apldo Privacy Policy

1 Introduction

apldo is committed to protecting the privacy and personal data of all Filipino players who use our platform. We recognize that your personal information is sensitive and we take our obligations under the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations seriously.

This Privacy Policy sets out the types of personal data we collect, the purposes for which we collect and process such data, how we protect it, your rights as a data subject, and how to exercise those rights. We encourage you to read this Policy carefully and to contact us if you have any questions regarding how we handle your personal information.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, the data controller responsible for your personal data is apldo, operating the online gaming platform accessible at apldo.cam.

apldo is the entity that determines the purposes and means of processing your personal data. All inquiries, requests, or complaints regarding your personal data should be directed to apldo's designated Data Protection Officer (DPO) or customer support team via the contact details provided in Section 14 of this Policy.

3 Personal Data We Collect

apldo collects various categories of personal data depending on how you interact with our platform. The types of data we collect include:

3.1 Registration & Account Information

• Full legal name (as it appears on your government-issued ID);
• Date of birth;
• Gender;
• Nationality and country of residence;
• Email address;
• Philippine mobile telephone number;
• Home address (for address verification purposes); and
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

Under PAGCOR regulations and anti-money laundering compliance requirements, apldo is required to verify the identity of all players before permitting real-money withdrawals. This requires the submission of:

• A clear photocopy or photograph of a valid government-issued Philippine ID (such as PhilSys National ID, Philippine Passport, Driver's License, SSS ID, UMID Card, or PRC ID);
• Proof of address (such as a recent utility bill, bank statement, or government correspondence); and
• Proof of payment method ownership (screenshot or statement showing your name and the registered payment account).

3.3 Financial & Transaction Data

• Payment method details (GCash mobile number, PayMaya account number, bank account details for BPI/BDO/Metrobank);
• Deposit and withdrawal transaction records, including amounts, dates, and payment methods used;
• Bonus claims, promotional redemptions, and wagering activity; and
• Account balance and wallet transaction history.

3.4 Gaming Activity & Gameplay Data

• Games played, betting history, wins, and losses;
• Session timestamps and durations;
• IP addresses and device identifiers used to access apldo;
• Browser type, operating system, and screen resolution; and
• Location data (country and region level only, derived from IP address).

3.5 Communications & Support Data

• Customer support inquiries, live chat transcripts, and email correspondence;
• Feedback, complaints, and survey responses; and
• Marketing preferences and communication consent settings.

4 How We Use Your Personal Data

apldo processes your personal data for the following purposes:

• Account Creation & Management: To register your apldo account, authenticate your identity at login, and maintain your account settings and preferences;
• KYC & Regulatory Compliance: To verify your identity, age (21+ requirement), and eligibility to participate in online gaming under Philippine law, as required by PAGCOR;
• Payment Processing: To process deposits to and withdrawals from your apldo account via GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment methods;
• Gaming Operations: To provide access to apldo's games, record gameplay outcomes, process bets and payouts, and detect and prevent fraud, collusion, or other prohibited conduct;
• Responsible Gaming: To enforce deposit limits, session reminders, cooling-off periods, and self-exclusion tools you activate on your account;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Marketing & Promotions: To send you promotional offers, bonuses, and platform updates (only where you have consented to receive marketing communications);
• Legal Obligations: To comply with anti-money laundering (AMLA) requirements, tax reporting, PAGCOR audits, and valid legal requests from Philippine law enforcement or regulatory authorities;
• Platform Improvement: To analyze usage patterns, improve game selection, optimize the mobile experience, and enhance overall platform security and performance; and
• Fraud Prevention & Security: To detect unusual account activity, monitor for duplicate accounts, and protect apldo and its players from fraudulent, unauthorized, or illegal activity.

5 Legal Basis for Processing Your Data

Under the Data Privacy Act of 2012, apldo must have a la wful basis for each processing activity. The legal bases apldo relies upon are:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you accepted when registering — including account management, payment processing, and gaming operations;
• Legal Obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws;
• Consent: Processing for optional purposes such as marketing communications, where we have obtained your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing; and
• Legitimate Interests: Processing necessary for apldo's legitimate business interests, such as fraud prevention, platform security, and analytics — provided such interests are not overridden by your fundamental privacy rights under Philippine law.

6 Data Sharing & Disclosure

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

6.1 Payment Service Providers

To process deposits and withdrawals, apldo shares necessary transaction data with Philippine payment service providers including GCash (G-Xchange Inc.), PayMaya Philippines Inc., BPI, BDO Unibank, and Metrobank. These providers are bound by their own privacy obligations under Philippine law and are prohibited from using your data for any purpose other than completing the requested transaction.

6.2 Regulatory & Law Enforcement Authorities

apldo is required by law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities when such disclosure is mandated by law, court order, or regulatory directive. apldo will not notify you of such disclosures where prohibited from doing so by applicable law.

6.3 Game Content Providers

apldo works with licensed game content providers whose software powers our gaming library. These providers may receive pseudonymised gameplay data (such as session identifiers and bet amounts) strictly for the purpose of game operation, technical support, and RNG auditing. Personal identifiers are not shared with game providers beyond what is technically necessary.

6.4 KYC Verification Services

apldo may engage third-party identity verification services to assist with KYC compliance checks. Any such provider is contractually bound to process your identity documents solely for verification purposes and in compliance with the Data Privacy Act.

6.5 Professional Advisers

apldo may share personal data with legal, accounting, or auditing professionals on a confidential basis where necessary for the conduct of apldo's business, subject to applicable professional privilege and confidentiality obligations.

