laro10 Privacy Policy

1. Introduction

1.1 laro10 is committed to protecting the privacy and personal data of all players who use the laro10 platform. We recognise that trust is the foundation of our relationship with our players, and we take our data protection obligations seriously.

1.2 This Policy applies to all personal data collected by laro10 in connection with your use of the laro10 platform, including the laro10 website, the laro10 Login page, the cashier, game interfaces, and any other features or services offered by laro10.

1.3 This Policy is governed by the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as any other applicable data protection laws in the Philippines.

1.4 This Policy should be read in conjunction with laro10's Terms & Conditions, which are incorporated herein by reference.

2. Personal Data We Collect

2.1 laro10 collects the following categories of personal data from players:

2.1.1 Identity Data

• Full legal name;
• Date of birth (for age verification — 21+ requirement);
• Government-issued identification number (e.g., Philippine passport number, SSS number, PhilSys ID number, driver's licence number);
• Nationality and country of residence.

2.1.2 Contact Data

• Email address;
• Mobile phone number (Philippine mobile number, e.g., Globe, Smart, DITO);
• Residential address (including barangay, city/municipality, province).

2.1.3 Financial Data

• GCash or PayMaya (Maya) account details;
• Bank account details (for bank transfer transactions with BPI, BDO, UnionBank, Metrobank, Landbank, PNB, Security Bank, or other Philippine banks);
• Debit card details (card number, expiry date — stored in tokenised form only);
• Transaction history, including deposits, withdrawals, and game wagers.

2.1.4 Technical Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session data, including login timestamps and session duration;
• Cookies and similar tracking data (see Section 7).

2.1.5 Usage Data

• Games played, wager amounts, and game outcomes;
• Bonus and promotion usage;
• Customer support interactions and communications with laro10.

2.1.6 KYC Verification Data

• Copies of government-issued identification documents;
• Proof of address documents (e.g., utility bills, bank statements);
• Selfie or facial verification images (where required for identity verification).

3. How We Collect Your Data

3.1 laro10 collects personal data through the following means:

• Direct collection: Data you provide when registering your laro10 account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Data collected automatically when you use the laro10 platform, including through cookies, log files, and analytics tools;
• Third-party sources: Data received from payment processors (e.g., GCash, PayMaya, banks), identity verification service providers, and fraud prevention services, where necessary to verify your identity or process transactions.

4. How We Use Your Personal Data

4.1 laro10 uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your laro10 account, including processing your laro10 Login and account settings;
• Identity verification: To verify your identity and age (21+ requirement) as required by applicable Philippine regulations;
• Transaction processing: To process deposits, withdrawals, and other financial transactions on the l aro10 platform;
• Customer support: To respond to your enquiries, complaints, and support requests;
• Legal compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR regulatory requirements, and the Data Privacy Act of 2012;
• Fraud prevention: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the laro10 platform;
• Responsible gaming: To monitor gaming behaviour and enforce responsible gaming tools, including deposit limits, cooling-off periods, and self-exclusion;
• Platform improvement: To analyse usage patterns and improve the laro10 platform, games, and services;
• Marketing communications: To send you promotional offers, bonuses, and news about laro10, where you have consented to receive such communications. You may opt out at any time.

5. Legal Basis for Processing

5.1 laro10 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including operating your laro10 account and processing transactions;
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, PAGCOR requirements, and tax obligations;
• Legitimate interests: Processing necessary for laro10's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your explicit consent, including marketing communications and certain cookie usage. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

6.1 laro10 does not sell, rent, or trade your personal data to third parties. laro10 may share your personal data with the following categories of recipients only where necessary and in accordance with this Policy:

• Payment processors: GCash, PayMaya (Maya), and Philippine banks (BPI, BDO, UnionBank, Metrobank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals;
• Identity verification providers: Third-party KYC and age verification service providers engaged by laro10 to verify player identities;
• Fraud prevention services: Third-party fraud detection and prevention service providers;
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers engaged by laro10 to operate the platform;
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where required by law or regulation;
• Legal and professional advisers: Lawyers, auditors, and other professional advisers engaged by laro10 in connection with its legal and compliance obligations.

