laroph Casino – Privacy Policy

This Privacy Policy ("Policy") applies to the personal data processed by laroph ("laroph," "we," "us," or "our") in connection with your use of the laroph online gaming platform at laroph.club. By registering for or using a laroph account, you acknowledge that you have read and understood this Policy. This Policy should be read in conjunction with the laroph Terms and Conditions and Responsible Gaming Policy.

1. Introduction

laroph respects the privacy of every Filipino player and is committed to handling personal data responsibly, transparently, and in strict compliance with the Philippine Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). laroph also adheres to PAGCOR's data governance requirements applicable to licensed online gaming operators.

This Policy describes the types of personal information laroph collects when you interact with our platform, the purposes for which that information is processed, the parties with whom it may be shared, and the security measures in place to protect it. It also sets out your rights as a data subject and how you may exercise them.

2. Data Controller

laroph acts as the Data Controller for personal data collected through the laroph Platform. As Data Controller, laroph determines the purposes and means of processing your personal data in accordance with RA 10173. All data controller obligations — including registration with the NPC, maintaining a data processing inventory, and appointing a Data Protection Officer (DPO) — are fulfilled by laroph.

For all privacy-related inquiries, you may contact laroph's Data Protection Officer at: [email protected] (plain text — not a clickable link).

3. Data We Collect

laroph collects the following categories of personal data, limited to what is necessary for the purposes described in this Policy:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify you meet the 21+ age requirement under PAGCOR regulations)
• Philippine mobile number
• Email address
• Residential address
• Government-issued ID number and ID document images (for KYC verification)

3.2 Financial Data

• GCash or PayMaya account number linked to your laroph wallet
• Bank account details (BPI, BDO, Metrobank) used for deposits or withdrawals
• Transaction history, deposit amounts, withdrawal requests, and wallet balance records

3.3 Technical & Usage Data

• IP address and approximate geolocation at the time of login
• Device type, browser, and operating system information
• Session duration, game history, betting activity, and platform interaction logs
• Login timestamps and session identifiers

3.4 Communications Data

• Records of correspondence between you and laroph support, including live chat transcripts and email exchanges
• Records of voluntary feedback, survey responses, or complaint submissions

4. How We Collect Data

laroph collects personal data through the following means:

• Direct interactions: Information you provide when creating a laroph account, completing KYC verification, making deposits or withdrawals, or contacting support.
• Automated technologies: Technical and usage data collected automatically when you access and interact with the laroph Platform, including through cookies, server logs, and session tracking tools.
• Third-party verification: Identity and address data confirmed through PAGCOR-approved KYC verification partners and payment processors including GCash and PayMaya.

5. Purpose of Processing

laroph processes your personal data for the following specific, legitimate purposes:

• Account creation and management: To register your laroph account, verify your identity, and maintain accurate account records.
• Age and eligibility verification: To confirm that you are at least 21 years of age and eligible to use the laroph Platform under PAGCOR requirements.
• Payment processing: To process deposits, withdrawals, and refunds through your registered payment methods.
• Regulatory compliance: To fulfil laroph's obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and RA 10173.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account compromise, and platform abuse.
• Customer support: To respond to your inquiries, resolve complaints, and provide technical assistance.
• Responsible gaming: To monitor gaming behaviour and provide responsible gaming interventions — including deposit limit enforcement, self-exclusion activation, and cooling-off periods — where warranted.
• Platform improvement: To analyse aggregated usage patterns and improve the performance, features, and user experience of the laroph Platform.
• Direct communications: To send you transactional notifications (deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about laroph offers and games.

6. Legal Basis for Processing

Under RA 10173, laroph processes personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and laroph (i.e., provision of the gaming platform and associated services).
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, NPC requirements, and other applicable Philippine laws.
• Legitimate interests: Processing necessary for laroph's legitimate interests in fraud prevention, platform security, and service improvement, where those interests are not overridden by your rights and interests.
• Consent: Processing for optional purposes (such as promotional communications) where you have given explicit, freely given, and informed consent. You may withdraw consent at any time by contacting laroph support.