7 Data Retention

apldo 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 following general retention periods apply:

• Account Data: Retained for the duration of your active apldo account and for a period of five (5) years following permanent account closure, as required by PAGCOR audit and AMLA record-keeping obligations;
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of submission, in compliance with anti-money laundering regulations under Philippine law;
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLA record retention requirements;
• Gaming & Gameplay History: Retained for a minimum of three (3) years following account closure for dispute resolution and regulatory audit purposes;
• Customer Support Records: Retained for two (2) years from the date of the last interaction; and
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of consent management.

Upon expiry of the applicable retention period, apldo will securely delete or anonymise your personal data in accordance with its internal data destruction procedures. Anonymised aggregate data that cannot be used to identify any individual may be retained indefinitely for statistical and analytical purposes.

8 Security Measures

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

• 256-bit SSL/TLS Encryption: All data transmitted between your device and apldo's servers is encrypted using industry-standard Transport Layer Security (TLS) protocols;
• Data Encryption at Rest: Sensitive personal data including identity documents and financial records are encrypted at rest on apldo's secure servers;
• Two-Factor Authentication (2FA): Players are encouraged to enable 2FA on their apldo accounts via their registered Philippine mobile number to prevent unauthorized login;
• Access Controls: Access to personal data within apldo's systems is restricted on a need-to-know basis, with role-based access controls and audit logging applied to all systems holding personal data;
• Continuous Monitoring: apldo's systems are monitored continuously for anomalous activity, suspicious login attempts, and potential data breaches; and
• Employee Training: apldo staff who handle personal data are trained in data privacy obligations under the Data Privacy Act and apldo's internal data handling procedures.

9 Cookies & Tracking Technologies

apldo uses cookies and similar tracking technologies on the apldo.cam platform. Cookies are small text files stored on your device by your browser when you visit a website. apldo uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function correctly, including session management, authentication tokens, and security cookies that prevent cross-site request forgery. These cannot be disabled without rendering the platform unusable;
• Functional Cookies: Store your platform preferences such as language settings, display options, and game lobby configurations to improve your experience on return visits;
• Analytics Cookies: Collect aggregated and pseudonymised data about how players navigate the platform — including pages visited, time spent, and features used — to help apldo improve the platform's design and functionality; and
• Session Cookies: Temporary cookies that expire when you close your browser, used to maintain your logged-in state during a gaming session.

apldo does not use third-party advertising cookies or cross-site tracking cookies that share your data with external advertising networks. You may configure your browser to refuse cookies or delete existing cookies at any time. Note that disabling strictly necessary cookies will prevent you from logging into your apldo account.

10 Your Privacy Rights Under Philippine Law

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by apldo:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed — this Privacy Policy fulfils that obligation;
• Right of Access: The right to obtain confirmation of whether apldo holds your personal data and to receive a copy of that data upon written request;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected promptly — you may update certain details directly via your apldo account settings;
• Right to Erasure: The right to request deletion of your personal data, subject to apldo's legal obligations to retain data under AMLA, PAGCOR, and other applicable regulations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes at any time, including withdrawing consent for marketing communications;
• Right to Data Portability: The right to receive a copy of personal data you have provided to apldo in a structured, commonly used format, where technically feasible; and
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your privacy rights have been violated.

To exercise any of the above rights, please contact apldo's support team at [email protected] with the subject line "Data Privacy Request." apldo will acknowledge your request within three (3) business days and respond substantively within thirty (30) days, or such other timeframe as required by the Data Privacy Act.

11 Children's Privacy

apldo's services are strictly restricted to individuals who are 21 years of age or older in compliance with Philippine gaming law. apldo does not knowingly collect personal data from anyone under the age of 21. All accounts undergo age verification during the KYC process using government-issued Philippine identification.

If apldo becomes aware that personal data has been collected from an individual under 21 years of age, that account will be immediately suspended, all associated personal data will be deleted, and any funds held in that account will be dealt with in accordance with applicable Philippine gaming regulations. If you believe a minor has registered on apldo, please contact us immediately at [email protected].

12 International Data Transfers

apldo primarily stores and processes personal data on servers located within or accessible to Philippine-based infrastructure. Where technical operations — such as cloud computing services, game content delivery, or cybersecurity monitoring — require data to be processed by systems located outside the Philippines, apldo ensures that appropriate safeguards are in place.

These safeguards include contractual data processing agreements with all international service providers that impose data protection obligations consistent with the Data Privacy Act of 2012, including restrictions on further transfers, security requirements, and audit rights. apldo does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate compensating controls.

13 Changes to This Privacy Policy

apldo may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or platform operations. Where changes are material — meaning they substantively affect your rights or how your personal data is used — apldo will provide advance notice via the platform and/or by email to your registered address before the changes take effect.

The "Last Updated" date at the top of this Policy reflects the date on which the most recent substantive revision was made. The current version of this Policy will always be accessible at apldo.cam/privacy-policy. Your continued use of apldo following notification of a material change constitutes your acceptance of the revised Privacy Policy. If you do not agree with the revised Policy, you should discontinue use of the platform and may request account closure in accordance with apldo's Terms & Conditions.

14 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or apldo's handling of your personal data, please contact our Data Protection Officer or support team using the following details:

• Email: [email protected]
• Subject Line: Data Privacy Request (for privacy-related enquiries)
• Live Chat: Available within your apldo account after login
• Platform: apldo.cam

apldo handles privacy inquiries in both English and Tagalog. We aim to acknowledge all written privacy requests within three (3) business days and to respond substantively within thirty (30) calendar days, consistent with the Data Privacy Act's requirements. Complex requests involving large volumes of data or requiring coordination with regulatory authorities may take longer, in which case apldo will provide you with an updated timeline.