glparty Privacy Policy

1 Introduction

glparty ("glparty," "we," "us," "our") is committed to protecting the privacy and personal data of all users of the glparty platform at glparty.org ("Platform"). This Privacy Policy ("Policy") describes how glparty collects, uses, stores, shares, and protects personal data in connection with your use of the Platform.

This Policy applies to all registered players, visitors, and any other individuals whose personal data is processed by glparty in connection with the Platform. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read together with glparty's Terms & Conditions and Responsible Gaming Policy, both of which are available on the Platform. In the event of any conflict between this Policy and the Terms & Conditions with respect to data privacy matters, this Policy shall prevail.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, glparty acts as the Personal Information Controller with respect to the personal data of its registered players and platform users.

As Personal Information Controller, glparty determines the purposes and means of processing personal data collected through the Platform. Where glparty engages third-party service providers to process personal data on its behalf, those providers act as Personal Information Processors and are bound by data processing agreements that require them to process data only in accordance with glparty's instructions and this Policy.

For all data privacy inquiries, requests, and complaints, you may contact glparty's designated Data Protection Officer at: [email protected]

3 Personal Data We Collect

glparty collects the following categories of personal data:

• Identity data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., SSS, PhilHealth, UMID, passport, or driver's license number).
• Contact data: Email address, mobile number, and residential address (including barangay, city/municipality, province, and postal code).
• Account data: Username, encrypted password, account preferences, security settings, and communication preferences.
• Financial data: Payment method details (e-wallet account numbers, bank account details, card details), transaction history, deposit and withdrawal records. Note: glparty does not store full card numbers — payment card data is handled by PCI-DSS compliant payment processors.
• Gaming data: Game history, wagering activity, session duration, win/loss records, bonus usage, and responsible gaming tool settings.
• Technical data: IP address, device type, operating system, browser type and version, time zone, and platform access logs.
• Usage data: Pages visited, features used, click-stream data, search queries within the Platform, and session recordings where applicable.
• Communications data: Records of your correspondence with glparty's customer support team, including live chat transcripts, emails, and support ticket history.
• Verification data: Copies of government-issued identification documents, proof of address, and proof of payment method submitted for KYC verification purposes.

Where you choose not to provide personal data that is required for a specific purpose (such as KYC verification), glparty may be unable to provide the relevant service or process the relevant transaction.

4 How We Collect Your Data

glparty collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing your profile, submitting KYC documents, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Data collected automatically when you access or use the Platform, including through cookies, web beacons, pixel tags, and similar tracking technologies. See Section 8 for more details on cookies.
• Third-party sources: Data received from payment processors, identity verification service providers, fraud prevention agencies, and publicly available sources, where permitted by applicable law.
• Responsible gaming tools: Data generated through your use of deposit limits, self-exclusion tools, and session time reminders, which is used to monitor and support responsible gaming behavior.

5 How We Use Your Personal Data

glparty uses your personal data for the following purposes:

• Account management: To register and maintain your glparty account, verify your identity, and manage your account preferences and security settings.
• Service delivery: To provide access to games, process deposits and withdrawals, credit bonuses, and deliver the full range of glparty platform services.
• KYC and AML compliance: To verify your identity and age (21+), conduct due diligence checks, and comply with Anti-Money Laundering obligations under Philippine law and PAGCOR regulations.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support channels.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other prohibited conduct as defined in the Terms & Conditions.
• Responsible gaming: To monitor gaming behavior, apply responsible gaming tools at your request, identify potentially problematic gambling patterns, and intervene where appropriate.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have opted in to receive such communications. You may opt out at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the functionality, content, and user experience of the glparty platform.
• Legal compliance: To comply with applicable Philippine laws, regulatory requirements, court orders, and lawful requests from government authorities including PAGCOR and the Anti-Money Laundering Council (AMLC).

