1. About This Privacy Policy
This Privacy Policy applies to all personal data collected, processed, and stored by the operator of panako.club (referred to in this document as "panako", "we", "us", or "the Company") in connection with the operation of the panako online gaming platform and any related services.
This Policy is issued in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, the regulations of the National Privacy Commission (NPC), and the data governance requirements of PAGCOR.
By registering a panako Account, using the panako Service, or continuing to browse the panako platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, you should not use the Service.
This Privacy Policy is to be read alongside the panako Terms and Conditions, which are available at panako.club/terms-conditions.
2. Personal Data We Collect
panako collects the following categories of personal data, depending on how you interact with the platform:
Identity & Contact Data
- Full legal name as it appears on your government-issued identification;
- Date of birth (to verify the 21+ age requirement);
- Philippine mobile number (used as your primary account identifier and for OTP verification);
- Email address, where provided;
- Residential address in the Philippines.
Verification & KYC Data
- Copies or photographs of government-issued identification documents (e.g., PhilSys national ID, passport, UMID, driver's licence, or voter's ID);
- Proof of address documentation where required;
- Selfie or liveness verification images collected during identity confirmation;
- Source of funds documentation where required by AMLA compliance procedures.
Financial Data
- GCash mobile number and transaction reference numbers;
- PayMaya account details as provided for withdrawal;
- Bank account details (BPI, BDO, Metrobank) for bank transfer withdrawals;
- Cryptocurrency wallet addresses used for USDT or BTC transactions;
- Transaction history including deposits, withdrawals, and in-platform transfers.
Gaming & Platform Activity Data
- Game session logs including wagers placed, outcomes, and session duration;
- Betting patterns and game preferences used for responsible gaming monitoring;
- Promotional offer eligibility and bonus usage history;
- Customer support interaction records including live chat transcripts and email correspondence.
Technical & Device Data
- IP address at the time of each session;
- Device type, operating system, and browser version;
- Approximate geolocation data derived from IP address (not GPS-level tracking);
- Session timestamps, page views, and navigation paths within the panako platform.
3. How We Collect Your Data
panako collects personal data through the following means:
- Direct submission: Information you provide when registering your panako Account, completing KYC verification, making a deposit or withdrawal request, or contacting customer support;
- Automated platform tracking: Technical and device data collected automatically when you access or interact with the panako platform, including through cookies and server logs (see Section 7);
- Payment providers: Transaction confirmation data shared by GCash, PayMaya, and bank partners in the course of processing your deposits and withdrawals;
- Third-party identity verification services: Where panako uses a licensed KYC provider to assist with document verification, that provider may share verification results and associated data with us;
- Regulatory bodies: In certain circumstances, panako may receive data from PAGCOR or other government authorities in the course of regulatory compliance obligations.
4. How and Why We Use Your Data
panako uses your personal data for the following specific purposes:
- Account creation and management: To create and maintain your panako Account, verify your identity, and provide you with access to the Service;
- Age verification: To confirm that you are at least 21 years of age as required by Philippine gaming law and PAGCOR regulations;
- Payment processing: To process deposits, withdrawals, and internal transfers through GCash, PayMaya, and banking partners;
- Regulatory compliance: To meet our obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012, including transaction monitoring and suspicious activity reporting;
- Responsible gaming: To monitor gaming patterns and identify potential problem gambling behaviour, and to administer deposit limits, cooling-off periods, and self-exclusion requests;
- Fraud prevention and security: To detect and prevent unauthorised access, fraud, money laundering, and other abuse of the panako platform;
- Customer support: To respond to your enquiries, process complaints, and resolve disputes;
- Service improvement: To analyse platform usage patterns and improve the panako gaming experience, subject to data being anonymised or pseudonymised where possible;
- Marketing communications: To send you promotional offers, new game announcements, and relevant updates — only where you have provided consent to receive such communications.
5. Legal Basis for Processing
panako processes your personal data on the following legal bases as recognised under the Philippine Data Privacy Act and its Implementing Rules:
- Contractual necessity: Processing required to perform the panako Terms and Conditions agreement, including Account management, game provision, and payment processing;
- Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, NPC requirements, and other applicable Philippine law;
- Legitimate interests: Processing for fraud prevention, platform security, and service improvement where such interests are not overridden by your data protection rights;
- Consent: Processing for marketing communications, where you have provided explicit opt-in consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.
6. Sharing Your Personal Data
panako does not sell your personal data to third parties. We share personal data only in the following circumstances and only to the extent necessary:
- Payment partners: GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency processors receive the transaction data required to execute your deposit and withdrawal requests;
- KYC and identity verification providers: Licensed third-party providers who assist with document authentication and liveness verification. These providers are bound by data processing agreements and may not use your data for any purpose other than the verification service;
- PAGCOR and government authorities: panako is obligated to report certain player transaction data and suspicious activity to PAGCOR and, where required, to the Anti-Money Laundering Council (AMLC) and other competent authorities under Philippine law;
- Game software providers: Game studios and live casino operators whose titles are hosted on panako may receive anonymised session identifiers necessary to run their games. They do not receive your full identity or financial data;
- Professional advisers: Legal counsel, auditors, and compliance consultants who are bound by professional confidentiality obligations and contractual data protection commitments;
- Business transfers: In the event of a merger, acquisition, or sale of all or part of the panako business, player data may be transferred to the acquiring entity subject to the same or equivalent data protection standards.
