gpanalo Privacy Policy

gpanalo is an online casino and sports betting platform operated for Filipino players through the website gpanalo.net. For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), gpanalo acts as the Personal Information Controller (PIC) in respect of the personal data you provide when registering, depositing, playing, or otherwise interacting with our platform.

As Personal Information Controller, gpanalo is responsible for determining the purposes and means of processing your personal data and for ensuring that such processing is carried out in a manner consistent with RA 10173, applicable National Privacy Commission (NPC) issuances, PAGCOR regulatory requirements, and the Anti-Money Laundering Act (AMLA) of the Philippines.

gpanalo collects personal data across several categories depending on your level of interaction with the platform. The following table summarizes the categories of personal information we collect and the context in which each category arises:

gpanalo collects your personal information through the following channels and mechanisms:

Directly from You: The majority of data we hold is information you actively provide to us — when you register your gpanalo account, complete KYC verification, make a deposit, request a withdrawal, set responsible gaming limits, or contact our customer support team.

Automatically Through Your Use of the Platform: When you visit gpanalo.net or use the platform, we automatically collect Technical and Behavioral Data through cookies, web beacons, server logs, and similar tracking technologies. This data is collected to maintain platform security, detect fraud, personalize your experience, and analyze platform performance. See Section 7 for full details on our cookie practices.

From Third-Party Payment Providers: When you make a deposit or withdrawal via GCash, Maya, BPI, BDO, Metrobank, InstaPay, or PesoNet, our payment processing partners share transaction confirmation data with gpanalo to credit or debit your gpanalo wallet. gpanalo does not receive or store your full GCash PIN, bank account password, or complete card number — only confirmation references and masked account identifiers necessary to link the transaction to your account.

From Identity Verification Services: For enhanced KYC, gpanalo may use third-party identity verification providers. These providers process your submitted documents and return a verification result to gpanalo. The underlying document data is processed by the provider in accordance with their own privacy policies and applicable Philippine data protection obligations.

From Regulatory Sources: gpanalo may receive information about you from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine government bodies in the exercise of their regulatory or law enforcement functions.

gpanalo uses your personal data for the following clearly defined purposes. We do not use your data for any purpose beyond those listed here without first obtaining your consent or establishing a separate lawful basis under RA 10173:

• Account Creation and Management: To register your gpanalo account, authenticate your identity on login, maintain your account settings and preferences, and manage your wallet balance.
• Identity Verification (KYC): To verify that you are who you say you are, that you meet the 21+ age requirement, and that your account is not being used for fraud, money laundering, or other prohibited purposes — as required under PAGCOR regulations and the AMLA.
• Payment Processing: To process your deposits and withdrawals via GCash, Maya, and other supported Philippine payment channels, and to maintain accurate records of all financial transactions on your account.
• Game Services: To provide access to casino games, live dealer tables, sports betting markets, bingo, and all other gpanalo platform features, and to accurately record game results and account for winnings and losses.
• Customer Support: To respond to your queries, investigate complaints, resolve disputes, and provide technical assistance via chat and email.
• Responsible Gaming: To monitor for signs of problem gambling behavior, apply deposit and loss limits you have set, enforce self-exclusion orders, and comply with our responsible gaming obligations under PAGCOR guidelines.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, multi-accounting, bonus abuse, money laundering, and other prohibited conduct on the platform.
• Legal and Regulatory Compliance: To meet our obligations under RA 10173, the AMLA, PAGCOR regulations, and any other applicable Philippine laws, including the filing of covered and suspicious transaction reports with the AMLC.
• Platform Improvement: To analyze aggregated, anonymized behavioral and technical data for the purpose of improving platform performance, game offerings, user experience, and responsible gaming tools.
• Marketing Communications (with consent): To send you promotional offers, bonus notifications, and platform updates via email or SMS — but only where you have opted in to receive marketing communications. You may withdraw your consent at any time by updating your communication preferences in your account settings or by contacting support.

