aplado Privacy
Policy

This Privacy Policy ("Policy") describes how aplado ("aplado," "we," "us," or "our"), operator of the online gaming platform at aplado.org, collects, uses, stores, discloses, and protects the personal information of users ("you," "Player," or "Data Subject") who register for or use the aplado platform and associated services.

aplado is committed to protecting your personal information in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the applicable regulations of the National Privacy Commission ("NPC") of the Philippines. aplado is also subject to the data governance requirements imposed by the Philippine Amusement and Gaming Corporation ("PAGCOR") as a condition of its gaming license.

By creating an aplado account, accessing the aplado platform, or otherwise providing your personal information to aplado, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal information as described herein.

For the purposes of the Philippine Data Privacy Act of 2012, the Personal Information Controller (PIC) responsible for your personal data is:

• Entity Name: aplado
• Platform: aplado.org
• Business Location: Manila, Philippines
• Regulatory Authority: PAGCOR (Philippine Amusement and Gaming Corporation)
• Data Protection Officer (DPO) Contact: [email protected] (plain text — not a clickable link)

aplado has designated a Data Protection Officer as required under the DPA and NPC regulations. The DPO is responsible for overseeing aplado's data privacy compliance program, serving as the point of contact for data subject requests, and liaising with the National Privacy Commission.

aplado collects the following categories of personal information from Players, the specific items within each category depending on the stage of the player relationship and applicable regulatory requirements:

aplado collects personal information through the following channels:

4.1 Directly from You

• When you create an aplado account and complete the registration process;
• When you complete KYC verification and submit identity documents;
• When you make a deposit or initiate a withdrawal and provide payment details;
• When you contact aplado's support team via live chat or any other communication channel;
• When you respond to surveys, promotions, or other communications from aplado;
• When you update your account information through account settings.

4.2 Automatically Through Platform Use

• Technical data (IP address, device information, browser type) collected automatically when you access the aplado platform;
• Gaming activity data generated by your participation in games, betting activity, and use of platform features;
• Session data including login times, duration of sessions, and navigation patterns within the platform;
• Cookie and tracking technology data as described in Section 8 of this Policy.

4.3 From Third Parties

• Identity verification data from licensed KYC service providers used to confirm the accuracy of documents you submit;
• Payment confirmation data from GCash, PayMaya, and banking partners to verify successful transactions;
• Fraud and AML screening data from authorised financial intelligence service providers;
• Public records data where applicable for compliance screening purposes.

Under the Philippine Data Privacy Act of 2012, aplado processes your personal information on the following legal bases:

• Contractual Necessity: Processing is necessary to fulfil aplado's obligations under the account agreement between aplado and you as a Player — including account creation, identity verification, payment processing, game delivery, and customer support.
• Legal Obligation: Processing is required to comply with applicable legal obligations under Philippine law, including PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act (RA 10173), and applicable tax regulations.
• Legitimate Interests: Processing is necessary for aplado's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and improvement of services — provided these interests are not overridden by your privacy rights.
• Consent: For certain optional data processing activities — such as sending promotional communications — aplado relies on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

aplado uses your personal information for the following purposes, each tied to one or more of the legal bases described in Section 5:

• Account Management: Creating, verifying, maintaining, and securing your aplado account; authenticating your identity at login; processing password resets and account recovery requests.
• Payment Processing: Facilitating deposits and withdrawals via GCash, PayMaya, bank transfers, and other approved methods; verifying payment instrument ownership; maintaining transaction records.
• Regulatory Compliance: Fulfilling PAGCOR licensing obligations; conducting and maintaining Anti-Money Laundering (AML) screening; meeting Know Your Customer (KYC) requirements; responding to lawful regulatory enquiries and directions.
• Fraud and Security: Detecting, investigating, and preventing fraudulent activity, account takeover attempts, money laundering, bonus abuse, and prohibited multi-accounting.
• Responsible Gaming: Monitoring gaming activity to identify potential signs of problem gambling; facilitating self-exclusion requests, cooling-off periods, and deposit limit settings; enforcing the 21+ age requirement.
• Customer Support: Responding to enquiries, complaints, and dispute submissions; maintaining records of support interactions for quality assurance and compliance purposes.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve game performance, user interface, and platform reliability. This analysis does not involve decisions based solely on automated processing that produce significant legal effects.
• Marketing Communications: Sending promotional offers, bonus notifications, and gaming updates to players who have consented to receive such communications. You may opt out at any time by contacting aplado support.

aplado does not sell, rent, or trade your personal information to third parties. aplado may share your personal data with third parties only in the following circumstances and to the minimum extent necessary:

7.1 Service Providers (Personal Information Processors)

aplado engages licensed third-party service providers who process personal data on aplado's behalf under binding data processing agreements that require them to maintain confidentiality and comply with the DPA. These include: identity verification (KYC) providers, payment processors (GCash, PayMaya, banking partners), cloud hosting and data storage providers, fraud and AML screening services, customer support platform providers, and game software providers where technically required.

