funnalo Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") describes how funnalo ("funnalo," "we," "us," or "our") collects, uses, stores, and discloses personal information obtained from individuals ("you," "Player," or "User") who access or use the funnalo website at funnalo.net and all associated gaming services, features, promotions, and customer support channels.

This Policy applies to all personal data processed by funnalo in connection with the operation of the funnalo platform. It is intended to comply with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

By accessing funnalo, registering an account, or interacting with any funnalo service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the funnalo platform immediately.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, funnalo acts as the Personal Information Controller (PIC) with respect to all personal data collected through the funnalo platform. This means funnalo determines the purpose and means by which your personal information is processed.

Where funnalo engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and fraud detection partners — those third parties act as Personal Information Processors (PIP) and are bound by data processing agreements that require them to maintain standards of data protection consistent with this Policy and applicable Philippine law.

3. Information We Collect

3.1 Information You Provide Directly

When you register an account, complete verification, access support, or interact with funnalo services, we may collect the following categories of personal information:

• Identity Data: Full legal name, date of birth, gender, and a government-issued ID number (e.g., Philippine National ID, Passport, SSS/GSIS number, Driver's License number) provided during KYC verification.
• Contact Data: Philippine mobile number, residential address (including barangay, city/municipality, and province), and email address.
• Account Data: Username, password (stored in hashed form), account preferences, and communication settings.
• Financial Data: GCash account number, PayMaya account details, BPI, BDO, Metrobank, or UnionBank account information used for deposits and withdrawals. funnalo does not store full bank account credentials; payment data is tokenized and handled by regulated payment processors.
• Identity Verification Documents: Scanned or photographed copies of government-issued IDs submitted for KYC purposes, selfie photographs, and proof of address documents.
• Communications Data: Records of your correspondence with funnalo's customer support team via live chat, email, or any other channel.

3.2 Information Collected Automatically

When you use the funnalo platform, certain technical and behavioral data is collected automatically:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and mobile network information.
• Usage Data: Pages visited, time spent on each page, game sessions played, bets placed, wager amounts, game outcomes, and login/logout timestamps.
• Location Data: Approximate geographic location derived from your IP address to verify access eligibility. funnalo does not collect precise GPS coordinates from mobile devices.
• Cookie & Tracking Data: Information collected via cookies, pixel tags, and similar technologies as described in Section 8 of this Policy.

4. How We Collect Your Data

funnalo collects personal data through the following means:

• Direct Submission: When you fill in a registration form, complete KYC verification, make a deposit or withdrawal request, contact customer support, or participate in a promotion.
• Automated Technologies: Via cookies, web beacons, server logs, and similar tracking technologies embedded in the funnalo platform during your use of the site.
• Third-Party Sources: From identity verification bureaus, fraud detection providers, and payment processors who may share supplementary data to validate your identity or flag suspicious transactions. Where permitted by law, funnalo may also receive data from publicly available sources such as sanctions screening databases and government registries in the Philippines.

5. How We Use Your Data

funnalo processes your personal data for the following specific, declared purposes:

• Account Registration & Management: To create, maintain, and administer your funnalo player account, including verifying your identity, managing your preferences, and communicating account-related notices.
• Know Your Customer (KYC) Compliance: To verify your identity and age (21+) in accordance with PAGCOR requirements and applicable Philippine anti-money laundering laws, including Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments.
• Transaction Processing: To process deposits, withdrawals, and bonus credits in Philippine Peso via GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank.
• Game Service Delivery: To provide access to funnalo's casino games, live dealer tables, bingo rooms, slot titles, and sports betting markets, and to maintain accurate records of all gaming activity.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, duplicate accounts, bonus abuse, money laundering, and other prohibited conduct outlined in the funnalo Terms & Conditions.
• Responsible Gaming: To monitor gaming patterns, enforce deposit and session limits you have set, administer self-exclusion requests, and identify players who may be at risk of problem gambling.
• Customer Support: To respond to your inquiries, complaints, and dispute submissions, and to maintain records of those interactions for quality assurance purposes.
• Marketing Communications: To send you promotional offers, bonus notifications, and funnalo news via email or SMS — but only where you have provided explicit consent to receive such communications. You may withdraw this consent at any time.
• Legal & Regulatory Compliance: To comply with our obligations under Philippine law, respond to lawful requests from government authorities, and maintain records required by PAGCOR or other regulatory bodies.
• Platform Improvement: To analyse aggregated usage data for the purpose of improving funnalo's features, game selection, and user experience. This analysis is conducted on de-identified or pseudonymised data wherever possible.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, funnalo processes your personal data on the following legal grounds:

• Consent: Where you have given clear, informed, and freely given consent — for example, for marketing communications or the use of non-essential cookies.
• Contractual Necessity: Where processing is necessary to perform the contract between you and funnalo — specifically, to operate your gaming account and deliver the services you have requested.
• Legal Obligation: Where funnalo is required to process data to comply with a legal or regulatory obligation, including KYC, AML screening, and reporting requirements under Philippine law.
• Legitimate Interests: Where processing is necessary for funnalo's legitimate business interests — such as fraud prevention, platform security, and service improvement — provided those interests are not overridden by your data protection rights.