Under the Data Privacy Act of 2012 and its IRR, gpanalo processes your personal information on one or more of the following lawful bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and gpanalo — specifically, to provide the gaming services you have registered for, process your deposits and withdrawals, and maintain your account.
• Legal Obligation: Processing is required for gpanalo to comply with its legal obligations under Philippine law, including PAGCOR licensing conditions, the AMLA, RA 10173 itself, and applicable court orders or regulatory directions.
• Legitimate Interests: Processing is necessary for gpanalo's legitimate interests in operating a secure, fair, and compliant gaming platform — including fraud detection, platform security, responsible gaming monitoring, and internal analytics — provided those interests are not overridden by your rights and interests.
• Consent: For processing activities that are not covered by the above bases — primarily direct marketing communications and the use of non-essential cookies — gpanalo relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

gpanalo does not sell, rent, or trade your personal data. We share your information only in the circumstances described below, and only to the extent necessary for the stated purpose:

Payment Processing Partners: We share the minimum necessary transaction data with GCash, Maya, BPI, BDO, Metrobank, InstaPay, PesoNet, GrabPay, and 7-Eleven CLiQQ to process your deposits and withdrawals. Each of these partners is bound by their own privacy obligations under Philippine law.

Identity Verification Providers: We may share your submitted KYC documents with accredited identity verification service providers for the purpose of verifying your identity. These providers process data solely as Personal Information Processors (PIPs) acting on gpanalo's instructions and are contractually bound to process data only for the specified purpose.

Game Content Providers: Third-party game studios and live casino providers integrated into the gpanalo platform may receive limited technical data (such as a session token or player ID) necessary to deliver game content and record game outcomes. These providers do not receive your name, contact details, or financial information.

Regulatory Authorities: gpanalo is legally obligated to share information with PAGCOR, the AMLC, the National Privacy Commission, and other Philippine government bodies when required by law, regulation, court order, or lawful authority. This includes the filing of covered and suspicious transaction reports under the AMLA.

Professional Advisors: We may share information with our lawyers, auditors, and accountants on a strictly need-to-know basis and subject to professional confidentiality obligations, where necessary to obtain legal or professional advice or to conduct audits of gpanalo's operations.

gpanalo uses cookies and similar tracking technologies on the gpanalo.net website. A cookie is a small text file placed on your device when you visit a website. Cookies allow the site to recognize your device on subsequent visits and enable certain platform functionality.

Types of Cookies We Use:

• Strictly Necessary Cookies: Essential for the gpanalo platform to function. These include session authentication cookies, security tokens, and cookies that remember your login state and wallet balance. You cannot opt out of strictly necessary cookies without ceasing to use the platform.
• Functional Cookies: Remember your preferences such as your chosen language, game display settings, and responsible gaming reminders. These improve your experience but are not essential to basic platform operation.
• Analytics Cookies: Collect aggregated, anonymized data about how players use gpanalo.net — which pages are visited most, where players encounter errors, and how long sessions last. This data helps us improve the platform. We use analytics tools that process data in accordance with RA 10173 and do not share identifiable player data with analytics providers.
• Security Cookies: Used by our fraud prevention and security systems to detect bot activity, multiple account creation, and suspicious session patterns. These cookies are strictly necessary for platform integrity.

Managing Cookies: You can control non-essential cookies through your browser settings. Most modern browsers allow you to refuse cookies, delete existing cookies, or set your browser to alert you when cookies are being set. Please note that disabling functional or analytics cookies may affect your experience on the gpanalo platform. Disabling strictly necessary cookies will prevent you from logging in or using the platform.

gpanalo does not use advertising cookies, retargeting pixels, or any tracking technology designed to build advertising profiles or track your activity across third-party websites.

gpanalo implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security framework includes:

• Transport Layer Security (TLS 1.3): All data transmitted between your device and gpanalo servers is encrypted in transit using current industry-standard TLS protocols.
• AES-256 Encryption at Rest: Sensitive personal data and financial information stored in gpanalo databases is encrypted at rest using AES-256 symmetric encryption.
• Password Hashing: Account passwords are stored exclusively as bcrypt-hashed values with a unique salt. Plain-text passwords are never stored or accessible to gpanalo staff.
• Two-Factor Authentication (2FA): gpanalo supports OTP-based two-factor authentication for account logins and withdrawal requests, adding an additional layer of account security for your Philippine mobile number.
• Access Controls: Access to personal data is restricted to gpanalo personnel who have a genuine operational need for that data, subject to role-based access controls and audit logging of all data access events.
• Regular Security Assessments: gpanalo conducts periodic vulnerability assessments and penetration testing of our platform infrastructure to identify and remediate security weaknesses before they can be exploited.
• Incident Response: gpanalo maintains a documented data breach incident response plan aligned with NPC Circular No. 16-03, ensuring rapid containment, investigation, and notification in the event of a security incident.

gpanalo retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, to maintain our service agreement with you, and to comply with our legal obligations under Philippine law. The table below summarizes our principal retention periods:

After the applicable retention period expires and where no other lawful basis for continued retention exists, gpanalo will securely delete or anonymize your personal data. Anonymized, aggregated data — which can no longer be attributed to any individual — may be retained indefinitely for statistical and analytical purposes.

