laroph Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is published by laroph ("laroph", "we", "us", "the Platform") and applies to all personal data collected from users ("you", "Player", "data subject") in connection with your access to and use of the laroph online gaming platform at laroph.org and any associated services.

laroph is operated under the regulatory authority of the Philippine Amusement and Gaming Corporation (PAGCOR) and is committed to processing personal data lawfully, fairly, and transparently in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

This Policy should be read together with laroph's Terms and Conditions, which incorporate this Policy by reference. By registering a laroph account or otherwise providing your personal data to laroph, you acknowledge that you have read and understood this Policy.

2. Data Controller Identity

laroph is the personal information controller in respect of all personal data processed by or on behalf of the laroph platform. For the purposes of the Philippine Data Privacy Act, laroph is responsible for determining the purposes and means by which your personal data is processed.

laroph has appointed a Data Protection Officer (DPO) who is responsible for overseeing the platform's compliance with the DPA and NPC regulations. The DPO can be contacted at the address provided in Section 13 of this Policy.

3. Personal Data We Collect

laroph collects personal data from you directly (when you provide it during registration or through your use of the platform), automatically (through your interaction with the laroph platform), and from third parties (such as payment processors and identity verification services) where applicable.

The categories of personal data laroph collects include:

laroph may collect sensitive personal information (as defined under the DPA) where required for identity verification, age verification, or AML compliance purposes. Such information is processed with heightened care and only to the extent strictly necessary for those purposes.

4. Purposes of Processing

laroph processes your personal data for the following specific purposes:

• Account Registration and Management: To create and administer your laroph account, verify your identity and age (21+ requirement), and maintain the accuracy of your account information.
• Service Delivery: To provide you with access to laroph's games, process bets, calculate and pay winnings, and deliver the full range of platform features available through your laroph Login.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods, and to maintain transaction records.
• Regulatory Compliance: To fulfil laroph's obligations under PAGCOR licensing conditions, the Philippine Anti-Money Laundering Act (AMLA), and the Data Privacy Act, including mandatory reporting to PAGCOR and the Anti-Money Laundering Council (AMLC) where required.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, money laundering, and other prohibited conduct on the laroph platform.
• Responsible Gaming: To monitor gaming activity patterns for indicators of problem gambling and to administer deposit limits, session alerts, and self-exclusion requests in accordance with PAGCOR's responsible gaming framework.
• Customer Support: To respond to your enquiries, resolve complaints, and improve laroph's support services based on interaction records.
• Platform Improvement: To analyse aggregated usage data, technical performance metrics, and player feedback to improve the laroph platform, correct errors, and develop new features.
• Marketing Communications: To send you promotional offers, bonus notifications, and other laroph marketing communications where you have provided consent or where permitted by applicable law. You may opt out at any time through your account settings.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, laroph processes your personal data on one or more of the following lawful bases:

• Contractual Necessity: Processing necessary for the performance of the laroph Terms and Conditions, including account management, game provision, and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, NPC requirements, and other applicable Philippine law.
• Legitimate Interest: Processing for fraud prevention, platform security, and aggregated analytics that does not override your fundamental privacy rights.
• Consent: Processing for marketing communications and certain optional data collection activities where your freely given, informed consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. Sharing Your Personal Data

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

• Service Providers: laroph engages third-party service providers — including payment processors, identity verification providers, cloud hosting services, and customer support tools — who process personal data on laroph's behalf as personal information processors under data processing agreements.
• Regulatory Authorities: laroph will disclose personal data to PAGCOR, the NPC, the AMLC, the Bureau of Internal Revenue, and other competent Philippine government authorities where required by law or in response to a lawful order.
• Law Enforcement: laroph may disclose personal data to the Philippine National Police or other law enforcement bodies where required by a valid legal process or where disclosure is necessary to prevent imminent harm.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of laroph's business assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

7. Data Retention

laroph retains your personal data for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law, whichever is longer. Specific retention periods apply as follows:

• Account and identity data: retained for the duration of your laroph account and for a minimum of five (5) years following account closure, consistent with PAGCOR licensing requirements and AMLA retention obligations.
• Financial transaction records: retained for a minimum of five (5) years as required under Philippine AML legislation.
• Gaming activity data: retained for three (3) years from the date of each session, or longer where required by PAGCOR or in connection with an ongoing investigation or dispute.
• Support communications: retained for two (2) years from the date of the last interaction, unless required to be retained longer in connection with a formal complaint or legal proceeding.

When personal data is no longer required for any lawful purpose, laroph will securely delete or anonymise it in accordance with NPC-approved disposal procedures.

8. Data Security

laroph implements technical, organisational, and administrative measures appropriate to the risk level of the personal data we process, in compliance with the security standards prescribed by the NPC under the Data Privacy Act. These measures include:

• TLS/SSL encryption for all data in transit between your device and laroph's servers, including laroph Login authentication flows;
• Encryption of sensitive personal data at rest using industry-standard algorithms;
• Role-based access controls ensuring that laroph personnel access personal data only to the extent required for their job function;
• Multi-factor authentication for laroph administrative systems that process personal data;
• Regular security assessments, penetration testing, and vulnerability management;
• Incident response and data breach notification procedures consistent with NPC Circular 16-03 and subsequent NPC issuances.

While laroph takes all reasonable steps to protect your personal data, no internet-based platform can guarantee absolute security. You are encouraged to use a strong, unique password for your laroph Login and to enable two-factor authentication from your account security settings.

9. Cookies and Tracking Technologies

laroph uses cookies and similar tracking technologies on the laroph platform to operate essential platform functions, analyse usage patterns, and improve the player experience. The following categories of cookies may be set when you use laroph:

• Strictly Necessary Cookies: Required for laroph Login sessions, security functions, and core platform operation. These cannot be disabled without impairing platform functionality.
• Performance and Analytics Cookies: Used to collect aggregated data on how players interact with laroph — which games are most accessed, how the lobby is navigated, and where technical errors occur. This data is used to improve the platform.
• Functional Cookies: Used to remember your preferences — such as language settings and display preferences — across sessions.

You may control non-essential cookie preferences through your browser settings. Note that disabling cookies may affect certain laroph platform features. laroph does not use cookies to serve third-party advertising.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to the personal data laroph holds about you:

• Right to be Informed: The right to be told what personal data laroph collects, why, and how it is used — 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 Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to laroph's legal retention obligations.
• Right to Object: The right to object to certain types of processing, including processing based on legitimate interest and direct marketing.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where processing is based on consent or contract.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe laroph has violated your data privacy rights.

To exercise any of these rights, please contact laroph's Data Protection Officer at the contact details provided in Section 13. laroph will respond to verified data subject requests within the timeframes required under the DPA and NPC regulations.

11. Minors

laroph's platform is strictly restricted to individuals aged 21 years and older under PAGCOR regulations and Philippine gaming law. laroph does not knowingly collect personal data from persons under the age of 21. If laroph becomes aware that personal data has been collected from a minor, it will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered a laroph account or provided personal data to laroph, please contact the laroph Data Protection Officer immediately at the contact details in Section 13 so that appropriate action can be taken.

12. Changes to This Privacy Policy

laroph reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. The "Last Updated" date at the top of this Policy will be revised to reflect the date of the most recent changes.

Where changes are material — meaning they significantly affect your rights as a data subject or the way laroph processes your personal data — laroph will provide advance notification to registered account holders via the email address on file. Continued use of the laroph platform following notification of a material change constitutes your acknowledgement of the updated Policy.

13. Contact the Data Protection Officer

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

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with laroph's response to your data privacy concerns. The NPC's contact details are available at the NPC's official website.