7.2 Regulatory and Law Enforcement Authorities

aplado may disclose personal information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), or any other competent Philippine government authority where disclosure is required by law, regulation, court order, or lawful regulatory direction. aplado will notify affected players of such disclosures to the extent permitted by applicable law.

7.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or restructuring involving aplado, personal data held by aplado may be transferred to the acquiring entity as part of the transaction, subject to equivalent data protection obligations being assumed by the transferee.

aplado uses cookies and similar tracking technologies on its platform to ensure the proper functioning of the website, maintain your login session, enable security features, and collect aggregated analytics data to improve platform performance.

8.1 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the basic operation of the aplado platform — including session authentication, security tokens, and fraud prevention signals. These cannot be disabled without preventing the platform from functioning correctly.
• Functional Cookies: Enable personalisation features such as remembering your language preference and game settings between sessions. These enhance your experience but are not essential to core platform function.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the aplado platform — pages visited, time spent, features used — to help aplado identify areas for improvement. Individual players are not identifiable in this data.
• Security Cookies: Help aplado detect and prevent suspicious activity including account takeover attempts and fraudulent transactions by recording session characteristics that can be compared against historical patterns.

8.2 Managing Cookies

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair or prevent your ability to use the aplado platform. Disabling functional or analytics cookies will not prevent you from using the platform but may reduce personalisation features. Detailed cookie management instructions are available in the help documentation of your browser.

aplado retains personal data for the periods set out below, after which data is securely deleted or irreversibly anonymised, unless a longer retention period is required by law:

Where retention is extended beyond the periods above due to a specific legal obligation, investigation, or litigation, aplado will document the reason for extended retention and restrict access to the minimum number of personnel required.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal information held by aplado. To exercise any of these rights, contact aplado's Data Protection Officer through the support channel.

aplado implements organisational and technical security measures appropriate to the risk level of the personal data processed. These include, but are not limited to:

• Encryption: All data transmitted between your device and the aplado platform is protected by SSL/TLS encryption. Personal data at rest is encrypted using industry-standard methods.
• Access Controls: Strict role-based access controls limit aplado personnel's access to personal data to the minimum necessary for their specific function. All access events are logged and subject to periodic review.
• Two-Factor Authentication: aplado account access is protected by OTP-based two-factor authentication for new devices and security-sensitive actions.
• Pseudonymisation: Where technically feasible, aplado pseudonymises personal data used in analytics and system testing to reduce the risk of re-identification.
• Regular Security Audits: aplado's platform and data systems undergo regular security assessments by internal and, periodically, independent external security professionals.
• Staff Training: All aplado personnel with access to personal data receive mandatory data privacy and security training as part of onboarding and on an ongoing basis.
• Incident Response: aplado maintains a documented data breach response procedure that includes notification workflows for affected players and the National Privacy Commission as required by the DPA.

aplado does not knowingly collect personal information from individuals under the age of twenty-one (21) years. The aplado platform is strictly intended for adults who meet the minimum age requirement under PAGCOR regulations and applicable Philippine law.

All aplado accounts are subject to identity verification (KYC) procedures that include confirmation of date of birth. Any account found to belong to a person under 21 years of age will be permanently closed immediately upon discovery. Personal data associated with such accounts will be handled in accordance with the DPA and the specific requirements applicable to processing personal information of minors.

If you are a parent or guardian and believe that your child has provided personal information to aplado or has accessed the aplado platform, please contact aplado's support team immediately. aplado will investigate promptly, close the account if confirmed, and delete any personal information attributable to the minor as permitted by applicable legal retention requirements.

aplado reserves the right to update this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidance, PAGCOR regulatory requirements, or aplado's data processing activities. All updates will be posted on this page with a revised "Last Updated" date.

For material changes — that is, changes that significantly affect how we collect, use, or share your personal information — aplado will provide notice to registered players via the mobile number associated with their account or through a prominent notice on the aplado platform prior to the change taking effect.

Your continued use of the aplado platform after the effective date of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the updated Policy, you should discontinue use of the aplado platform and contact support to discuss your account options.

For any questions about this Privacy Policy, to exercise your data subject rights, or to report a privacy concern, please contact aplado's Data Protection Officer through the following channels:

• Live Chat: Available 24/7 directly through the aplado platform after logging into your account — this is the fastest channel for urgent privacy matters.
• Email (Data Privacy Matters): [email protected] — please include "Privacy Request" in your subject line for faster routing to the DPO team.
• Business Address: Manila, Philippines
• Response Time: Acknowledgement within 5 business days; substantive response within 30 calendar days.

If you are not satisfied with aplado's response to your privacy complaint or data subject request, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent regulatory authority responsible for enforcing the Data Privacy Act.