palago Privacy Policy

1. Introduction

palago ("palago", "we", "us", "our") operates the online gaming platform available at palago.co. We are committed to protecting the privacy and personal data of all players, visitors, and users ("you", "your", "data subject") who interact with our platform.

This Privacy Policy ("Policy") describes in detail the types of personal data we collect, the purposes and legal basis for processing, how data is stored and secured, who we may share it with, how long we keep it, and the rights you hold as a data subject under Philippine law — specifically the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

This Policy applies to all palago services, including account registration, deposits and withdrawals, gaming activity, promotions, and customer support interactions — whether accessed via desktop, mobile browser, or any palago-branded interface.

2. Data Controller

palago acts as the data controller responsible for the personal data collected through the platform. As data controller, palago determines the purposes and means of processing personal data and is accountable for compliance with the Data Privacy Act of 2012.

palago has designated a Data Protection Officer (DPO) responsible for overseeing data protection compliance and serving as the point of contact for data subject inquiries and complaints. Contact details for the DPO are provided in Section 15 of this Policy.

3. Data We Collect

3.1 Identity & Contact Data

• Full legal name;
• Date of birth (to verify 21+ age eligibility);
• Philippine mobile number (used as primary account identifier);
• Email address (optional secondary contact);
• Residential address (required for enhanced KYC and large withdrawal processing).

3.2 Identity Verification (KYC) Data

• Scanned or photographed copies of government-issued Philippine identification documents (e.g., PhilSys ID, passport, UMID, driver's licence, voter's ID, PRC ID);
• Selfie or live photograph for biometric identity matching;
• Proof of payment method ownership documents where required.

3.3 Financial Data

• GCash account reference numbers, Maya wallet references, bank account names and last digits (sufficient for transaction reconciliation but never full account credentials);
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment methods;
• Account wallet balances and bonus credit records.

3.4 Gaming & Activity Data

• Game session logs including game type, bet amounts, outcomes, and timestamps;
• Sports betting selections, odds, and wager history;
• Login timestamps, session durations, and logout events;
• Responsible gaming tool usage (deposit limits set, self-exclusion requests).

3.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, browser type and version;
• Cookie identifiers and session tokens;
• Platform access logs for security and fraud detection purposes.

3.6 Communication Data

• Records of live chat, Messenger, Viber, and email support interactions;
• Any information you voluntarily provide when contacting palago support.

4. How We Collect Data

palago collects personal data through the following means:

• Directly from you — when you complete the registration form, submit KYC documents, make deposits or withdrawals, contact support, or participate in promotions;
• Automatically — through cookies, server logs, and analytics tools during your use of the palago platform;
• From third parties — identity verification service providers used to process KYC submissions; payment processors including GCash and Maya; fraud detection and AML screening partners; regulatory authorities where legally required.

5. Legal Basis for Processing

palago processes personal data on the following legal bases under the Data Privacy Act of 2012:

6. How We Use Your Data

palago uses your personal data for the following purposes:

• To create, maintain, and manage your palago player account;
• To verify your identity, age (21+), and eligibility to participate on the platform;
• To process deposits, withdrawals, and bonus transactions;
• To detect, investigate, and prevent fraudulent transactions, money laundering, and other illegal activities;
• To comply with legal and regulatory obligations, including reporting to PAGCOR and the Anti-Money Laundering Council (AMLC);
• To provide customer support and resolve complaints or disputes;
• To administer promotions, bonuses, and loyalty programmes you participate in;
• To enforce our Terms & Conditions and Responsible Gaming policies;
• To send service communications, including transaction receipts, security alerts, and policy update notices;
• To send promotional communications where you have provided explicit consent and not subsequently withdrawn it;
• To improve platform performance, user experience, and game offerings through aggregated analytics.

7. Data Sharing & Disclosure

palago does not sell or rent your personal data. We may share personal data with the following categories of recipients only as necessary and with appropriate data protection safeguards in place:

• Payment processors — GCash (GXI), Maya (Voyager Innovations), banks, and e-wallet operators to process transactions you initiate;
• Identity verification providers — third-party KYC platforms engaged to process document verification and biometric matching;
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and courts, where disclosure is required by law or court order;
• Technology service providers — cloud hosting, cybersecurity, fraud detection, and platform infrastructure providers operating under data processing agreements;
• Game providers — game studios (such as JILI, Pragmatic Play, PG Soft) receive limited session data necessary to operate certified gaming titles;
• Professional advisors — legal counsel, auditors, and compliance consultants bound by confidentiality obligations.

