Privacy Policy

This Privacy Policy ("Policy") is issued by tracksino ("tracksino," "we," "us," or "our"), the operator of the online gaming platform accessible at tracksino.asia (the "Platform"). This Policy governs the collection, use, storage, disclosure, and protection of personal data submitted to or collected by tracksino in connection with your use of the Platform.

tracksino is committed to full compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). Where applicable, tracksino also observes the data protection standards required by the Philippine Amusement and Gaming Corporation ("PAGCOR") as a condition of its operating authorization.

By registering an account on the tracksino Platform, accessing our games, or otherwise interacting with our services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform and contact us to request account closure.

tracksino collects the following categories of personal data from registered users and Platform visitors:

A. Identity & Contact Data

• Full legal name as it appears on your Philippine government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Gender (optional, for personalization purposes)
• Residential address (city, province, postal code)
• Email address and mobile number
• Government-issued ID type and number (for KYC verification)

B. Financial Data

• GCash or PayMaya/Maya account details (registered name and mobile number)
• Bank account details (bank name, account name, account number) for bank transfer transactions
• Debit card details (card type, last four digits, expiry date) where applicable
• Transaction history: deposits, withdrawals, bonus credits, and wager records

C. Gaming & Behavioral Data

• Game session logs: games played, bet amounts, win/loss outcomes, session duration
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
• Customer support interaction records

D. Technical & Device Data

• IP address and approximate geolocation (city/region level)
• Device type, operating system, and browser version
• Cookie identifiers and session tokens
• Platform access timestamps and navigation logs

E. KYC Documentation

• Scanned or photographed copies of government-issued Philippine IDs
• Proof of address documents (utility bills, bank statements, barangay certificates)
• Source of funds declarations where required under AMLA thresholds
• Selfie or liveness verification images where required for identity confirmation

tracksino does not collect sensitive personal information beyond what is strictly necessary for KYC compliance and responsible gaming obligations. We do not collect data relating to political opinions, religious beliefs, or health conditions unless directly relevant to a responsible gaming intervention.

tracksino collects personal data through the following channels:

• Direct submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and behavioral data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Identity verification data from licensed KYC service providers; fraud and AML screening data from compliance databases; payment confirmation data from GCash, PayMaya/Maya, and partner banks.
• Regulatory sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with licensing, compliance audits, or self-exclusion registry checks.

tracksino will always inform you at the point of collection what data is being collected and for what purpose. Mandatory fields are clearly marked during registration; optional fields are provided for your convenience and personalization only.

tracksino processes your personal data for the following specific purposes:

tracksino will not use your personal data for any purpose not listed above without first obtaining your explicit consent or as otherwise required by Philippine law.

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

• Consent: For marketing communications, optional personalization features, and any processing not covered by the bases below. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contractual necessity: Processing required to fulfill our obligations under the tracksino Terms & Conditions, including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with Philippine law, including the Anti-Money Laundering Act (AMLA), the Data Privacy Act, PAGCOR licensing conditions, and NPC regulations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregate analytics, where such interests are not overridden by your privacy rights.
• Vital interests: In exceptional circumstances, processing necessary to protect the safety or wellbeing of a data subject, such as responsible gaming interventions.

Where tracksino relies on consent as the legal basis for processing, you will be presented with a clear, affirmative opt-in mechanism. Pre-ticked boxes and bundled consents are not used by tracksino.

tracksino does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the following limited circumstances:

• Licensed game providers: Game session data is shared with our licensed third-party game providers (e.g., live casino operators, slot providers) solely to deliver the games you play. These providers are contractually bound to process your data only for game delivery purposes.
• Payment processors: Financial data is shared with GCash, PayMaya/Maya, partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), and debit card processors to facilitate deposits and withdrawals.
• KYC and compliance providers: Identity and document data is shared with licensed identity verification and AML screening service providers to fulfill our regulatory obligations.
• Regulatory authorities: tracksino is required by law to share certain data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government agencies upon lawful request or as mandated by applicable regulations.
• Law enforcement: tracksino will disclose personal data to Philippine law enforcement agencies where required by a valid court order, subpoena, or other lawful legal process.
• Corporate transactions: In the event of a merger, acquisition, or sale of substantially all of tracksino's assets, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

tracksino uses cookies and similar tracking technologies to operate the Platform, improve your experience, and fulfill our security and compliance obligations. The types of cookies we use are:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without breaking core Platform functionality.
• Functional cookies: Remember your preferences such as language settings, game display options, and responsible gaming tool configurations.
• Analytics cookies: Collect aggregated, anonymized data about how users navigate the Platform to help us identify and fix usability issues. No personally identifiable information is included in analytics reports.
• Security and fraud-detection cookies: Help tracksino identify suspicious login patterns, detect bot activity, and prevent unauthorized account access.