7. Sharing Your Data

funnalo does not sell, rent, or trade your personal information to unaffiliated third parties for their own marketing purposes. We may share your data only in the following circumstances:

• Service Providers: With regulated third-party processors who assist funnalo in delivering its services — including identity verification partners, payment processors (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank), fraud detection vendors, cloud hosting providers, and customer support platform operators. All such processors are contractually bound to use your data solely for the purposes specified by funnalo.
• Regulatory & Law Enforcement Authorities: With PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Philippine National Police (PNP), or any other government authority, where disclosure is required by law, court order, or regulatory directive.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of funnalo's assets, your personal data may be transferred to the successor entity, subject to equivalent data protection obligations.
• With Your Consent: In any other circumstance where you have provided explicit prior consent to the specific disclosure.

Where data is shared with overseas processors, funnalo ensures that appropriate safeguards are in place and that such transfers comply with the cross-border data transfer requirements of the Data Privacy Act of 2012.

8. Cookies & Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. funnalo uses cookies and similar technologies (including web beacons, session tokens, and local storage) to operate the platform, personalise your experience, and gather usage analytics.

8.2 Types of Cookies We Use

8.3 Managing Cookies

Strictly necessary cookies cannot be disabled as they are essential for platform operation. You may manage functional, analytics, and marketing cookies through the funnalo cookie preference centre, accessible from the footer of the platform. You may also configure your browser to block or delete cookies; however, doing so may impair certain funnalo features, including the ability to stay logged in across sessions.

9. Data Retention

funnalo retains personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law. The following retention periods apply:

• Active Account Data: Retained for the duration of your account relationship with funnalo.
• KYC & Identity Documents: Retained for a minimum of five (5) years following account closure, in compliance with AMLC record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years following the date of the transaction, consistent with Philippine financial record-keeping obligations.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, or longer if the interaction is subject to an ongoing dispute or legal proceeding.
• Marketing Consent Records: Retained for three (3) years from the date consent was given or withdrawn.
• Technical & Analytics Data: Retained in aggregated, anonymised form for up to two (2) years.

When the applicable retention period expires and no legal or regulatory obligation requires continued retention, funnalo will securely delete or anonymise your personal data.

10. Data Security

funnalo implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and funnalo's servers.
• AES-256 encryption at rest for all sensitive personal and financial data stored in funnalo's database systems.
• Password hashing using industry-standard algorithms (bcrypt with salt). funnalo never stores plaintext passwords.
• SMS OTP two-factor authentication (2FA) available for all player accounts — strongly recommended for all users.
• Role-based access controls ensuring that only authorised funnalo personnel can access personal data on a strict need-to-know basis.
• Regular penetration testing and vulnerability assessments conducted by independent security firms.
• 24/7 automated intrusion detection and anomalous activity monitoring across funnalo's infrastructure.
• Secure data centre hosting compliant with ISO 27001 standards.

11. Your Rights Under Philippine Law

As a data subject under the Data Privacy Act of 2012, you are entitled to the following rights with respect to your personal data held by funnalo:

• Right to Be Informed: The right to be told what personal data funnalo holds about you and how it is being processed — which this Policy fulfils.
• Right of Access: The right to request a copy of all personal data funnalo holds about you in a structured, commonly used format.
• Right to Correction: The right to request that inaccurate, outdated, or incomplete personal data be corrected without unreasonable delay.
• Right to Erasure: The right to request deletion of personal data where it is no longer necessary for the purposes for which it was collected, subject to funnalo's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a machine-readable format and to transmit it to another controller where technically feasible.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe funnalo has processed your personal data in a manner inconsistent with the Data Privacy Act of 2012.

To exercise any of the above rights, please contact the funnalo Data Privacy Officer (DPO) using the contact details provided in Section 14 of this Policy. funnalo will respond to all verified data subject requests within fifteen (15) business days of receipt.

12. Children's Privacy

The funnalo platform is strictly for persons who are 21 years of age or older, in accordance with PAGCOR's age requirements for real-money gaming in the Philippines. funnalo does not knowingly collect personal data from individuals under the age of 21.

If funnalo discovers or has reasonable grounds to believe that personal data has been collected from a person under 21 years of age, it will immediately suspend the relevant account, void all associated transactions, and securely delete all personal data connected to that account. If you are a parent or guardian and believe your minor child has registered on funnalo, please contact our support team immediately at [email protected].

13. Changes to This Privacy Policy

funnalo reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or our data processing practices. When material changes are made, funnalo will:

• Update the "Last Updated" date at the top of this Policy.
• Display a prominent notice on the funnalo platform for a minimum of fourteen (14) days following the effective date of the change.
• Send an email notification to your registered funnalo email address where the change materially affects your rights or the way your data is used.

Your continued use of the funnalo platform after the effective date of any amendment constitutes acceptance of the updated Policy. If you do not agree with the amended Policy, you may request account closure prior to the effective date.

14. Contact & Complaints

For any questions, requests, or concerns relating to this Privacy Policy or funnalo's data processing practices, please contact our Data Privacy Officer through the following channels:

If you are not satisfied with funnalo's response to your data privacy concern, you have the right to escalate your complaint directly to the National Privacy Commission (NPC) of the Philippines. The NPC is the independent government body responsible for enforcing the Data Privacy Act of 2012.