All third-party data processors engaged by panako are required to maintain data protection standards consistent with the Philippine Data Privacy Act and the principles of this Policy.
7. Cookies & Tracking Technologies
panako uses cookies and similar tracking technologies on the panako.club platform to improve functionality, maintain sessions, and understand how players interact with the site. The following categories of cookies are in use:
- Essential cookies: Required for the platform to function. These include session authentication cookies that keep you logged in to your panako Account during an active session. Disabling these cookies will prevent you from using the Service.
- Functional cookies: Store your preferences such as language settings, display preferences, and recently played games. These improve your experience but are not required for the Service to operate.
- Analytics cookies: Collect anonymised data about how players navigate the platform — which pages are visited, how long sessions last, and which features are used most. This data is used only to improve panako's platform design and is not linked to individual identity.
panako does not use third-party advertising cookies or share browsing data with advertising networks. You may manage cookie preferences through your browser settings. Blocking essential cookies will affect your ability to log in to and use the panako Service.
8. Data Retention
panako retains personal data for the following periods, unless a longer retention period is required by law:
- Active Account data: Retained for the duration of your panako Account plus five (5) years after Account closure, in compliance with PAGCOR and AMLA record-keeping requirements;
- KYC verification documents: Retained for five (5) years from the date of last transaction or Account closure, whichever is later, as required by AMLA;
- Transaction records: Retained for five (5) years from the date of each transaction;
- Customer support records: Retained for three (3) years from the date of the last interaction;
- Marketing consent records: Retained for three (3) years from the date consent was given or withdrawn;
- Technical logs: Retained for twelve (12) months from the date of generation, after which they are deleted or anonymised.
After the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where data cannot be immediately deleted due to technical constraints, it is restricted from active use pending deletion.
9. Data Security
panako implements appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, disclosure, alteration, or destruction. Key security measures include:
- TLS encryption for all data transmitted between your device and panako servers;
- Encryption at rest for sensitive personal and financial data stored in panako databases;
- Role-based access controls limiting employee access to personal data on a need-to-know basis;
- Multi-factor authentication for panako personnel accessing administrative systems;
- Regular security assessments and penetration testing conducted by qualified third-party security firms;
- Incident response procedures compliant with NPC breach notification requirements — in the event of a data breach affecting your rights, panako will notify affected players and the NPC within the timeframes required by law.
No data transmission over the internet can be guaranteed to be 100% secure. While panako takes all reasonable steps to protect your data, you are encouraged to maintain strong, unique credentials for your panako Account and to notify us immediately if you suspect any security compromise.
10. Your Data Rights
Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by panako:
- Right to be Informed: The right to know that your data is being collected and processed, which this Policy fulfils;
- Right of Access: The right to request a copy of the personal data panako holds about you. panako will respond to access requests within 15 business days;
- Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update basic account details directly through your panako Account dashboard;
- Right to Erasure: The right to request deletion of your personal data where panako has no overriding legal obligation to retain it. Note that regulatory retention obligations under AMLA and PAGCOR requirements may prevent immediate deletion of certain data categories;
- Right to Data Portability: The right to receive a copy of your personal data in a structured, machine-readable format where technically feasible;
- Right to Object: The right to object to processing based on legitimate interests, including processing for direct marketing purposes. Objections to marketing will be honoured immediately;
- Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request" and your registered mobile number for identity verification. panako will respond within 15 business days of receiving a verified request.
11. Children and Minors
The panako Service is strictly intended for individuals who are 21 years of age or older, in compliance with Philippine gaming law. panako does not knowingly collect personal data from individuals under the age of 21.
Age verification is conducted as part of the registration and KYC process. Where panako discovers that an Account was registered by or on behalf of a person under 21 years of age, the Account will be immediately and permanently closed, all associated personal data will be deleted to the extent not required for regulatory reporting, and any funds will be returned to the source deposit method.
If you believe that panako has inadvertently collected data from a minor, please contact [email protected] immediately so that the appropriate action can be taken.
12. Changes to This Privacy Policy
panako may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or the features of the panako Service. Material changes — meaning changes that affect how your data is collected, used, or shared in a way that is less protective or significantly different from the current Policy — will be communicated to you via your registered mobile number or through a prominent notice on the panako platform at least seven (7) days before the revised Policy takes effect.
Non-material updates (such as editorial corrections or clarifications that do not affect your rights) may be made without prior notice, with the "Last Updated" date at the top of this page revised accordingly.
Your continued use of the panako Service after the effective date of any Policy revision constitutes your acceptance of the updated Privacy Policy. If you do not agree with the revised Policy, you should close your Account by contacting panako support.
13. Contact & Complaints
For questions, data rights requests, or complaints regarding how panako handles your personal data, please contact our Data Protection Officer at:
- Email: [email protected] (subject line: "Privacy Enquiry" or "Data Rights Request")
- Response time: panako aims to acknowledge all privacy enquiries within two (2) business days and to provide a substantive response within fifteen (15) business days
If you are not satisfied with panako's response to a privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information on how to file a complaint with the NPC is available on the NPC's official government website.