Privacy Policy

Phalaro ("Phalaro," "we," "us," or "our") operates the online gaming platform accessible at https://phalaro.com and through the Phalaro mobile application (collectively, the "Platform"). We are committed to protecting the personal data of every player, visitor, and user who interacts with our Platform.

This Privacy Policy ("Policy") describes how Phalaro collects, uses, stores, shares, and protects your personal data. It also explains the rights you have under Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and how you can exercise those rights.

By registering an account, accessing the Platform, or otherwise providing your personal data to Phalaro, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform and contact us to close your account.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, which are incorporated herein by reference.

Phalaro collects the following categories of personal data from players and users of the Platform:

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by applicable law or regulatory obligation (for example, collecting information about problem gambling history for responsible gaming purposes, with your explicit consent).

Phalaro collects your personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from payment processors; and publicly available information used to verify your identity or detect suspicious activity;
• Payment providers: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners when you make deposits or request withdrawals.

Phalaro uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your Phalaro account, including verifying your identity and age (21+ requirement);
• Transaction processing: To process deposits, withdrawals, and bonus payments via your chosen payment method;
• Legal and regulatory compliance: To comply with anti-money laundering (AML) obligations, PAGCOR regulatory requirements, and the Data Privacy Act of 2012;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and unauthorized access to the Platform;
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Responsible gaming: To monitor gaming patterns, enforce self-exclusion requests, and provide responsible gaming tools to players who may need them;
• Platform improvement: To analyze usage patterns, fix bugs, and develop new features that improve the Phalaro experience for Filipino players;
• Marketing communications: To send you promotional offers, bonuses, and platform updates where you have consented to receive such communications. You may opt out at any time.

Under the Data Privacy Act of 2012, Phalaro processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration, including account management and transaction processing;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, PAGCOR requirements, and tax reporting;
• Legitimate interests: Processing necessary for Phalaro's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your explicit consent, including marketing communications and the collection of any sensitive personal information. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Phalaro does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners, solely to process your financial transactions;
• Identity verification providers: Third-party KYC service providers engaged to verify your identity and age in compliance with regulatory requirements;
• Fraud prevention services: Specialist providers who assist Phalaro in detecting and preventing fraudulent activity on the Platform;
• IT and hosting providers: Cloud infrastructure and technology service providers who host and maintain the Phalaro Platform under strict data processing agreements;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where disclosure is required by law or court order;
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third parties with whom Phalaro shares personal data are required to handle that data in accordance with the Data Privacy Act of 2012 and are bound by appropriate data processing agreements.

Phalaro retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account data: Retained for the duration of your account and for five (5) years following account closure, in accordance with AML and regulatory requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations;
• Identity verification documents: Retained for five (5) years following account closure or the completion of the relevant transaction;
• Customer support communications: Retained for two (2) years from the date of the interaction;
• Technical and usage data: Retained for up to twelve (12) months, after which it is anonymized or deleted.

When personal data is no longer required, Phalaro will securely delete or anonymize it in accordance with our data disposal procedures.

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls ensuring that only authorized personnel can access personal data on a need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Multi-factor authentication for staff accessing systems that contain personal data;
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC notification requirements.

While Phalaro takes all reasonable steps to protect your data, no system is completely immune to security risks. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

Phalaro uses cookies and similar tracking technologies to enhance your experience on the Platform. A cookie is a small text file placed on your device when you visit a website. We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function, including session management and security. These cannot be disabled;
• Functional cookies: Remember your preferences such as language settings and login status to provide a more personalized experience;
• Analytics cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized;
• Marketing cookies: Used to deliver relevant promotional content. These are only placed with your explicit consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. By continuing to use the Platform after being presented with our cookie notice, you consent to our use of non-essential cookies.

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

To exercise any of these rights, please contact our Data Privacy Officer at privacy@phalaro.com. We will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

The Phalaro Platform is strictly intended for individuals who are twenty-one (21) years of age or older, in accordance with Philippine gaming regulations. Phalaro does not knowingly collect personal data from persons under the age of 21.

If we become aware that we have inadvertently collected personal data from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data, and return any deposited funds to the payment source. If you believe that a minor has registered on the Platform, please contact us immediately at support@phalaro.com.

Phalaro primarily stores and processes your personal data within the Philippines. In certain circumstances, your data may be transferred to and processed in countries outside the Philippines, for example where we use cloud infrastructure providers or specialist service providers with operations in other jurisdictions.

Where such transfers occur, Phalaro ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to provide a level of data protection equivalent to that required under the Data Privacy Act of 2012. We will not transfer your personal data to a jurisdiction that does not provide adequate data protection without your explicit consent or a lawful basis under the DPA.

Phalaro reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email or a prominent notice on the Platform, and update the "Last Updated" date at the top of this page.

We encourage you to review this Policy periodically to stay informed about how Phalaro protects your personal data. Your continued use of the Platform following the posting of an updated Policy constitutes your acceptance of the changes.

If you have any questions, concerns, or complaints about this Privacy Policy or the way Phalaro handles your personal data, please contact our Data Privacy Officer:

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012 and ensuring compliance by personal information controllers operating in the Philippines.