Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how oklaro ("oklaro," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "your," or "Player") who access or use the oklaro online gaming platform, including the website at oklaro.one and any associated mobile applications (collectively, the "Platform").

Oklaro is committed to handling your personal data with transparency, integrity, and respect. We understand that Filipino players entrust us with sensitive information when they register and play on our platform, and we take that responsibility seriously. This Policy is designed to give you a clear and honest picture of our data practices so you can make informed decisions about your use of oklaro.

This Policy should be read alongside oklaro's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. By accessing the Platform or creating an account, you acknowledge that you have read and understood this Policy.

02 Data Controller

For the purposes of applicable data protection legislation, oklaro is the data controller in respect of the personal data collected through the Platform. As data controller, oklaro determines the purposes and means by which your personal data is processed.

If you have any questions about how oklaro processes your personal data, or if you wish to exercise any of your data rights as described in Section 11 of this Policy, you may contact our Data Privacy Officer using the contact details provided in Section 14.

03 Data We Collect

Oklaro collects the following categories of personal data in connection with your use of the Platform:

Oklaro does not intentionally collect special categories of sensitive personal data (such as health data, racial or ethnic origin, or political opinions) unless specifically required by law or regulation and with your explicit consent where applicable.

04 How We Collect Your Data

Oklaro collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and similar tracking technologies. See Section 8 for more detail on cookies.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment data from payment processors such as GCash, PayMaya, BDO, BPI, and Metrobank.
• Publicly available sources: In limited circumstances, oklaro may supplement your profile with information from publicly available sources for the purposes of fraud prevention or regulatory compliance.

05 How We Use Your Data

Oklaro uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and administer your oklaro player account, including processing your registration and verifying your identity.
• Platform operation: To provide you with access to games, process wagers, calculate and credit winnings, and deliver the core services of the oklaro Platform.
• Financial transactions: To process deposits and withdrawals via your chosen payment method, and to maintain accurate financial records.
• Regulatory compliance: To fulfil our obligations under applicable gaming regulations, anti-money laundering (AML) laws, and know-your-customer (KYC) requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other security threats to the Platform.
• Responsible gaming: To monitor gaming patterns and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications or where we have a legitimate interest in doing so. You may opt out at any time.
• Platform improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the oklaro Platform.
• Legal obligations: To comply with court orders, regulatory requests, and other legal obligations applicable to oklaro's operations in the Philippines.

06 Legal Basis for Processing

Oklaro processes your personal data on the following legal bases:

• Contractual necessity: Processing that is necessary to perform the contract between you and oklaro — that is, to provide you with the gaming services you have registered for. This includes account management, transaction processing, and game operation.
• Legal obligation: Processing that is required to comply with applicable laws and regulations, including AML obligations, KYC requirements, and gaming regulatory requirements.
• Legitimate interests: Processing carried out for oklaro's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and general platform improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of direct marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Data Sharing & Disclosure

Oklaro does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BDO, BPI, Metrobank, and other payment service providers, for the purpose of processing your financial transactions.
• Identity verification providers: Third-party KYC and AML service providers who assist oklaro in verifying your identity and screening for financial crime risks.
• Technology and infrastructure providers: Cloud hosting, data storage, and platform technology providers who process data on oklaro's behalf under strict data processing agreements.
• Game content providers: Game software providers whose titles are available on the oklaro Platform, to the extent necessary for game operation and audit purposes.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory direction, oklaro may disclose your personal data to government agencies, gaming regulators, or law enforcement bodies.
• Professional advisers: Legal, accounting, and auditing professionals who are bound by professional confidentiality obligations.

Any third party that receives your personal data from oklaro is required to handle it in accordance with applicable data protection laws and is prohibited from using it for any purpose other than that for which it was shared.

08 Cookies & Tracking Technologies

Oklaro uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session security, and gather analytics data. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. These cookies cannot be disabled without affecting core Platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the Platform, including pages visited and features used. This data helps oklaro improve the Platform over time.
• Marketing cookies: Used to deliver relevant promotional content and to measure the effectiveness of oklaro's marketing campaigns. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the oklaro Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the service.

09 Data Retention

Oklaro retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with applicable AML and gaming regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations.
• KYC and identity documents: Retained for the period required by applicable AML legislation, typically five (5) years from the end of the business relationship.
• Customer support records: Retained for up to three (3) years from the date of the interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing consent records: Retained for as long as you remain subscribed to marketing communications, plus a reasonable period thereafter to demonstrate compliance.

When personal data is no longer required, oklaro will securely delete or anonymise it in accordance with our internal data disposal procedures.

10 Data Security

Oklaro implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the oklaro Platform.
• Encryption of sensitive data fields at rest, including payment information and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with applicable legal requirements.

While oklaro takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You also play an important role in keeping your data safe — please ensure your oklaro account password is strong and unique, and never share your login credentials with anyone.

11 Your Data Rights

Subject to applicable data protection laws, you have the following rights in relation to the personal data oklaro holds about you:

• Right of access: You have the right to request a copy of the personal data oklaro holds about you, along with information about how it is being used.
• Right to rectification: You have the right to request that oklaro correct any inaccurate or incomplete personal data held about you.
• Right to erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to oklaro's legal and regulatory retention obligations.
• Right to restriction of processing: You have the right to request that oklaro restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data.
• Right to data portability: Where processing is based on your consent or on a contract, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object: You have the right to object to the processing of your personal data where oklaro relies on legitimate interests as the legal basis, and to opt out of direct marketing communications at any time.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact oklaro's Data Privacy Officer using the details in Section 14. Oklaro will respond to all valid requests within 30 days. In some cases, we may need to verify your identity before processing your request.

12 Children's Privacy

The oklaro Platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gaming regulations. Oklaro does not knowingly collect personal data from individuals under the age of 21.

If oklaro becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage user will be returned to the source payment method after deducting any applicable processing fees.

If you believe that a minor has registered an account on oklaro or that oklaro has inadvertently collected personal data from a minor, please contact us immediately using the details in Section 14.

13 Changes to This Policy

Oklaro reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, oklaro will notify registered players by email or by displaying a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how oklaro protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgement of the revised Policy.

If you do not agree with any changes to this Policy, you should cease using the Platform and may request the closure of your account in accordance with oklaro's Terms & Conditions.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or oklaro's handling of your personal data, please contact our Data Privacy Officer. All data-related enquiries are treated as a priority and handled with strict confidentiality.

For responsible gaming concerns, including self-exclusion requests, please visit our Responsible Gaming page or contact support directly. For general account queries, our 24/7 live support team is available through the chat feature within your oklaro account dashboard.