phalaro is committed to protecting the personal data of every Filipino player who uses our platform. This Privacy Policy explains what information we collect, why we collect it, how we use it, and the rights you hold as a data subject under Philippine law. We handle your data with the same seriousness we bring to every aspect of being a PAGCOR-regulated operator.
These are the principles guiding how phalaro handles your personal data. Full legal detail is in the policy below.
All personal data processing by phalaro is conducted in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations issued by the National Privacy Commission.
phalaro does not sell, rent, or lease your personal information to third parties for their own commercial purposes. Your data is processed only for the purposes described in this Privacy Policy.
All data transmitted between your device and phalaro's servers is protected with 256-bit Transport Layer Security (TLS) encryption — the same standard applied by major Philippine banks and financial institutions.
phalaro collects only the personal data necessary to provide gaming services, process payments, comply with PAGCOR and AML requirements, and maintain account security. We do not collect data beyond what is needed for these stated purposes.
Under RA 10173, you have the right to access, correct, delete, and port your personal data, to object to processing, and to lodge a complaint with the National Privacy Commission. phalaro will action all data subject requests within 30 days.
phalaro retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by Philippine law and PAGCOR regulatory obligations. Account data is deleted or anonymised upon expiry of the applicable retention period.
This Privacy Policy ("Policy") describes how phalaro ("phalaro," "we," "us," "our"), the operator of the online gaming platform at phalaro.org, collects, processes, stores, shares, and protects the personal data of users ("Players," "you," "your") in connection with your use of the phalaro Platform.
phalaro is a PAGCOR-regulated online gaming operator serving Filipino players across the Philippines. As a regulated entity, phalaro is subject to the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and relevant issuances of the National Privacy Commission ("NPC"). These obligations inform every aspect of how phalaro handles your personal information.
By creating a phalaro account, accessing the Platform, or submitting personal information to phalaro in any manner, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. This Policy is incorporated by reference into phalaro's Terms and Conditions.
For the purposes of the Philippine Data Privacy Act, phalaro is the Personal Information Controller (PIC) in respect of the personal data collected through the Platform. phalaro determines the purposes for which and the manner in which personal data is processed in connection with the phalaro gaming service.
phalaro has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with data privacy obligations and serving as the primary point of contact for data subject inquiries and complaints. Contact details for the DPO are provided in Section 14 of this Policy.
phalaro collects the following categories of personal data in connection with the provision of its online gaming services:
phalaro collects personal data through the following channels and mechanisms:
phalaro processes personal data only for the purposes set out below and in accordance with at least one lawful basis under RA 10173:
| Purpose | Legal Basis (RA 10173) |
|---|---|
| Account registration and identity verification (KYC) | Contractual necessity; compliance with legal obligation (PAGCOR KYC requirements) |
| Age verification (21+ PAGCOR requirement) | Compliance with legal obligation |
| Processing deposits and withdrawals via GCash, Maya, and bank transfer | Contractual necessity; legitimate interests |
| Providing and improving gaming services | Contractual necessity; legitimate interests |
| Anti-Money Laundering (AML) transaction monitoring | Compliance with legal obligation (AMLA and PAGCOR requirements) |
| Fraud detection and account security | Legitimate interests; contractual necessity |
| Responsible gaming monitoring and intervention | Compliance with legal obligation (PAGCOR responsible gaming rules); legitimate interests |
| Customer support and dispute resolution | Contractual necessity; legitimate interests |
| Promotional communications (where opted in) | Consent |
| Platform analytics and performance optimisation | Legitimate interests (anonymised or aggregated data) |
| Compliance with PAGCOR reporting obligations | Compliance with legal obligation |
phalaro does not sell, rent, or trade your personal data to third parties for their own commercial purposes. phalaro may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements or legal obligations:
GCash (G-Xchange, Inc.), Maya (Voyager Innovations), and Philippine banking partners receive transaction data necessary to process your deposits and withdrawals. These entities operate under their own privacy and data protection policies and applicable Bangko Sentral ng Pilipinas (BSP) regulations.
Third-party KYC service providers engaged by phalaro receive identity documents and information for the sole purpose of verifying your identity and age in compliance with PAGCOR requirements. These providers are contractually bound to process data only for the specified purpose and to maintain appropriate security standards.
phalaro may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), and other Philippine government authorities where required by law, court order, or regulatory directive. Disclosure is limited to the minimum data required to comply with the applicable legal obligation.