Any third party with whom palago shares data is contractually required to protect that data in accordance with applicable Philippine data privacy laws and to use it solely for the purposes specified.

8. International Data Transfers

Where personal data is transferred outside the Philippines — for example, to cloud infrastructure providers or international game studios — palago ensures that appropriate safeguards are in place, including standard contractual clauses or confirmation that the receiving country provides an adequate level of data protection consistent with Philippine law.

Such transfers are limited to what is strictly necessary and are conducted in compliance with the National Privacy Commission's guidelines on cross-border data transfers.

9. Data Retention

palago retains personal data for as long as necessary to fulfil the purposes for which it was collected, and in accordance with applicable legal and regulatory retention requirements:

• Active account data — retained throughout the lifetime of your palago account;
• Transaction and gaming records — retained for a minimum of five (5) years following account closure, as required by AML regulations;
• KYC documentation — retained for a minimum of five (5) years from the date of the last transaction or account closure;
• Support communication records — retained for three (3) years;
• Technical logs and device data — retained for up to twelve (12) months unless extended for active investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with palago's data disposal procedures.

10. Cookies & Tracking Technologies

The palago platform uses cookies and similar tracking technologies to operate core platform functions and improve your experience. The categories of cookies palago uses are as follows:

• Essential cookies — required for the platform to function, including login session management, security token validation, and CSRF protection. These cannot be disabled;
• Analytics cookies — used to collect aggregated, anonymised information about how players use palago (pages visited, session duration, feature engagement) to guide product improvements;
• Fraud detection cookies — used to identify unusual access patterns or suspicious account behaviour for security purposes.

palago does not use third-party advertising cookies or cross-site tracking for behavioural advertising. You may manage cookie preferences through your browser settings; however, disabling essential cookies will impair core platform functionality including login capability.

11. Security Measures

palago implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data processed, including:

• 256-bit SSL/TLS encryption for all data transmissions between your device and palago servers;
• Encrypted storage of sensitive data at rest using industry-standard cryptographic algorithms;
• Salted cryptographic hashing of account passwords — palago staff cannot read your password in plain text;
• Role-based access controls ensuring that only authorised palago personnel access player data on a need-to-know basis;
• Regular independent security audits and penetration testing;
• Two-factor authentication (2FA) options for player accounts;
• Automated intrusion detection and anomaly monitoring systems.

While palago takes all reasonable precautions, no system is entirely immune to breach. In the event of a confirmed personal data breach that poses risk to data subjects, palago will notify affected players and the National Privacy Commission within 72 hours of discovery.

12. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you hold the following rights in relation to your personal data processed by palago:

• Right to be informed — to know what personal data palago holds about you and how it is used (addressed by this Policy);
• Right of access — to request a copy of the personal data palago holds about you;
• Right to rectification — to request correction of inaccurate or incomplete personal data;
• Right to erasure — to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to object — to object to processing based on legitimate interests, including direct marketing;
• Right to data portability — to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint — to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of the above rights, contact palago's Data Protection Officer using the details in Section 15. We will respond to verified requests within thirty (30) days. Identity verification is required before processing any data subject rights request.

13. Children & Minors

palago's services are strictly for individuals aged 21 years and above as required by PAGCOR regulations and Philippine law. palago does not knowingly collect personal data from persons under 21 years of age. If palago discovers that an account has been registered by an underage individual, the account will be immediately suspended, all data will be deleted to the extent permitted by legal obligations, and any funds will be handled in accordance with regulatory requirements.

If you believe a minor has registered on palago, please contact our support team immediately.

14. Amendments to This Policy

palago reserves the right to amend this Privacy Policy at any time to reflect changes in applicable laws, regulatory requirements, or palago's data processing practices. Material changes will be communicated to registered players via their registered mobile number or email address, or by a prominent notice on the palago platform, at least fourteen (14) days before the changes take effect.

Your continued use of palago following the effective date of any amendment constitutes acceptance of the revised Privacy Policy. If you do not accept the revised Policy, you must cease using palago and may request account closure.

15. Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact palago's Data Protection Officer:

• Email: [email protected] (mark subject as "Data Privacy Request")
• Live Chat: Available 24/7 via the palago platform
• Messenger / Viber: palago official support channels

If you are not satisfied with palago's response to a data privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

This Privacy Policy was last updated in June 2026 and supersedes all previous versions. Continued use of palago constitutes acceptance of this Policy in its current form.