aplado Privacy Policy

1. Introduction

aplado ("we", "us", "our") is committed to protecting the privacy and personal data of all individuals who use the aplado Platform at aplado.app. This Privacy Policy describes how aplado collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform, including account registration, gameplay, financial transactions, and customer support interactions.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). It should be read together with aplado's Terms & Conditions, which govern your use of the Platform.

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

2. Data Controller

aplado is the data controller responsible for your personal data collected through the Platform. As data controller, aplado determines the purposes and means of processing your personal information and is accountable for ensuring that such processing complies with applicable Philippine data privacy laws.

aplado has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data privacy regulations. Contact details for the DPO are provided in Section 16 of this Policy.

3. Personal Data We Collect

aplado collects the following categories of personal data in connection with your use of the Platform:

• Identity Data: Full legal name, date of birth, nationality, government-issued identification number (e.g., Philippine National ID, passport, driver's license), and a photograph or scan of your identity document.
• Contact Data: Email address, mobile phone number, and residential address (including city, province, and postal code).
• Account Data: Username, encrypted password, account registration date, account status, and communication preferences.
• Financial Data: Payment method details (e.g., GCash mobile number, Maya account reference, bank account name and number for bank transfer), transaction history, deposit and withdrawal records, and account balance information. aplado does not store full payment card numbers.
• Gaming Data: Game history, wager amounts, win/loss records, session duration, game preferences, and bonus usage history.
• Technical Data: IP address, device type and model, operating system, browser type and version, time zone, and unique device identifiers.
• Usage Data: Pages visited on the Platform, features accessed, click-stream data, session timestamps, and referral source.
• Communications Data: Records of your interactions with aplado's customer support team, including live chat transcripts, email correspondence, and support ticket history.
• Responsible Gaming Data: Self-exclusion status, deposit limit settings, cooling-off period records, and any responsible gaming assessments conducted in connection with your account.

4. How We Collect Your Data

aplado collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or updating your account profile.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, through cookies, web beacons, server logs, and similar tracking technologies (see Section 8).
• Third-party sources: Identity verification data from KYC service providers; fraud and sanctions screening data from compliance databases; payment confirmation data from payment processors (GCash, Maya, banking partners).
• Regulatory sources: Self-exclusion register data from PAGCOR or other regulatory bodies, where applicable.

5. Legal Basis for Processing

aplado processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your account, process transactions, and provide gaming services.
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Personal Data

aplado uses your personal data for the following purposes:

• To create, verify, and manage your aplado account.
• To process deposits, withdrawals, and other financial transactions.
• To verify your identity and age (21+) in compliance with PAGCOR requirements and Philippine law.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities.
• To provide customer support and respond to your inquiries and complaints.
• To administer bonuses, promotions, and loyalty programs.
• To monitor and enforce responsible gaming obligations, including processing self-exclusion requests and applying deposit limits.
• To analyze Platform usage and improve our products, services, and user experience.
• To send you transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts) — these are not optional as they are necessary for account operation.
• To send you marketing communications about aplado's products and promotions, where you have opted in to receive them.
• To comply with our legal and regulatory obligations, including reporting to PAGCOR and the Anti-Money Laundering Council (AMLC) where required.

7. Sharing Your Personal Data

aplado does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We 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, and banking partners, to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist aplado in verifying your identity and age in compliance with PAGCOR and AMLA requirements.
• Fraud prevention and compliance services: Providers of sanctions screening, fraud detection, and anti-money laundering tools.
• Game software providers: Third-party game developers whose games are hosted on the aplado Platform may receive limited gameplay data necessary to operate their games.
• IT and hosting service providers: Cloud infrastructure, data storage, and cybersecurity vendors who process data on aplado's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory instruction.
• Professional advisers: Lawyers, auditors, and accountants, where necessary for the conduct of aplado's business and subject to professional confidentiality obligations.

All third-party service providers who process personal data on aplado's behalf are required to enter into data processing agreements that obligate them to handle your data securely, use it only for the specified purpose, and comply with applicable Philippine data privacy laws.