Certain game providers whose content is available on the phalaro Platform may receive anonymised or pseudonymised gameplay data necessary for game integrity and technical operation purposes. phalaro does not share personally identifiable information with game content providers beyond what is technically necessary.
Legal counsel, auditors, and other professional advisers engaged by phalaro may access personal data on a confidential basis to the extent required for the provision of their professional services.
phalaro retains personal data for the periods set out below, or such longer period as may be required by applicable Philippine law or PAGCOR regulation:
On expiry of the applicable retention period, phalaro will securely delete or anonymise the relevant personal data such that it can no longer be linked to an individual.
phalaro implements appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, alteration, disclosure, or destruction. These measures include:
While phalaro takes all reasonable steps to secure your data, no system is completely immune from risk. You also have a responsibility to keep your phalaro account credentials secure and to notify us immediately of any suspected unauthorised access.
phalaro uses cookies and similar tracking technologies on the Platform to enable essential functionality, maintain your session, detect fraud, and analyse usage patterns. The following categories of cookies are used:
You may configure your browser to block or delete cookies. Note that blocking strictly necessary cookies will prevent you from accessing the phalaro Platform. phalaro does not use advertising or third-party tracking cookies for cross-site profiling purposes.
phalaro strictly enforces the PAGCOR minimum age requirement of 21 years for all real-money gaming activities. The Platform is not directed at, and is not intended for use by, individuals under the age of 21. phalaro does not knowingly collect personal data from individuals under 21.
If phalaro discovers or has reasonable grounds to believe that personal data has been collected from an individual under 21, such data will be deleted promptly, the associated account will be permanently closed, and all balances will be held pending review in accordance with PAGCOR guidelines.
Under the Philippine Data Privacy Act (RA 10173), you have the following rights with respect to your personal data processed by phalaro. To exercise any of these rights, contact phalaro's DPO using the details in Section 14. phalaro will respond within thirty (30) calendar days of receiving a verifiable request.
You have the right to be informed about how phalaro collects and processes your personal data. This Privacy Policy fulfils phalaro's obligation under this right.
You may request a copy of the personal data phalaro holds about you, along with information about the purposes for which it is processed and the categories of recipients with whom it has been shared.
You may request correction of inaccurate or incomplete personal data. For account details, you can update most information directly in your phalaro account dashboard. For KYC-related data, contact our support team.
You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to phalaro's legal and regulatory retention obligations.
You may object to processing based on legitimate interests or for direct marketing purposes. Where you object to marketing communications, phalaro will honour the request immediately. Objects to other processing will be assessed on a case-by-case basis.
Where technically feasible, you may request a copy of personal data you provided to phalaro in a structured, commonly used, machine-readable format for transfer to another service provider.
If you believe phalaro has not handled your personal data in compliance with RA 10173, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.
Certain service providers engaged by phalaro, including cloud infrastructure providers, certain game content providers, and technical platform partners, may process data in jurisdictions outside the Philippines. Where such transfers occur, phalaro ensures that appropriate safeguards are in place as required by RA 10173 and NPC regulations, including contractual obligations requiring the receiving party to afford a comparable level of data protection.
phalaro does not transfer personal data internationally for the purpose of evading Philippine data privacy requirements. All cross-border data flows involving phalaro player data are documented and governed by appropriate data transfer agreements.
phalaro may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, PAGCOR regulatory requirements, or Platform functionality. Where changes are material — particularly where they affect your rights as a data subject or the purposes for which your data is processed — phalaro will notify you by email to your registered address or via a prominent notice on the Platform at least fourteen (14) days before the changes take effect.
The "Last updated" date at the top of this Policy will always reflect the date of the most recent revision. Continued use of the Platform following notification of material changes constitutes acceptance of the updated Policy. If you do not accept the changes, you should cease using the Platform and may request account closure.
For all privacy-related inquiries, data subject rights requests, and complaints regarding phalaro's data processing practices, please contact phalaro's Data Protection Officer using the details below:
phalaro endeavours to respond to all data subject rights requests within thirty (30) calendar days of receipt. Where a request requires additional time due to its complexity, phalaro will notify you within the initial 30-day period and provide an estimated completion date.
If you are not satisfied with phalaro's response to a data privacy complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.
phalaro is PAGCOR-regulated, RA 10173 compliant, and built from the ground up for Filipino players who want to game safely. Your personal data is never sold. Your account is protected by 256-bit encryption. For players 21 and older only.