Privacy Policy for inato.ph

1 Introduction

1.1 inato.ph is committed to protecting the privacy and personal data of all players who use our Platform. This Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines.

1.2 This Policy applies to all personal data collected by inato.ph in connection with your use of the Platform, whether collected online, through our mobile application, or through any other channel of interaction with inato.ph.

1.3 For the purposes of this Policy, "personal data" means any information from which you can be identified, directly or indirectly, including but not limited to your name, contact details, financial information, device identifiers, and gaming activity records.

1.4 inato.ph acts as the personal information controller in respect of the personal data it collects and processes. Our Data Protection Officer ("DPO") is responsible for overseeing compliance with this Policy and applicable data protection law. Contact details for our DPO are provided in Section 14.

2 Personal Data We Collect

2.1 inato.ph collects the following categories of personal data in connection with your use of the Platform:

2.2 Where you choose not to provide personal data that is required for a specific purpose — such as identity verification documents required for withdrawal processing — inato.ph may be unable to provide the relevant service or fulfill the relevant request.

2.3 inato.ph does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where such information is voluntarily provided by you in the context of a responsible gaming self-assessment or support interaction.

3 How We Collect Your Data

3.1 inato.ph collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Data collected automatically when you access the Platform, including cookies, web beacons, server logs, and device fingerprinting technologies;
• Third-party sources: Data received from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), identity verification service providers, fraud prevention agencies, and regulatory authorities, where permitted by applicable law;
• Publicly available sources: Information from public records or databases where relevant to our legal compliance obligations, such as anti-money laundering screening.

3.2 inato.ph does not purchase personal data lists from third-party data brokers for marketing purposes.

4 How We Use Your Personal Data

4.1 inato.ph uses the personal data we collect for the following purposes:

• To create, manage, and maintain your inato.ph player account;
• To verify your identity and age in accordance with applicable Philippine gaming regulations, including the mandatory 21+ age requirement;
• To process deposits, withdrawals, and other financial transactions through your chosen payment method;
• To operate, maintain, and improve the games and features available on the inato.ph Platform, including Dreams of Macao, Golden Leopard, Fishing Disco, D&T Ranking, Ocean Phoenix, MT Live, and Lucky Dice;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To monitor gaming activity for responsible gaming purposes and to enforce self-exclusion and account restriction requests;
• To communicate with you regarding your account, transactions, promotions, and Platform updates;
• To respond to your customer support enquiries and resolve disputes;
• To comply with our legal and regulatory obligations, including reporting requirements under Philippine anti-money laundering laws;
• To analyze Platform usage patterns and improve the overall user experience for players across Manila, Cebu, Davao, Quezon City, Makati, and the rest of the Philippines.

4.2 inato.ph will not use your personal data for any purpose that is incompatible with the purposes described in this Section without first obtaining your consent or establishing another lawful basis for processing.

5 Legal Basis for Processing

5.1 inato.ph 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, including operating your account, processing transactions, and providing gaming services;
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering obligations, gaming regulatory requirements, and tax reporting;
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, Platform security, and service improvement, where such interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

6.1 inato.ph does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your financial transactions;
• Identity verification providers: Third-party KYC and age verification service providers engaged to assist with our regulatory compliance obligations;
• Fraud prevention and AML screening services: Providers of fraud detection, risk assessment, and anti-money laundering screening tools;
• Technology and infrastructure providers: Cloud hosting, data storage, and software service providers who process data on our behalf under binding data processing agreements;
• Regulatory and law enforcement authorities: Philippine government agencies, regulatory bodies, law enforcement, and courts, where disclosure is required by law or necessary to protect the rights and safety of inato.ph or others;
• Professional advisers: Lawyers, auditors, and other professional advisers, subject to binding confidentiality obligations.

6.2 All third-party service providers who process personal data on behalf of inato.ph are required to implement appropriate technical and organizational security measures and to process data only in accordance with our documented instructions.