8. Cookies and Tracking Technologies

aplado uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations. Disabling these may affect your experience.
• Analytics cookies: Collect anonymized or pseudonymized data about how users interact with the Platform, helping aplado identify areas for improvement. These are only set with your consent.
• Marketing cookies: Used to deliver relevant promotional content within the Platform based on your activity. These are only set with your explicit consent.

You can manage your cookie preferences through your browser settings at any time. Note that disabling certain cookies may limit the functionality of the Platform. For detailed information on the specific cookies aplado uses, please refer to our Cookie Notice, available within the Platform's account settings.

9. Data Retention

aplado retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention periods:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by AMLA and PAGCOR regulations.
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer support records: Retained for three (3) years from the date of the interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your marketing subscription and for two (2) years following withdrawal of consent, as evidence of the consent given.
• Technical and usage data: Retained for up to thirteen (13) months in identifiable form, after which it is aggregated or anonymized.

Upon expiry of the applicable retention period, aplado will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless retention is required by a specific legal obligation or ongoing regulatory investigation.

10. Data Security

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

• Transport Layer Security (TLS) encryption for all data transmitted between your device and aplado's servers.
• Encryption of sensitive data at rest, including financial records and identity documents.
• Role-based access controls ensuring that aplado staff can only access personal data necessary for their specific job functions.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Staff training on data privacy and security obligations on a regular basis.
• 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, aplado will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, as required by the Data Privacy Act and NPC Circular No. 16-03.

While aplado takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for keeping your account credentials confidential and for notifying aplado immediately if you suspect unauthorized access to your account.

11. Your Rights 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 aplado:

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data aplado holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your aplado account settings.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to aplado's legal obligations to retain certain records.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests. Objection to marketing will be honored immediately; objection to other processing will be assessed on a case-by-case basis.
• Right to restrict processing: The right to request that aplado limits the processing of your personal data in certain circumstances, such as while a rectification request is being assessed.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe aplado has violated your data privacy rights. The NPC can be reached through its official channels.

To exercise any of the above rights, please contact aplado's Data Protection Officer using the contact details in Section 16. aplado will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. aplado may request proof of identity before processing your request to protect against unauthorized access to your data.

12. Children's and Minors' Privacy

The aplado Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing casino-style gambling in the Philippines. aplado does not knowingly collect personal data from individuals under the age of 21.

If aplado becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be suspended immediately, all associated data will be reviewed, and the data will be deleted to the extent permitted by applicable law. Any funds held in an underage account will be handled in accordance with aplado's Terms & Conditions and applicable regulatory requirements.

If you are a parent or guardian and believe that your child under 21 has registered an account on aplado, please contact our Data Protection Officer immediately using the details in Section 16.

13. International Data Transfers

aplado's primary operations and data storage are based in the Philippines. In certain circumstances, your personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or game software vendors operating internationally.

Where such transfers occur, aplado ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under Philippine law. aplado will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining your consent.

14. Third-Party Links and Services

The aplado Platform may contain references to third-party services, such as payment processors, that have their own privacy policies. aplado is not responsible for the privacy practices of third-party services and encourages you to review their privacy policies before providing any personal data to them.

aplado's Privacy Policy applies solely to data collected through the aplado Platform at aplado.app. It does not apply to any data collected by third parties through their own platforms or services, even where those services are accessed in connection with your use of aplado.

15. Changes to This Privacy Policy

aplado reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. Material changes will be communicated to registered users via email or prominent notice on the Platform at least seven (7) days before taking effect.

The "Last updated" date at the top of this page reflects the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how aplado protects your personal data. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

16. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or aplado's handling of your personal data, please contact our Data Protection Officer:

• Role: Data Protection Officer, aplado
• Email: privacy@aplado.app
• General Support: support@aplado.app

aplado aims to respond to all privacy-related inquiries within fifteen (15) business days. If you are not satisfied with aplado's response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) through its official complaint channels.