Privacy Policy

1. Who We Are

1.1 panako is an online gaming platform accessible at panako.org, offering casino games, live dealer tables, bingo, slots, and other gaming products to eligible players in the Philippines.

1.2 For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173), panako acts as the personal information controller in respect of the personal data it collects from players and visitors to the panako platform.

1.3 panako is committed to handling all personal data responsibly, transparently, and in full compliance with applicable Philippine data protection legislation, including RA 10173 and its Implementing Rules and Regulations.

2. Personal Data We Collect

2.1 panako collects the following categories of personal data from players and platform visitors:

Category	Examples	Purpose
Identity Data	Full name, date of birth, nationality, government ID number	Account registration, KYC verification, age verification
Contact Data	Email address, mobile number, residential address	Account communication, transaction notifications, support
Financial Data	GCash number, PayMaya account, BPI/BDO/Metrobank account details	Deposit and withdrawal processing, fraud prevention
Gaming Data	Wager history, game sessions, win/loss records, bonus usage	Account management, responsible gaming monitoring, dispute resolution
Technical Data	IP address, device type, browser type, operating system, session logs	Platform security, fraud detection, service optimization
Usage Data	Pages visited, features used, time spent on platform, click patterns	Platform improvement, personalization, analytics

2.2 panako does not intentionally collect sensitive personal information as defined under RA 10173 (such as health data, political opinions, or religious beliefs) unless specifically required for regulatory compliance purposes, in which case your explicit consent will be sought.

3. How We Collect Your Data

3.1 panako collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the panako platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers, fraud screening data from security partners, and payment data from payment processors such as GCash and PayMaya.
• Publicly available sources: Information from public registries or databases where necessary for regulatory compliance or fraud prevention purposes.

4. How panako Uses Your Personal Data

4.1 panako uses the personal data it collects for the following purposes:

• To create, manage, and maintain your panako player account;
• To verify your identity and age in compliance with applicable gaming regulations (21+ requirement);
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP / ₱);
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To provide customer support and respond to your queries and complaints;
• To send you transactional communications, including account notifications and security alerts;
• To administer bonuses, promotions, and loyalty programs you have opted into;
• To monitor your gaming activity for responsible gaming purposes and to apply any self-imposed limits or exclusions;
• To comply with legal and regulatory obligations, including reporting requirements under applicable Philippine law;
• To improve the panako platform, analyze usage patterns, and develop new features.

4.2 panako will not use your personal data for purposes that are incompatible with those listed above without first obtaining your explicit consent.

5. Legal Basis for Processing

5.1 panako processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and panako, including account management and transaction processing;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering requirements and gaming regulations;
• Legitimate interests: Processing necessary for panako's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications and non-essential cookies.

6. Sharing Your Personal Data

6.1 panako does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. Your data may be shared only in the following circumstances:

• Service providers: Trusted third-party vendors who assist panako in operating the platform, including KYC verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), IT infrastructure providers, and customer support tools. All such providers are bound by strict data processing agreements.
• Regulatory and law enforcement authorities: Where panako is required by law, court order, or regulatory directive to disclose personal data to Philippine government agencies, law enforcement bodies, or gaming regulators.
• Anti-fraud and security networks: Where necessary to prevent or investigate fraud, money laundering, or other illegal activity, panako may share data with industry fraud prevention bodies.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of panako's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

6.2 Where panako shares your data with third-party service providers, it remains responsible for ensuring that such providers handle your data in accordance with this Privacy Policy and applicable Philippine data protection law.

7. Cookies and Tracking Technologies

7.1 The panako platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze platform usage. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences and settings to provide a more personalized experience on panako.
• Analytics cookies: Collect anonymized data about how players use the platform, helping panako identify areas for improvement.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats.

7.2 You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the panako platform.

8. Data Retention

8.1 panako retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the duration of your active account and for a period thereafter as required by applicable law.

8.2 In general, panako applies the following retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering regulations.
• Transaction and gaming records: Retained for a minimum of five (5) years from the date of the transaction or gaming session.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Technical and usage data: Retained for up to twelve (12) months, after which it is anonymized or deleted.

8.3 Where panako is required by law to retain data for a longer period, the statutory retention period will apply. Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized.

9. Data Security

9.1 panako implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the panako platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Strict role-based access controls limiting internal access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication requirements for internal systems access;
• Incident response procedures to detect, contain, and report data breaches in accordance with RA 10173.

9.2 In the event of a personal data breach that is likely to result in harm to affected players, panako will notify the National Privacy Commission and affected individuals within the timeframes prescribed by the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

10. Your Data Protection Rights

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

• Right to be informed: You have the right to be informed about how panako collects and uses your personal data, as set out in this Privacy Policy.
• Right of access: You may request a copy of the personal data panako holds about you, along with information about how it is processed.
• Right to rectification: You may request that panako correct any inaccurate or incomplete personal data held about you.
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to panako's legal retention obligations.
• Right to object: You may object to the processing of your personal data where panako relies on legitimate interests as the legal basis, or where data is used for direct marketing.
• Right to data portability: You may request that panako provide your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe panako has not handled your personal data in accordance with RA 10173.

10.2 To exercise any of the above rights, please contact the panako Data Protection Officer using the contact details provided in Section 14 of this Privacy Policy. panako will respond to all verified requests within thirty (30) days of receipt.

10.3 panako may need to verify your identity before processing a data rights request to ensure that personal data is not disclosed to unauthorized individuals.

11. Children's Privacy and the 21+ Requirement

11.1 The panako platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with Philippine gaming regulations. panako does not knowingly collect personal data from individuals under the age of 21.

11.2 If panako becomes aware that personal data has been collected from an individual under the age of 21, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the panako platform, please contact the panako support team immediately.

12. Cross-Border Data Transfers

12.1 In some cases, panako may transfer your personal data to service providers or infrastructure partners located outside the Philippines. Where such transfers occur, panako ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Philippine law.

12.2 Such safeguards may include contractual clauses approved by the National Privacy Commission, binding corporate rules, or transfers to countries recognized as providing an adequate level of data protection.

12.3 By using the panako platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Privacy Policy, subject to the safeguards described above.

13. Updates to This Privacy Policy

13.1 panako may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or platform features. The effective date at the top of this page indicates when the current version came into force.

13.2 Where changes to this Privacy Policy are material, panako will notify registered players by email or through a prominent notice on the platform prior to the changes taking effect. Your continued use of the panako platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

13.3 The most current version of this Privacy Policy is always available at panako.org/privacy-policy.

14. Contact Us and Data Protection Officer

14.1 panako has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, you may contact the panako DPO at:

14.2 Email: [email protected]

14.3 For general support inquiries unrelated to data privacy, you may contact the panako customer support team at: [email protected]

14.4 If you are not satisfied with panako's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.