tracksino does not use third-party advertising or behavioral profiling cookies. You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log in and use the Platform.

tracksino's cookie consent mechanism is presented to new visitors upon their first visit to the Platform. Continued use of the Platform after dismissing the cookie notice constitutes acceptance of strictly necessary cookies only.

tracksino retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Our standard retention periods are as follows:

Upon expiry of the applicable retention period, tracksino will securely delete or anonymize your personal data in accordance with NPC-approved data disposal procedures. Data subject to an ongoing legal dispute, regulatory investigation, or court order will be retained until the matter is fully resolved.

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

• Encryption in transit: All data transmitted between your device and the tracksino Platform is encrypted using TLS 1.2 or higher.
• Encryption at rest: Sensitive personal data, including KYC documents and financial records, is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data is restricted to tracksino personnel and authorized service providers on a strict need-to-know basis. All access is logged and audited.
• Two-factor authentication: Available for all tracksino accounts and mandatory for administrative access to systems containing personal data.
• Penetration testing: tracksino's Platform and infrastructure undergo regular third-party security assessments and penetration tests.
• Incident response: tracksino maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, tracksino will notify the NPC within 72 hours and affected data subjects without undue delay, as required by the DPA.

While tracksino takes all reasonable steps to protect your data, no security system is completely impenetrable. You are responsible for maintaining the security of your account credentials. If you suspect that your tracksino account has been compromised, please contact our support team immediately via live chat.

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

• Right to be informed: You have the right to know what personal data tracksino collects about you, how it is used, and with whom it is shared — which is the primary purpose of this Policy.
• Right of access: You may request a copy of the personal data tracksino holds about you, along with information about how it is processed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data in your tracksino account.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to tracksino's legal retention obligations under AMLA and PAGCOR regulations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to tracksino's overriding legal obligations.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format for transfer to another service provider.
• Right to lodge a complaint: If you believe tracksino has violated your data privacy rights, you may file a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.

To exercise any of the above rights, please submit a written request to tracksino's Data Protection Officer at the contact details provided in Section 13. tracksino will respond to all verified data subject requests within fifteen (15) calendar days, as required by the DPA. Complex requests may require up to thirty (30) days, in which case tracksino will notify you of the extension and the reason for it.

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

During registration, all users are required to confirm their date of birth and submit government-issued ID for age verification. Any account found to belong to a person under 21 years of age will be immediately suspended, all balances forfeited, and the matter reported to PAGCOR as required by our licensing conditions.

If you are a parent or guardian and believe that a minor has registered on the tracksino Platform using false information, please contact us immediately at [email protected]. tracksino will investigate and take appropriate action, including account closure and deletion of any personal data collected from the minor, within 48 hours of a verified report.

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

• Post the updated Policy on this page with a revised "Last Updated" date
• Send a notification to your registered email address at least seven (7) days before the changes take effect
• Display a prominent notice on the Platform for at least fourteen (14) days following the update

Your continued use of the tracksino Platform after the effective date of any amended Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you may request account closure in accordance with the Terms & Conditions before the effective date.

tracksino encourages you to review this Policy periodically to stay informed about how we protect your personal data. The most current version of this Policy is always available at tracksino.asia/privacy-policy.

tracksino has appointed a Data Protection Officer ("DPO") in accordance with Section 21 of the Data Privacy Act of 2012 and its Implementing Rules and Regulations. The DPO is responsible for overseeing tracksino's data protection compliance program and serving as the primary point of contact for data subject inquiries and NPC communications.

To exercise your data subject rights, report a privacy concern, or submit a formal complaint, please contact us through the following channels:

• Data Protection Officer: [email protected]
• General Privacy Inquiries: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the tracksino Platform

tracksino aims to acknowledge all privacy-related inquiries within two (2) Philippine business days and to resolve them within the statutory timeframes prescribed by the DPA. For urgent account security matters, please use the 24/7 live chat service.

If you are not satisfied with tracksino's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.