pabcor Privacy Policy

1. Introduction & Data Controller

pabcor Gaming Corporation ("pabcor," "we," "us," "our") is committed to protecting the privacy and security of personal information provided by players and visitors to our Platform. This Privacy Policy describes our practices concerning the collection, use, storage, disclosure, and protection of personal data in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and issuances of the National Privacy Commission (NPC).

pabcor Gaming Corporation, a company duly incorporated under Philippine law with principal office in Metro Manila, Philippines, acts as the Data Controller for all personal information processed through the pabcor Platform. As Data Controller, we determine the purposes and means of processing your personal data and are responsible for ensuring compliance with applicable data protection laws.

By creating a pabcor account, using our services, or providing personal information to us, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein, subject to your rights under the Data Privacy Act.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a pabcor account, we collect the following personal information:

• Identity Information: Full legal name, date of birth, nationality, gender, government-issued identification number (as shown on submitted ID documents)
• Contact Information: Email address, mobile phone number, residential address (street, barangay, city/municipality, province, postal code)
• Account Credentials: Username, password (stored in hashed form), security questions and answers
• Financial Information: Payment method details (GCash mobile number, PayMaya account, bank account number and bank name), transaction history, deposit and withdrawal records
• Verification Documents: Copies of government-issued identification (passport, driver's license, national ID, etc.), proof of address documents, selfie photographs for identity verification
• Communication Records: Content of customer support inquiries, live chat transcripts, email correspondence, complaint submissions

2.2 Information Collected Automatically

When you access the pabcor Platform, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers
• Connection Information: IP address, internet service provider, geographic location (city/region level, not precise GPS coordinates)
• Usage Data: Pages visited, games played, bet amounts, session duration, click patterns, feature usage, timestamps of activity
• Cookies and Tracking: Session cookies, preference cookies, analytics cookies (see Section 9 for details)

2.3 Information from Third Parties

We may receive limited information from third-party service providers, including payment processors (transaction confirmation, fraud screening results), identity verification services (ID authentication results, AML database checks), and game providers (gameplay statistics, technical diagnostics). We do not purchase marketing lists or consumer profiles from data brokers.

3. How We Use Your Information

pabcor processes your personal information for the following purposes:

3.1 Account Management & Service Delivery

• Creating and maintaining your pabcor account
• Authenticating your identity when you log in
• Processing deposits, withdrawals, and other financial transactions
• Enabling gameplay on casino games, live dealer tables, sports betting, and other Platform features
• Maintaining accurate records of your transactions, bets, and account balances
• Providing customer support and responding to your inquiries

3.2 Legal & Regulatory Compliance

• Verifying you meet the minimum age requirement (21 years) for gambling in the Philippines
• Complying with PAGCOR licensing conditions and reporting obligations
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by law
• Detecting and preventing fraud, money laundering, terrorist financing, and other illegal activity
• Responding to lawful requests from PAGCOR, the Anti-Money Laundering Council (AMLC), National Privacy Commission, courts, or law enforcement agencies
• Maintaining audit trails and records for regulatory inspection

3.3 Security & Fraud Prevention

• Monitoring for suspicious account activity, unusual betting patterns, or signs of account compromise
• Detecting and preventing bonus abuse, collusion, use of bots or automated software, and other Terms violations
• Protecting pabcor and other players from fraud, identity theft, and financial crime
• Investigating disputes, complaints, and reported violations

3.4 Platform Improvement & Analytics

• Analyzing usage patterns to improve user experience, navigation, and feature design
• Conducting statistical analysis of gameplay, payment method preferences, and platform performance
• Testing new features, games, and functionality before full release
• Optimizing Platform performance for Philippine internet connections and mobile devices

3.5 Communication & Marketing

• Sending transactional emails and SMS notifications (deposit confirmations, withdrawal status, password resets, security alerts)
• Delivering promotional offers, bonus announcements, and new game releases (only if you have opted in to marketing communications)
• Sending important account updates, Terms changes, and regulatory notices (these are mandatory communications not subject to opt-out)

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, pabcor processes your personal information based on the following lawful grounds:

• Consent: You have provided explicit consent to processing of your personal data for specific purposes (account registration, marketing communications, optional features)
• Contract Performance: Processing is necessary to fulfill our contractual obligations to provide gambling services under our Terms and Conditions
• Legal Obligation: Processing is required to comply with Philippine laws, including PAGCOR regulations, AML/CFT laws, data privacy laws, and tax reporting requirements
• Legitimate Interests: Processing is necessary for legitimate business interests (fraud prevention, platform security, service improvement) that do not override your fundamental rights and freedoms

5. Information Sharing & Disclosure

5.1 No Sale of Personal Information

pabcor does not sell, rent, or trade your personal information to third parties for their marketing purposes. Your data is not a commodity.

