collect

ggpanlo collects personal data across several categories depending on how you interact with the Service. The table below summarises the main categories of data we collect and representative examples:

ggpanlo does not intentionally collect sensitive personal information (as defined under RA 10173, such as race, religion, health data, or political affiliation) except where strictly required by applicable law or with your explicit written consent.

04 How We Collect Your Data

We collect personal data through the following channels:

4.1 Directly From You

• When you register an account on ggpanlo;
• When you complete Know Your Customer (KYC) verification and submit identification documents;
• When you make a deposit or request a withdrawal via GCash, Maya, BPI, BDO, Metrobank, or other supported channels;
• When you contact our customer support team by email, live chat, or any other support channel;
• When you participate in promotions, surveys, or competitions hosted on the platform;
• When you set responsible gaming preferences such as deposit limits or self-exclusion.

4.2 Automatically From Your Device

• Through cookies, web beacons, pixel tags, and similar tracking technologies embedded in the ggpanlo website;
• Through our server logs, which automatically record your IP address, browser information, and access timestamps each time you visit the platform;
• Through device fingerprinting technologies used for fraud detection and responsible gaming enforcement purposes.

4.3 From Third Parties

• From identity verification and KYC service providers engaged to validate government-issued Philippine IDs;
• From payment processors including GCash, Maya, BPI, BDO, and Metrobank, who share transaction confirmation data with us;
• From fraud detection and anti-money laundering (AML) screening partners who flag high-risk activity;
• From applicable Philippine regulatory or law enforcement authorities where required by law.

05 Purpose & Legal Basis for Processing

ggpanlo processes your personal data only where we have a lawful basis under RA 10173 to do so. The table below sets out the primary purposes for which we process your data and the corresponding legal basis:

06 Sharing Your Personal Data

ggpanlo does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We may share your data only in the following limited circumstances:

6.1 Service Providers and Processors

We share personal data with trusted third-party service providers who process data on our behalf under written data processing agreements. These include: cloud hosting and infrastructure providers, KYC and identity verification platforms, payment gateways (GCash, Maya, BDO, BPI, Metrobank), fraud screening vendors, and customer support software providers. All processors are required to maintain security standards consistent with RA 10173.

6.2 Regulatory and Legal Authorities

We may disclose personal data to Philippine government agencies, regulatory bodies, law enforcement authorities, or courts where required by law or valid legal process. This includes disclosures to the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and applicable gaming regulatory authorities, where legally compelled.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of ggpanlo's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified in advance of any such transfer and of any material changes to how your data will be processed.

6.4 With Your Consent

We may share your personal data with third parties in circumstances not covered above, provided we have obtained your explicit prior consent for that specific disclosure.

07 Data Retention

ggpanlo retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The general retention guidelines we follow are set out below:

• 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 Philippine AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act of 2001 (RA 9160, as amended).
• Gaming history and session logs: Retained for five (5) years from the date of the activity, or longer if required by a regulatory investigation.
• Communications and support records: Retained for three (3) years from the date of the last interaction.
• Technical and usage data: Typically anonymised or deleted within twelve (12) months of collection.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data disposal procedures. Where data cannot be immediately deleted due to technical or regulatory constraints, it is isolated from active processing until deletion is possible.

08 Data Security

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

• Encryption: All data transmitted between your device and the ggpanlo platform is encrypted using Transport Layer Security (TLS). Sensitive data stored on our servers, including account credentials and financial information, is encrypted at rest using industry-standard algorithms.
• Access Controls: Access to personal data within ggpanlo is restricted on a strict need-to-know basis. All staff with access to personal data undergo privacy training and are bound by confidentiality obligations.
• Fraud and Intrusion Detection: We employ automated monitoring systems to detect unusual activity, attempted breaches, and fraudulent access patterns in real time.
• Vulnerability Management: The ggpanlo platform undergoes regular security assessments and penetration testing to identify and remediate technical vulnerabilities.
• Incident Response: In the event of a personal data breach, ggpanlo will notify the National Privacy Commission (NPC) and affected users within the timeframes prescribed by RA 10173 and NPC Circular No. 16-03.

09 Cookies & Tracking Technologies

ggpanlo uses cookies and similar tracking technologies to operate and improve the platform. A "cookie" is a small text file placed on your device when you visit a website. The types of cookies we use are described below:

You can manage or disable cookies through your browser settings at any time. Please note that disabling strictly necessary cookies may impair your ability to log in and use the ggpanlo platform. For detailed instructions on managing cookies in popular Philippine browsers, refer to your browser's help documentation.

10 Your Data Rights Under RA 10173

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 ggpanlo:

11 Minors and Age Restriction

The ggpanlo Service is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. ggpanlo does not knowingly collect personal data from any person under the age of 21.

We employ age verification procedures during the account registration and KYC process to prevent minors from accessing the Service. Where we discover that personal data has been collected from a person under 21, we will immediately suspend the relevant account, delete the personal data collected, and report the incident as required by applicable regulations.

If you are a parent or guardian and believe that a minor has registered on ggpanlo without your knowledge, please contact us immediately at [email protected] so that we can take prompt corrective action.

12 Changes to This Privacy Policy

ggpanlo may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, or NPC guidance. When material changes are made, we will notify registered players by email and by posting a prominent notice on the platform. The updated Policy will take effect on the date indicated at the top of this page.

Your continued use of the ggpanlo Service following notification of any update constitutes your acceptance of the revised Policy. If you do not agree to the updated terms, you should stop using the Service and contact us to request account closure. We encourage you to review this Policy periodically to stay informed of how we protect your data.

13 Contact Us & Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or the way ggpanlo processes your personal data, you may reach our Data Protection Officer (DPO) and support team through the following channels:

When submitting a data rights request, please include your full name, registered email address, and a clear description of your request. We may ask for additional information to verify your identity before processing the request — this is to ensure the security of your account and protect against unauthorised requests by third parties.