croyale Privacy Policy

1 About This Policy

This Privacy Policy applies to all personal data collected and processed by croyale in connection with the operation of the croyale online gaming platform, including the website at croyale.app, any mobile-optimized interfaces, customer support channels, and promotional communications.

This Policy does not apply to third-party websites, services, or applications that may be linked to or from the croyale platform. croyale is not responsible for the privacy practices of any third-party services, and we encourage you to review the privacy policies of any third-party platforms you access.

2 Data Controller

croyale acts as the personal information controller ("PIC") in respect of the personal data collected through the croyale platform, as defined under the Philippine Data Privacy Act of 2012. As PIC, croyale determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws.

croyale has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection strategy and implementation, and for ensuring compliance with the DPA and NPC regulations. You may contact our DPO for any privacy-related inquiries at the contact details provided in Section 14 of this Policy.

3 Data We Collect

croyale collects the following categories of personal data from players and platform visitors:

4 How We Collect Your Data

croyale collects personal data through the following means:

• Direct collection: Information you provide when registering a croyale account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the croyale platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from accredited KYC service providers; fraud screening data from payment processors; and, where applicable, information from PAGCOR or other regulatory authorities.

croyale will always inform you at the point of collection what data is being collected and for what purpose, in accordance with the transparency requirements of the DPA.

5 How We Use Your Data

croyale processes your personal data for the following purposes:

• To create and manage your croyale player account and verify your identity and age (21+ requirement).
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP).
• To comply with PAGCOR licensing conditions, anti-money laundering (AML) obligations, and other applicable Philippine laws and regulations.
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited conduct on the platform.
• To monitor gameplay patterns for responsible gaming purposes and to identify players who may be experiencing gambling-related harm.
• To provide customer support and resolve disputes or complaints.
• To send you transactional communications (account notifications, deposit/withdrawal confirmations, security alerts).
• To send you marketing communications about croyale promotions and offers, where you have provided consent or where we have a legitimate interest to do so.
• To improve and personalize the croyale platform experience based on your usage patterns.
• To comply with any court order, legal process, or regulatory request from a competent Philippine authority.

6 Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you (i.e., to operate your croyale account, process transactions, and provide gaming services).
• Legal obligation: Processing required to comply with PAGCOR regulations, AML laws, tax obligations, and other applicable Philippine legal requirements.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for optional purposes such as marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Sharing Your Data

croyale does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors and e-wallet providers (GCash, PayMaya/Maya, partner banks) — to process your financial transactions.
• KYC and identity verification providers — to verify your identity and age in compliance with PAGCOR requirements.
• Fraud prevention and AML screening services — to detect and prevent financial crime on the platform.
• IT infrastructure and cloud service providers — who host and maintain the croyale platform under strict data processing agreements.
• PAGCOR and other Philippine regulatory authorities — where required by law, regulation, or regulatory direction.
• Law enforcement and courts — where required by a valid court order, subpoena, or legal process under Philippine law.

All third-party service providers who process personal data on behalf of croyale are required to enter into data processing agreements that impose obligations consistent with the DPA and this Privacy Policy.

8 Data Retention

croyale retains your personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and PAGCOR regulations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your croyale account and for a minimum of 5 years after account closure, in compliance with PAGCOR record-keeping requirements and AML obligations.
• Transaction and financial data: Retained for a minimum of 5 years from the date of the transaction, as required by Philippine AML regulations.
• Customer support communications: Retained for 3 years from the date of the communication.
• Technical and usage data: Retained for up to 12 months from collection, unless required for longer periods for security or fraud investigation purposes.
• Marketing consent records: Retained for the duration of your consent and for 3 years after withdrawal of consent.

Upon expiry of the applicable retention period, croyale will securely delete or anonymize your personal data in accordance with NPC-approved data disposal procedures.

9 Security Measures

croyale 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:

• TLS/SSL encryption for all data transmitted between your device and the croyale platform.
• Encryption of sensitive data at rest, including financial data and government ID information.
• Multi-factor authentication (MFA) options for player accounts.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing by independent security professionals.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

10 Cookies & Tracking Technologies

croyale uses cookies and similar tracking technologies on the croyale platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how you use the platform.

croyale uses the following categories of cookies:

• Strictly necessary cookies: Essential for the platform to function correctly (e.g., session management, login authentication). These cannot be disabled.
• Functional cookies: Remember your preferences and settings (e.g., language, display preferences) to improve your experience.
• Analytics cookies: Collect anonymized data about how players use the platform to help us improve performance and usability.
• Security cookies: Used to detect and prevent fraudulent activity and protect the integrity of the platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the croyale platform. croyale does not use third-party advertising or behavioral tracking cookies.

12 Minors & Age Policy

The croyale platform is strictly intended for persons aged 21 years and above, in compliance with Philippine gambling regulations. croyale does not knowingly collect personal data from individuals under the age of 21. If croyale becomes aware that personal data has been collected from a person under 21, such data will be immediately deleted and the associated account will be closed.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to croyale, please contact our Data Protection Officer immediately so that we can take appropriate action.

13 Changes to This Policy

croyale reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes to this Policy will be communicated to registered players via the email address or mobile number on file at least 7 days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how croyale protects your personal data. Your continued use of the croyale platform after any amendments constitutes your acceptance of the revised Policy.

14 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by croyale, please contact our Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Support: [email protected] (plain text — not a clickable link)
• Live Chat: Available through the croyale platform after login

If you are not satisfied with croyale's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information about how to file a complaint with the NPC is available on the NPC's official website.