7. Data Sharing

laroph does not sell your personal data to third parties. laroph may share your personal data in the following limited circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank — solely for the purpose of processing your financial transactions.
• KYC and identity verification partners: Third-party identity verification services approved by laroph and compliant with RA 10173 and PAGCOR requirements.
• Game providers and technology vendors: Software providers who supply game content or platform infrastructure under strict data processing agreements that prohibit independent use of your data.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the NPC, and other Philippine government authorities, where disclosure is required by law or regulatory order.
• Professional advisers: Lawyers, auditors, and accountants engaged by laroph under obligations of confidentiality, where necessary for business operations or legal proceedings.

All third parties with whom laroph shares personal data are required to maintain appropriate technical and organisational security measures and are prohibited from processing your data for any purpose other than those specified by laroph.

8. International Data Transfers

Where laroph engages technology vendors or game providers whose infrastructure is hosted outside the Philippines, laroph ensures that any transfer of personal data is subject to appropriate safeguards consistent with RA 10173, including contractual clauses requiring the recipient to maintain equivalent data protection standards. laroph will not transfer your personal data to jurisdictions that do not provide adequate levels of data protection without your explicit consent or without implementing appropriate safeguards.

9. Data Retention

laroph retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for compliance with legal, regulatory, accounting, and reporting obligations. In practice:

• Account and identity data is retained for a minimum of five (5) years after account closure, as required under Philippine AMLA regulations.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Technical and usage logs are retained for twelve (12) months, after which they are deleted or anonymised.

Upon expiry of the applicable retention period, laroph will securely delete or anonymise your personal data so that it can no longer be associated with you.

10. Security Measures

laroph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the laroph Platform
• Encrypted storage of sensitive personal and financial data at rest
• Role-based access controls that restrict internal access to personal data to authorised personnel on a strict need-to-know basis
• Regular security audits, penetration testing, and vulnerability assessments
• Multi-factor authentication requirements for all internal administrative access to player data systems
• Incident response procedures compliant with NPC breach notification requirements

In the event of a personal data breach that may adversely affect you, laroph will notify the NPC and affected players within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

11. Cookies and Tracking Technologies

laroph uses cookies and similar technologies on the laroph Platform for the following purposes:

• Essential cookies: Required for session authentication, security, and basic platform functionality. These cannot be disabled without impairing platform performance.
• Analytics cookies: Anonymised data used to understand aggregate platform usage patterns and improve features. laroph does not use third-party advertising trackers.
• Preference cookies: Used to remember your platform settings and preferences between sessions.

You may control cookie settings through your browser's privacy settings. Disabling essential cookies may affect your ability to log in and use the laroph Platform normally. laroph does not use cross-site tracking technologies or sell cookie data to advertisers.

12. Your Data Subject Rights

Under RA 10173, you have the following rights with respect to your personal data held by laroph:

• Right to be Informed: The right to know what personal data laroph holds about you and how it is being processed — as set out in this Policy.
• Right to Access: The right to request a copy of the personal data laroph holds about you.
• Right to Correction: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.
• Right to Object: The right to object to processing of your personal data based on legitimate interests, including for direct marketing purposes.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Damages: The right to seek compensation for damages sustained due to inaccurate, incomplete, outdated, or unlawfully obtained personal data.

To exercise any of the above rights, please submit a written request to laroph's Data Protection Officer at [email protected]. laroph will respond to verified data subject requests within fifteen (15) business days. laroph may request proof of identity before fulfilling a data access or erasure request.

13. Children's Privacy

The laroph Platform is strictly for persons aged 21 years and above. laroph does not knowingly collect personal data from individuals under the age of 21. If laroph discovers that personal data has been collected from a person under the minimum age, that account will be immediately suspended and the data will be securely deleted. If you believe that a minor has registered on the laroph Platform, please notify laroph support immediately.

14. Changes to This Policy

laroph reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, platform features, or applicable legal requirements. Material changes will be communicated to registered Players via the email address on file at least seven (7) days before the updated Policy takes effect. The "Last Updated" date at the top of this page will reflect the date of the most recent revision. Your continued use of the laroph Platform after the effective date of any revision constitutes acceptance of the updated Policy.

15. Contact & Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or laroph's data practices, please contact laroph's designated Data Protection Officer:

Email (plain text): [email protected]

laroph's DPO is available Monday through Sunday, including Philippine public holidays. All privacy complaints will be acknowledged within three (3) business days and resolved within thirty (30) business days. If you are not satisfied with laroph's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.