Aplado Privacy Policy

Aplado ("we," "us," "our," or the "Platform") is committed to protecting the privacy and personal data of every player and visitor who uses our online gaming platform at aplado.net and through the Aplado mobile application. This Privacy Policy describes how Aplado collects, uses, stores, shares, and protects your personal information in connection with your use of our services.

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. It applies to all personal data processed by Aplado in connection with the operation of the platform, regardless of whether such data is collected online, through our mobile application, or through any other channel.

This Privacy Policy should be read together with Aplado's Terms & Conditions, which govern your use of the platform. Capitalised terms not defined in this policy have the meanings given to them in the Terms & Conditions.

Aplado collects the following categories of personal data in connection with the operation of the platform and the provision of our gaming services:

Aplado does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive information is collected — such as government ID details — it is handled with the highest level of care and subject to strict access controls.

Aplado collects personal data through the following means:

• Direct collection: Information you provide when you register an account, complete identity verification, make deposits or withdrawals, contact our support team, or respond to surveys and promotions.
• Automated collection: Technical and usage data collected automatically when you access and use the platform, including through cookies, web beacons, log files, and similar tracking technologies embedded in the website and mobile application.
• Third-party sources: Identity and fraud verification data received from third-party KYC (Know Your Customer) service providers, payment processors, and financial institutions in connection with transaction processing and regulatory compliance.
• Publicly available sources: In limited circumstances, Aplado may supplement your profile with information from publicly available sources for fraud prevention and compliance purposes.

Aplado uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and administer your Aplado player account, including verifying your identity and age (21+ requirement) and managing your account settings and preferences.
• Service delivery: To provide access to our gaming services, process bets and game outcomes, credit winnings, and deliver the full range of features available on the Aplado platform.
• Financial transactions: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods, and to maintain accurate financial records.
• Regulatory compliance: To comply with our obligations under applicable Philippine law, including anti-money laundering (AML) regulations, PAGCOR licensing requirements, and the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other illegal or prohibited conduct on the platform.
• Responsible gaming: To monitor gaming behaviour, enforce responsible gaming limits and self-exclusion requests, and identify players who may be at risk of problem gambling.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Platform improvement: To analyse usage patterns, conduct research, and improve the functionality, performance, and user experience of the Aplado platform.
• Marketing communications: To send you promotional offers, bonuses, and platform updates where you have consented to receive such communications. You may opt out of marketing communications at any time.

Aplado processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing that is necessary to perform our contract with you — that is, to operate your Aplado account and provide the gaming services you have registered to use.
• Legal obligation: Processing that is required to comply with applicable Philippine law, including AML regulations, PAGCOR requirements, tax obligations, and data retention mandates.
• Legitimate interests: Processing carried out for Aplado's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily in relation to marketing communications and the use of non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Aplado does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Payment processors and financial institutions: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers involved in processing your deposits and withdrawals. These parties process your financial data under their own privacy policies and applicable financial regulations.
• Identity verification providers: Third-party KYC and age verification service providers engaged by Aplado to verify your identity and confirm that you meet the 21+ age requirement.
• Game providers: Third-party game developers and providers whose games are available on the Aplado platform. These providers may receive limited technical data necessary to deliver their games.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or regulatory obligation.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by Aplado in connection with the operation of the platform, subject to confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of Aplado's business, your personal data may be transferred to the relevant successor entity, subject to equivalent privacy protections.

Aplado uses cookies and similar tracking technologies on our website and mobile application. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and understand how you use our platform.

We use the following types of cookies:

• Strictly necessary cookies: These cookies are essential for the platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Functional cookies: These cookies remember your preferences and settings — such as your preferred language and display options — to provide a more personalised experience.
• Analytics cookies: These cookies collect anonymised information about how players use the platform, including which pages are visited most frequently and how players navigate between sections. This data helps us improve the platform.
• Marketing cookies: These cookies are used to deliver relevant promotional content and offers. They are only placed with your consent and can be disabled at any time.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Aplado platform. For strictly necessary cookies, no opt-out is available as they are required for the platform to operate.

Aplado retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Account data: Retained for the duration of your active account and for a period of at least five (5) years following account closure, in accordance with AML record-keeping requirements under Philippine law.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Gaming history: Retained for a minimum of three (3) years to support dispute resolution and regulatory compliance.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your consent and for a reasonable period thereafter to demonstrate compliance.
• Technical and usage data: Typically retained for up to twelve (12) months, after which it is anonymised or deleted.

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

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by Aplado:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• 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 used.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to Aplado's legal and regulatory retention obligations.
• 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.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your privacy rights have been violated.

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

• TLS encryption for all data transmitted between your device and Aplado's servers.
• Encryption of sensitive data at rest, including financial and identity information.
• Role-based access controls limiting access to personal data to authorised personnel only.
• Regular security assessments and penetration testing of the platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Staff training on data protection obligations and security best practices.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

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 and, where required, affected players in accordance with the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

The Aplado platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing casino-style online gaming 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 the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be returned through the original payment method following verification.

If you are a parent or guardian and believe that your child has registered on the Aplado platform, please contact us immediately at support@aplado.net so that we can take appropriate action.

Aplado reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — we will notify registered players via the email address associated with their account or through a prominent notice on the platform prior to the changes taking effect.

Your continued use of the Aplado platform following notification of any changes to this Privacy Policy constitutes your acceptance of the revised policy. If you do not agree with the changes, you should discontinue use of the platform and contact us to close your account.

We encourage you to review this Privacy Policy periodically to stay informed about how Aplado is protecting your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way Aplado handles your personal data, please contact our Data Protection Officer. We are committed to addressing your privacy concerns promptly and transparently.

You may reach our Data Protection Officer by email at: privacy@aplado.net

For general support enquiries, account issues, or responsible gaming assistance, please contact our customer support team at: support@aplado.net

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about how to file a complaint is available on the NPC's official channels.

Please include your registered account username and a clear description of your query or concern when contacting us so that we can respond as efficiently as possible.