6.2 All third-party service providers engaged by laro10 are contractually required to process your personal data only in accordance with laro10's instructions and applicable data protection laws.

7. Cookies & Tracking Technologies

7.1 laro10 uses cookies and similar tracking technologies (including web beacons and pixel tags) on the laro10 platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and improve your experience.

7.2 laro10 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the operation of the laro10 platform, including maintaining your laro10 Login session and enabling secure transactions. These cannot be disabled;
• Functional cookies: Used to remember your preferences and settings, such as language and display preferences;
• Analytics cookies: Used to collect anonymised data about how players use the laro10 platform, helping us improve our services;
• Marketing cookies: Used to deliver relevant promotional content about laro10, where you have consented to receive such communications.

7.3 You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the laro10 platform.

8. Data Retention

8.1 laro10 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy applicable legal, regulatory, accounting, and reporting requirements.

8.2 In general, laro10 retains account and transaction data for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations and PAGCOR requirements. KYC verification documents are retained for the same period.

8.3 Where personal data is no longer required for any lawful purpose, laro10 will securely delete or anonymise it in accordance with its data retention and disposal procedures.

9. Data Security

9.1 laro10 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption across all pages of the laro10 platform, including the laro10 Login page and cashier;
• Encryption of sensitive data at rest, including financial data and KYC documents;
• Access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits and penetration testing;
• Firewalls and intrusion detection systems;
• Two-factor authentication (2FA) available for all player accounts.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, laro10 will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.

10. Your Data Rights

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by laro10:

• Right to be informed: The right to be informed about how laro10 collects and uses your personal data, as set out in this Policy;
• Right of access: The right to request a copy of the personal data laro10 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to laro10's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe laro10 has processed your personal data unlawfully.

10.2 To exercise any of the above rights, please contact the laro10 Data Privacy Officer at the contact details provided in Section 15. laro10 will respond to your request within thirty (30) days, or such other period as required by applicable law.

11. Children's Privacy

11.1 The laro10 platform is strictly for persons aged 21 years and above. laro10 does not knowingly collect personal data from persons under 21 years of age. If laro10 becomes aware that personal data has been collected from a person under 21, it will take immediate steps to delete that data and close the relevant account.

11.2 If you believe that laro10 has inadvertently collected personal data from a person under 21, please contact us immediately at the details provided in Section 15.

12. International Data Transfers

12.1 laro10 primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data outside the Philippines — for example, to cloud service providers or technology partners — laro10 will ensure that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012 and NPC guidelines.

12.2 laro10 will only transfer personal data to countries or organisations that provide an adequate level of data protection, or where appropriate contractual safeguards (such as data processing agreements) are in place.

13. Third-Party Links

13.1 The laro10 platform may contain links to third-party websites or services. laro10 is not responsible for the privacy practices of third-party websites and encourages you to review the privacy policies of any third-party sites you visit. This Policy applies solely to data collected by laro10 through the laro10 platform.

14. Updates to This Policy

14.1 laro10 reserves the right to update or amend this Privacy Policy at any time. Where changes are material, laro10 will notify registered players via email or an in-platform notification prior to the changes taking effect.

14.2 The date of the most recent update is displayed at the top of this Policy. Your continued use of the laro10 platform following the posting of an updated Policy constitutes your acceptance of the revised terms.

15. Contact Us & Data Privacy Officer

15.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by laro10, please contact our Data Privacy Officer:

15.2 Data Privacy Officer Email: [email protected]

15.3 General Support Email: [email protected]

15.4 laro10 aims to acknowledge all privacy-related requests within 72 hours and to resolve them within thirty (30) days. Complex matters may require additional time, and laro10 will keep you informed of the progress of your request.

15.5 If you are not satisfied with laro10's response to your privacy request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.