funpanalo Privacy Policy

1 Introduction

funpanalo ("we", "us", "our") is committed to protecting the privacy and personal data of all individuals who interact with our platform. This Privacy Policy describes how funpanalo collects, uses, discloses, stores, and safeguards personal information in connection with the operation of the funpanalo online gaming platform accessible at funpanalo.asia.

This Privacy Policy applies to all Players, registered users, visitors, and any other individuals whose personal data is processed by funpanalo in the course of operating our platform and fulfilling our obligations under Philippine law, including our PAGCOR licensing requirements.

By registering an Account on funpanalo or by continuing to use our Platform, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. This Policy should be read together with our Terms & Conditions, which are available at /terms-conditions.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, funpanalo acts as the Personal Information Controller in respect of the personal data it collects and processes in connection with the operation of the funpanalo Platform.

funpanalo operates under PAGCOR licensing regulations and is subject to the oversight of both PAGCOR and the National Privacy Commission of the Philippines. Our designated Data Protection Officer (DPO) can be contacted through the support channels listed in Section 15 of this Policy.

3 Personal Data We Collect

funpanalo collects the following categories of personal data in the course of operating our Platform:

funpanalo does not collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly necessary for identity verification and compliance with our PAGCOR licensing obligations and anti-money laundering requirements.

4 How We Collect Your Data

funpanalo collects personal data through the following means:

• Direct collection: Information you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and interact with the funpanalo Platform, including through cookies, log files, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; transaction data from payment processors such as GCash, PayMaya, and Philippine banking partners; fraud prevention data from security service providers.
• Regulatory sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with our licensing obligations or investigations.

5 How We Use Your Personal Data

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

• To create, manage, and maintain your funpanalo Account, including verifying your identity and age (21+ requirement) in compliance with PAGCOR regulations.
• To process deposits, withdrawals, and other financial transactions through GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels.
• To provide customer support via live chat and email, and to resolve disputes or complaints.
• To comply with our legal and regulatory obligations, including anti-money laundering (AML) requirements, PAGCOR reporting obligations, and the Data Privacy Act of 2012.
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited activities on the Platform.
• To monitor gameplay patterns for responsible gaming purposes, including identifying Players who may be exhibiting signs of problem gambling.
• To send you transactional communications, including deposit confirmations, withdrawal notifications, and security alerts.
• To send you promotional communications about funpanalo offers and bonuses, where you have consented to receive such communications.
• To improve and personalise your experience on the funpanalo Platform through analytics and usage data.
• To enforce our Terms & Conditions and other platform policies.

6 Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you, including operating your Account, processing transactions, and providing gaming services.
• Legal obligation: Processing required to comply with applicable Philippine law, including PAGCOR licensing conditions, anti-money laundering regulations, and tax reporting requirements.
• Legitimate interests: Processing necessary for funpanalo's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing & Disclosure

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

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your financial transactions.
• KYC and identity verification providers: Third-party service providers engaged to assist with identity verification and age confirmation in compliance with PAGCOR requirements.
• Fraud prevention and security providers: Service providers who assist funpanalo in detecting and preventing fraudulent activity, money laundering, and other prohibited conduct.
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers who process data on funpanalo's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by funpanalo, subject to professional confidentiality obligations.

8 Data Retention

funpanalo retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and our PAGCOR licensing obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, in accordance with anti-money laundering record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required under Philippine AML regulations.
• KYC verification documents: Retained for a minimum of five (5) years following Account closure or the completion of the relevant transaction.
• Customer support communications: Retained for a period of two (2) years from the date of the communication, unless a longer period is required for dispute resolution purposes.
• Technical and usage data: Retained for a period of twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

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

9 Cookies & Tracking Technologies

funpanalo uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain session security, and gather analytics data. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the Platform, including maintaining your login session and ensuring platform security. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences and settings, such as language preferences and display options, to personalise your experience on funpanalo.
• Analytics cookies: Used to collect aggregated, anonymised data about how Players use the Platform, helping funpanalo identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats to the Platform.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the funpanalo Platform. funpanalo does not use third-party advertising or behavioural tracking cookies.

10 Data Security

funpanalo implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the funpanalo Platform.
• Encryption of sensitive data at rest, including financial information and identity documents, using industry-standard encryption protocols.
• Role-based access controls ensuring that funpanalo staff can only access personal data to the extent necessary for their specific job functions.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, funpanalo will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

11 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by funpanalo:

• 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 funpanalo 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 our legal 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 processing is based on consent or contractual necessity.
• 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 of the Philippines if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact funpanalo's Data Protection Officer through the support channels listed in Section 15. We will respond to all verified data subject requests within fifteen (15) business days, in accordance with NPC guidelines. We may require you to verify your identity before processing your request.

12 Children's Privacy

The funpanalo Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing real-money gaming in the Philippines. funpanalo does not knowingly collect personal data from individuals under the age of 21.

If funpanalo becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated Account. If you believe that a minor has registered on the funpanalo Platform, please contact our support team immediately so that we can investigate and take appropriate action.

Age verification is a mandatory step in the funpanalo registration and KYC process. We take our obligations to prevent underage gambling seriously and cooperate fully with PAGCOR's responsible gaming framework.

13 Cross-Border Data Transfers

funpanalo primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed from locations outside the Philippines, for example where funpanalo engages international technology service providers for cloud hosting, KYC verification, or fraud prevention services.

Where personal data is transferred outside the Philippines, funpanalo ensures that appropriate safeguards are in place to protect your data, including:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission.
• Implementing contractual data protection clauses with international service providers that require them to protect personal data to standards equivalent to those required under Philippine law.
• Conducting due diligence on international service providers to verify their data security practices prior to engagement.

14 Updates to This Privacy Policy

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

Where changes to this Privacy Policy are material, funpanalo will notify registered Players via email or an in-platform notification prior to the changes taking effect. We encourage you to review this Privacy Policy periodically to stay informed about how funpanalo protects your personal data.

Your continued use of the funpanalo Platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the revised terms. If you do not agree with the updated Policy, you may request Account closure by contacting our support team.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or funpanalo's data processing practices, please contact our Data Protection Officer through the following channels:

• Live Chat: Available 24/7 through the funpanalo Platform. Our support team can escalate data protection queries to the DPO within one business day.
• Support Email: [email protected]

For complaints that cannot be resolved directly with funpanalo, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through their official government channels.