oklaro Privacy Policy

1. Introduction

oklaro ("oklaro," "we," "us," or "our") operates the online gaming platform accessible at oklaro.asia ("Platform"). We are committed to protecting the privacy and personal data of all users ("Player," "User," or "you") who access or use the oklaro Platform.

This Privacy Policy describes how oklaro collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform. It also explains your rights under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and how you may exercise those rights.

By registering an oklaro account or using any part of the Platform, 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. If you do not agree with this Privacy Policy, please do not use the oklaro Platform.

2. Information We Collect

2.1 Information You Provide Directly

When you register for an oklaro account or use our services, we collect information that you provide directly to us, including:

• Full legal name and date of birth;
• Philippine mobile number and email address;
• Government-issued identification documents (for identity and age verification);
• Payment information, including GCash or PayMaya account details and bank account information for withdrawals;
• Correspondence and communications you send to oklaro support;
• Responses to surveys, promotions, or feedback requests.

2.2 Information Collected Automatically

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

• IP address and approximate geographic location;
• Device type, operating system, and browser information;
• Pages visited, features used, and time spent on the Platform;
• Game history, wagering activity, and transaction records;
• Session logs and error reports;
• Cookie identifiers and similar tracking data (see Section 8).

2.3 Information from Third Parties

oklaro may receive information about you from third-party identity verification providers, payment processors, and fraud prevention services in connection with our compliance and security obligations.

3. How We Use Your Information

oklaro uses the personal information we collect for the following purposes:

• Account management: To create, verify, and maintain your oklaro account;
• Identity and age verification: To confirm that you are at least 21 years of age and are who you say you are, as required by PAGCOR regulations;
• Service delivery: To process deposits, withdrawals, and gameplay, and to provide customer support;
• Legal compliance: To comply with anti-money laundering (AML) obligations, PAGCOR reporting requirements, and other applicable Philippine laws;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, and unauthorized access;
• Responsible gaming: To monitor gaming behavior and enforce responsible gaming tools such as deposit limits and self-exclusion;
• Communications: To send you account notifications, transaction confirmations, and — where you have opted in — promotional offers and updates;
• Platform improvement: To analyze usage patterns and improve the oklaro Platform's features, performance, and user experience.

4. Legal Basis for Processing

oklaro processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform our contract with you (i.e., to operate your oklaro account and provide gaming services);
• Legal obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations and AML obligations;
• Legitimate interests: Processing is necessary for oklaro's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights;
• Consent: For certain processing activities, such as sending promotional communications, we rely on your explicit consent, which you may withdraw at any time.

5. Sharing of Personal Information

oklaro does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal information with the following categories of recipients, strictly as necessary:

• Payment processors: GCash, PayMaya, and partner banks, to process your deposits and withdrawals;
• Identity verification providers: Third-party KYC (Know Your Customer) service providers engaged to verify your identity and age;
• Regulatory authorities: PAGCOR and other Philippine government agencies, where required by law or regulation;
• Fraud prevention services: Third-party providers engaged to detect and prevent fraud, money laundering, and other illegal activity;
• Technology and hosting providers: Cloud infrastructure and software providers who process data on our behalf under strict data processing agreements;
• Professional advisers: Lawyers, auditors, and other professional advisers, where necessary for legal or compliance purposes.

All third parties with whom oklaro shares personal data are required to handle such data in accordance with applicable privacy laws and oklaro's data protection standards.

6. Data Retention

oklaro retains your personal data for as long as your account is active and for a period thereafter as required by applicable law. Specifically:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AML requirements;
• Identity verification documents are retained for the period required by applicable KYC regulations;
• Communications and support records are retained for three (3) years;
• Technical logs and usage data are retained for up to twelve (12) months.

After the applicable retention period, your personal data will be securely deleted or anonymized.

7. Data Security

oklaro implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the oklaro Platform;
• Encryption of sensitive data at rest, including payment information and identity documents;
• Access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing;
• Incident response procedures for detecting and responding to data breaches.

While oklaro takes data security seriously, no system is completely immune to security risks. In the event of a data breach that is likely to result in a risk to your rights and freedoms, oklaro will notify you and the National Privacy Commission (NPC) as required by the DPA.

8. Cookies and Tracking Technologies

oklaro uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use include:

• Essential cookies: Necessary for the Platform to function, including session management and security features. These cannot be disabled.
• Performance cookies: Used to analyze how players use the Platform, helping us identify and fix issues and improve performance.
• Functional cookies: Used to remember your preferences, such as language settings and game history.
• Analytics cookies: Used to collect aggregated, anonymized data about Platform usage patterns.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the oklaro Platform.

9. Your Rights as a Data Subject

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

• Right to be informed: The right to know how your personal data is being collected and processed;
• Right of access: The right to request a copy of the personal data oklaro holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to oklaro's legal retention obligations;
• Right to object: The right to object to certain types of data processing, including direct marketing;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact oklaro's Data Protection Officer at the contact details provided in Section 12. oklaro will respond to your request within thirty (30) days.

10. Children's Privacy

The oklaro Platform is strictly intended for individuals who are at least twenty-one (21) years of age. oklaro does not knowingly collect personal data from individuals under 21 years of age. If oklaro becomes aware that personal data has been collected from an individual under 21, such data will be deleted immediately and the associated account will be suspended.

If you believe that oklaro may have inadvertently collected personal data from an underage individual, please contact us immediately at the details provided in Section 12.

11. Changes to This Privacy Policy

oklaro reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered players via email or in-platform notification at least seven (7) days before the changes take effect. The "Last Updated" date at the top of this policy will reflect the most recent revision.

Your continued use of the oklaro Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this policy periodically.

12. Contact and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or oklaro's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Support Email: [email protected]
• Live Chat: Available 24/7 via the oklaro Platform
• Response Time: Within 30 days for data subject requests; within 24 hours for general support inquiries

If you are not satisfied with oklaro's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.