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by gpanalo. To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request":

gpanalo will respond to all data subject rights requests within fifteen (15) business days of receipt. Where a request is complex or we receive a high volume of requests, we may extend this period by a further fifteen (15) business days, in which case we will notify you of the extension and the reason for it within the initial 15-day window.

The gpanalo platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law governing casino-style online gambling. gpanalo does not knowingly collect personal information from persons below 21 years of age.

During registration and KYC verification, gpanalo requires all players to confirm that they are aged 21 or above and to submit a valid government-issued ID that verifies their date of birth. Any account found to belong to a person below 21 years of age will be immediately suspended, all funds will be frozen pending investigation, and the account will be permanently closed in accordance with our Terms & Conditions.

If you believe that gpanalo has inadvertently collected personal data from a minor, please contact our Data Protection Officer immediately at [email protected]. Upon verification of such a report, gpanalo will promptly delete all personal data associated with the minor's account and report the matter to the appropriate regulatory authorities where required by law.

gpanalo's primary data processing infrastructure is oriented toward serving Filipino players in the Philippines. However, certain service providers and technology partners — including cloud infrastructure providers, identity verification services, and game content delivery networks — may process or store data in server locations outside the Philippines.

Where personal data is transferred outside the Philippines, gpanalo ensures that such transfers comply with Section 21 of RA 10173 and the NPC's rules on cross-border data flows. Specifically, gpanalo implements one or more of the following safeguards for each international transfer:

• Binding contractual clauses in our data processing agreements with overseas providers that impose data protection standards equivalent to those required under Philippine law;
• Transfer only to jurisdictions that have been assessed to provide an adequate level of data protection comparable to RA 10173 requirements;
• Where required, obtaining your consent to the specific cross-border transfer prior to processing.

gpanalo does not transfer your personal data to jurisdictions or entities that cannot provide appropriate data protection guarantees. A list of the categories of overseas recipients to whom data may be transferred is available upon request from our Data Protection Officer.

The gpanalo platform may contain references to third-party services such as payment providers, responsible gaming organizations, or regulatory bodies. If you navigate away from gpanalo.net to a third-party website or service, please be aware that gpanalo has no control over the content, privacy practices, or data handling of those external sites.

This Privacy Policy applies solely to personal data processed by gpanalo in connection with the gpanalo.net platform. gpanalo accepts no responsibility or liability for the privacy practices of any third-party sites or services you may access through links or references on our platform. We encourage you to read the privacy notices of any third-party services you use.

gpanalo reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. When material changes are made, we will notify registered players by email to the address associated with their gpanalo account and/or by a prominent notice on the platform upon next login.

Minor amendments — such as typographical corrections or clarifications that do not substantively alter your rights or gpanalo's data processing activities — may be made without prior notice, though the effective date at the top of this Policy will be updated accordingly.

Your continued use of the gpanalo platform after the updated Privacy Policy's effective date constitutes your acknowledgment of and agreement to the revised terms. If you do not agree with any amendments, you may request account closure in accordance with gpanalo's Terms & Conditions, and we will process any deletion or retention obligations applicable to your data in accordance with Section 9 of this Policy.

We recommend bookmarking this page and reviewing the Privacy Policy periodically. The most current version is always available at gpanalo.net/privacy-policy.

gpanalo has appointed a Data Protection Officer (DPO) as required under Section 21(d) of the Data Privacy Act of 2012. The DPO is responsible for overseeing gpanalo's compliance with RA 10173 and for handling data subject rights requests, privacy complaints, and data breach notifications.

Data Protection Officer — gpanalo
Email: [email protected]
Subject Line: "Data Privacy — [Nature of Request]"
Available: 24 hours a day, 7 days a week (Philippine Standard Time)

When contacting the DPO, please include your registered gpanalo username, the email address associated with your account, a clear description of your request or concern, and any relevant supporting documentation. This will allow us to locate your account and process your request efficiently.

If you are not satisfied with gpanalo's response to your data privacy request or complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing RA 10173. The NPC accepts complaints at its office in Pasay City, Metro Manila, and through its online complaints portal.