6.3 In the event of a merger, acquisition, or sale of all or substantially all of the assets of inato.ph, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

7 Cookies & Tracking Technologies

7.1 inato.ph uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage) to operate and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These cookies enable core features such as account login, session management, and security. They cannot be disabled without impairing Platform functionality;
• Performance and analytics cookies: Used to collect anonymized information about how players use the Platform, including which pages are visited most frequently and how players navigate between pages. This data helps us improve Platform performance and user experience;
• Functional cookies: Used to remember your preferences and settings, such as your preferred language and display options, to provide a more personalized experience;
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats to the Platform and your account.

7.2 You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the inato.ph Platform and your ability to access certain features.

7.3 inato.ph does not use third-party advertising cookies or behavioral tracking cookies for the purpose of serving targeted advertisements on external websites.

8 Data Retention

8.1 inato.ph retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering record-keeping requirements;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations;
• Gaming activity records: Retained for a minimum of three (3) years from the date of the activity, for dispute resolution and regulatory compliance purposes;
• Customer support communications: Retained for a minimum of two (2) years from the date of the interaction;
• Technical and log data: Retained for up to twelve (12) months, unless a longer retention period is required for security investigation purposes.

8.2 Where personal data is no longer required for any lawful purpose, inato.ph will securely delete or anonymize it in accordance with our data disposal procedures. Anonymized data that can no longer be linked to an identifiable individual may be retained indefinitely for statistical and analytical purposes.

9 Data Security

9.1 inato.ph implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption of data in transit using Transport Layer Security (TLS) protocols;
• Encryption of sensitive data at rest using industry-standard encryption algorithms;
• Role-based access controls limiting access to personal data to authorized personnel only;
• Regular security assessments, vulnerability scanning, and penetration testing of Platform infrastructure;
• Staff training on data protection obligations and security best practices;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, inato.ph will notify the National Privacy Commission of the Philippines and, where required, affected players, in accordance with the timelines prescribed by applicable law.

9.3 While inato.ph takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the security of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

10 Your Data Subject Rights

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by inato.ph:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as described in this Policy;
• Right of access: The right to request a copy of the personal data inato.ph holds about you, along with information about how it is being used;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held about you;
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

10.2 To exercise any of the rights described above, please contact our Data Protection Officer using the details provided in Section 14. We will respond to all verified data subject requests within thirty (30) days of receipt, or within such extended period as permitted by applicable law where the request is complex or numerous.

10.3 inato.ph may need to verify your identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized parties. We may request a copy of a government-issued identification document for this purpose.

11 Children's Privacy

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

11.2 If inato.ph becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any deposits made by an underage player will be returned, less any amounts already wagered.

11.3 If you are a parent or guardian and believe that your child has registered on the inato.ph Platform, please contact us immediately using the details in Section 14 so that we can take appropriate action.

12 International Data Transfers

12.1 inato.ph primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers located in other countries in connection with the provision of cloud hosting, technical support, or other contracted services.

12.2 Where personal data is transferred outside the Philippines, inato.ph ensures that appropriate safeguards are in place to protect your data, including contractual clauses that impose data protection obligations on the recipient equivalent to those applicable under Philippine law.

12.3 By using the inato.ph Platform, you acknowledge and consent to the transfer of your personal data as described in this Section, subject to the safeguards described herein.

13 Changes to This Privacy Policy

13.1 inato.ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

13.2 Where material changes are made to this Policy, inato.ph will notify registered players via email or through a prominent notice on the Platform prior to the changes taking effect, where reasonably practicable.

13.3 Your continued use of the inato.ph Platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of the updated Policy. We encourage you to review this Policy periodically to stay informed of how we protect your personal data.

13.4 If you do not agree with any changes to this Privacy Policy, you should cease using the Platform and may request closure of your account by contacting our support team.

14 Contact Us & Data Protection Officer

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the way inato.ph handles your personal data, please contact our Data Protection Officer. Our DPO is responsible for ensuring that inato.ph processes personal data in compliance with applicable data protection law.

14.2 You may contact our Data Protection Officer at the following email address (plain text — not a clickable link):

14.3 For general customer support enquiries unrelated to data protection, you may contact our support team at (plain text — not a clickable link):

14.4 If you are not satisfied with our response to a data protection concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

14.5 inato.ph aims to acknowledge all data protection enquiries within five (5) business days and to resolve substantive requests within thirty (30) days of receipt of all relevant information and identity verification.