5.2 Service Providers & Business Partners

We share limited personal information with trusted third-party service providers who assist in Platform operations, including:

• Payment Processors: GCash, PayMaya, Philippine banks, and card payment gateways process financial transactions on our behalf
• Identity Verification Services: Third-party KYC/AML providers authenticate identity documents and screen against watchlists
• Game Providers: Software companies (Evolution Gaming, Pragmatic Play, others) delivering live dealer and slot game content
• Technology Infrastructure: Cloud hosting, database management, security monitoring, and technical support providers
• Customer Support: Support ticketing systems and live chat platforms used by our customer service team

All service providers are contractually bound to confidentiality obligations, data protection requirements, and restrictions on use of your information beyond the services they provide to pabcor. We conduct due diligence on service providers' data security practices before engagement.

5.3 Legal Disclosure & Regulatory Authorities

We may disclose personal information when required by Philippine law or lawful government request, including:

• Responding to PAGCOR inquiries, audits, and regulatory investigations
• Complying with court orders, subpoenas, and search warrants
• Reporting suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Cooperating with National Privacy Commission investigations of data breaches or complaints
• Providing information to law enforcement investigating crimes involving pabcor accounts

5.4 Business Transfers

In the event of a merger, acquisition, sale of assets, or bankruptcy proceeding involving pabcor, your personal information may be transferred to the successor entity. You will be notified of any such change in ownership and given the opportunity to delete your account before transfer if you object.

6. Data Security Measures

pabcor implements comprehensive technical, organizational, and physical security measures to protect personal information from unauthorized access, disclosure, alteration, or destruction:

6.1 Technical Security

• Encryption: SSL/TLS encryption for all data transmitted between your device and pabcor servers; encryption-at-rest for stored sensitive data
• Access Controls: Role-based access restrictions limiting employee access to personal data on a need-to-know basis
• Authentication: Strong password requirements, optional two-factor authentication, session timeout controls
• Network Security: Firewalls, intrusion detection systems, DDoS protection, regular security patching
• Monitoring: Real-time security event logging, anomaly detection, automated alert systems

6.2 Organizational Security

• Employee Training: Mandatory data privacy and security training for all staff with access to personal information
• Confidentiality Agreements: Contractual obligations binding employees and contractors to data confidentiality
• Incident Response: Documented procedures for detecting, containing, and responding to data breaches
• Vendor Management: Security assessments and contractual data protection requirements for third-party service providers

6.3 Physical Security

• Data Center Security: Our servers are housed in secure, access-controlled data centers with 24/7 monitoring, biometric access, and environmental controls
• Backup Systems: Regular encrypted backups stored in geographically separate locations to ensure data availability and disaster recovery

While we employ industry-standard security measures, no system is completely immune to security risks. You play an important role in protecting your account by maintaining strong, unique passwords, not sharing login credentials, and reporting suspicious activity immediately.

7. Data Retention & Deletion

7.1 Retention Periods

pabcor retains personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Account Information: Retained for the duration of your account's active status, plus 7 years after account closure (as required by PAGCOR and tax regulations)
• Financial Records: Transaction history, deposit/withdrawal records, and related financial documentation retained for 7 years after the transaction date (AML/CFT legal requirement)
• Identity Documents: Copies of government IDs and verification documents retained for 7 years after last account activity (AML/CFT and PAGCOR compliance)
• Communication Records: Customer support inquiries and correspondence retained for 3 years
• Usage Data: Anonymous analytics data retained indefinitely for statistical purposes; identifiable usage logs retained for 1 year

7.2 Data Deletion

Upon expiration of applicable retention periods, personal information is securely deleted or anonymized using industry-standard data destruction methods. You may request deletion of your personal data subject to our legal retention obligations. Certain information cannot be deleted while legal retention requirements remain in effect, but will be isolated from active systems and deleted once the retention period expires.

8. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

8.1 Right to Access

You have the right to obtain confirmation of whether pabcor is processing your personal data and to access the personal information we hold about you. You may request a copy of your personal data through your account settings or by contacting customer support.

8.2 Right to Rectification

If your personal information is inaccurate, incomplete, or outdated, you have the right to request correction. You can update most account information directly through your account settings. For changes to verified identity information (name, date of birth), contact customer support with supporting documentation.

8.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal information, subject to our legal retention obligations. Accounts can be closed and eligible data deleted by submitting a deletion request to customer support. Data subject to legal retention requirements will be deleted after the retention period expires.

8.4 Right to Object

You may object to processing of your personal information for direct marketing purposes at any time by opting out of marketing communications. For objections to other types of processing, contact customer support with your specific concerns. We will assess whether legitimate grounds exist to continue processing.

8.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format (CSV or JSON) and to transmit this data to another data controller. Request data export through customer support.

8.6 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal. Some services may become unavailable if you withdraw consent necessary for their provision.

9. Cookies & Tracking Technologies

9.1 What Are Cookies

Cookies are small text files stored on your device when you visit the pabcor Platform. Cookies enable the Platform to remember your preferences, authenticate your session, and provide personalized features.

9.2 Types of Cookies We Use

• Essential Cookies: Required for basic Platform functionality, including login authentication, session management, and security features. These cannot be disabled.
• Preference Cookies: Remember your language selection, display settings, and other customizable preferences to enhance user experience.
• Analytics Cookies: Collect anonymous usage statistics to help us understand how players interact with the Platform and identify areas for improvement. We use Google Analytics with IP anonymization enabled.
• Security Cookies: Help detect fraudulent activity, unusual login patterns, and potential security threats to protect your account.

9.3 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Disabling cookies may limit your ability to use certain Platform features. To manage cookies, access your browser's privacy or settings menu. Note that essential cookies cannot be disabled without losing access to the Platform.

10. International Data Transfers

pabcor primarily stores and processes personal information within the Philippines. However, some service providers (cloud hosting, payment processing, game providers) may operate servers or facilities outside the Philippines. When personal data is transferred internationally, we ensure adequate protection through:

• Contractual data protection clauses requiring foreign processors to maintain standards equivalent to Philippine data protection law
• Selection of service providers in jurisdictions recognized by the National Privacy Commission as having adequate data protection frameworks
• Technical safeguards including encryption in transit and at rest

International data transfers are limited to what is necessary for Platform operation and comply with the cross-border data transfer requirements of the Data Privacy Act.

11. Children's Privacy

The pabcor Platform is not intended for use by individuals under 21 years of age. We do not knowingly collect personal information from minors. Account registration requires age verification, and accounts found to belong to underage individuals are immediately suspended and deleted.

If you believe we have inadvertently collected information from a minor, please contact us immediately at [email protected] so we can delete the information and close the account. Parents and guardians are encouraged to monitor their children's internet usage and prevent access to gambling websites.

12. Changes to This Policy

pabcor reserves the right to update this Privacy Policy to reflect changes in our practices, legal requirements, or operational needs. Material changes will be communicated via email notification, prominent Platform notice, or notification upon next login at least 7 days before taking effect.

The "Last Updated" date at the top of this document reflects the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed of how we protect your information. Continued use of the Platform after changes take effect constitutes acceptance of the updated Privacy Policy.

13. Contact & Complaints

13.1 Data Protection Officer

For questions, concerns, or requests regarding this Privacy Policy or your personal information, contact our Data Protection Officer:

• Email: [email protected] (subject line: "Privacy Inquiry" or "Data Protection Officer")
• Response Time: We aim to respond to privacy inquiries within 15 days as required by the Data Privacy Act

13.2 National Privacy Commission Complaints

If you are not satisfied with our response to a privacy concern or believe we have violated your data protection rights, you have the right to file a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission
• 5th Floor, Philippine International Convention Center (PICC), Vicente Sotto Street, Pasay City, Metro Manila 1307
• Email: [email protected]
• Website: privacy.gov.ph
• Hotline: (02) 8234-2228

Document Version: v3.0 | Last Updated: October 8, 2026 | Effective Date: October 8, 2026