6 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, glparty processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and glparty — including account registration, game access, payment processing, and customer support.
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC/AML obligations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for glparty's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided these interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing & Disclosure

glparty does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Visa, and other payment service providers, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers engaged to assist with identity verification and fraud prevention.
• Technology providers: Cloud hosting, data storage, analytics, and platform infrastructure providers who process data on glparty's behalf under data processing agreements.
• Game content providers: Third-party game studios and live dealer platform providers, to the extent necessary to deliver game services.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law, court order, or regulatory obligation.
• Professional advisors: Legal counsel, auditors, and other professional advisors, subject to applicable professional confidentiality obligations.

All third-party service providers engaged by glparty are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with glparty's instructions and applicable data protection law.

8 Cookies & Tracking Technologies

glparty uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings, display preferences, and responsible gaming tool configurations.
• Analytics cookies: Used to collect aggregated, anonymized data about how users interact with the Platform, helping glparty identify areas for improvement. These are only set with your consent.
• Marketing cookies: Used to deliver relevant promotional content within the Platform. These are only set with your explicit consent and can be withdrawn at any time via your cookie preferences.

You can manage your cookie preferences through your browser settings or through the cookie consent tool available on the Platform. Please note that disabling certain cookies may affect the functionality of the Platform.

9 Data Security

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

• 256-bit SSL/TLS encryption for all data in transit between your device and the glparty platform.
• Encryption of sensitive data at rest, including payment details and identity verification documents.
• Role-based access controls ensuring that only authorized glparty personnel can access personal data, and only to the extent required for their specific role.
• Regular security audits, vulnerability assessments, and penetration testing conducted by independent security specialists.
• Multi-factor authentication options for player accounts and mandatory multi-factor authentication for all glparty staff with access to personal data systems.
• Incident response procedures to detect, contain, and notify affected individuals and the National Privacy Commission of personal data breaches within the timeframes required by law.

While glparty takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying glparty immediately if you suspect unauthorized access to your account.

10 Data Retention

glparty retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with AML record-keeping obligations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer support records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing consent records: Retained for the duration of your consent plus three (3) years, to demonstrate compliance with consent requirements.
• Technical and usage data: Generally retained for up to twenty-four (24) months in identifiable form, after which it may be anonymized and retained for analytical purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with glparty's data disposal procedures.

11 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by glparty:

• Right to be informed: The right to be informed of how your personal data is being collected and processed — which is the primary purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data glparty holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You can update most account information directly through your account settings.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to glparty's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact glparty's Data Protection Officer at [email protected] with the subject line "Data Privacy Request – [Your Account Username]." glparty will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with the requirements of the Data Privacy Act.

12 Children's Privacy

The glparty platform is strictly intended for individuals aged 21 years and above. glparty does not knowingly collect personal data from individuals under the age of 21. Registration by minors is prohibited under Philippine law and glparty's Terms & Conditions.

If glparty becomes aware that personal data has been collected from an individual under the age of 21, it will take immediate steps to close the relevant account, delete the associated personal data, and — where applicable — return any deposited funds in accordance with applicable law.

If you believe that a minor has registered an account on glparty, please contact our support team immediately at [email protected].

13 International Data Transfers

glparty's primary operations and data processing activities are based in the Philippines. However, some of glparty's third-party service providers — including cloud infrastructure providers, game content providers, and analytics platforms — may process personal data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, glparty ensures that appropriate safeguards are in place to protect your data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law.
• Transfers only to jurisdictions that the National Privacy Commission has recognized as providing an adequate level of data protection.
• Implementation of additional technical and organizational safeguards where required by the nature of the transfer.

14 Updates to This Privacy Policy

glparty reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The most current version of this Policy will always be available on this page, with the "Last Updated" date revised accordingly.

For material changes — those that significantly affect your rights or the way glparty processes your personal data — glparty will provide advance notice via the email address registered to your account or via a prominent notice on the Platform, at least seven (7) days before the changes take effect.

Your continued use of the glparty platform after the effective date of any update constitutes your acknowledgment of the revised Policy. If you do not agree with the updated Policy, you should cease using the Platform and may request account closure in accordance with the Terms & Conditions.

15 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or glparty's data processing practices, please contact our Data Protection Officer. Our support team is available 24 hours a day, 7 days a week, and our Filipino agents are always ready to assist.

If you are not satisfied with glparty's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint is available on the NPC's official website.