cosino Privacy Policy – How We Handle Your Personal Data

Introduction

This Privacy Policy applies to all personal information collected, used, stored, or otherwise processed by cosino ("the Platform," "we," "us") in connection with the online gaming services available at cosino.cam. It covers all users of the cosino platform, including registered players, applicants for registration, and visitors who browse the site without creating an account.

cosino is committed to protecting the privacy and personal data of every Filipino player on the platform. We process personal data in accordance 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 (NPC). Where relevant, we also observe internationally recognized data protection standards.

By registering for or continuing to use a cosino account, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please do not create or continue using a cosino account.

Data Controller

For the purposes of this Privacy Policy and applicable Philippine data protection law, cosino — the operator of the platform at cosino.cam — acts as the personal information controller with respect to the data it collects directly from players and visitors.

Where cosino engages third-party service providers (such as payment processors, game content providers, or IT infrastructure vendors) who process data on cosino's behalf and under cosino's instructions, those providers act as personal information processors. cosino takes appropriate contractual steps to ensure processors handle your data in accordance with this Policy and applicable law.

For all data privacy-related inquiries, requests, and complaints, you may contact the cosino Data Protection Officer (DPO) at:
Email: [email protected] (subject line: Data Privacy Request)

Personal Data We Collect

cosino collects personal data only to the extent necessary for the purposes described in this Policy. The categories of data we may collect include:

How We Collect Your Data

cosino collects personal data through the following channels:

• Directly from you — when you register for a cosino account, complete identity or age verification, make a deposit or withdrawal request, contact support, or update your account settings.
• Automatically — when you use the cosino platform, our systems automatically record technical data (IP address, device, browser) and gaming activity data (sessions, bets, outcomes) as a necessary function of delivering the service.
• From payment processors — when you initiate or complete a GCash, PayMaya, BPI, BDO, or Metrobank transaction, those processors share confirmation data (transaction reference, amount, timestamp) with cosino to enable wallet crediting and withdrawal processing.
• From identity verification services — where cosino engages a third-party KYC (Know Your Customer) or age verification provider, that provider may share verification outcomes and document summaries with cosino to fulfil our compliance obligations.
• From cookies and tracking technologies — as described in the Cookies section of this Policy.

Purposes of Processing

cosino processes your personal data for the following purposes:

• Account creation and management — to register your cosino account, maintain it in good standing, and process account closure requests.
• Identity and age verification — to confirm that you are at least 21 years of age and are who you claim to be, as required under applicable Philippine regulations.
• Payment processing — to credit deposits to your cosino wallet and to process withdrawals to your registered GCash, PayMaya, BPI, BDO, or Metrobank account in Philippine Peso.
• Fraud prevention and anti-money laundering (AML) compliance — to detect, investigate, and prevent fraudulent activity, financial crime, and multi-accounting on the cosino platform.
• Security and account protection — to send OTP codes to your registered Philippine mobile number, detect unauthorized login attempts, and notify you of security-relevant events on your account.
• Gaming services delivery — to run game sessions, record outcomes, apply bonus credits, track wagering requirement progress, and power the cosino loyalty program.
• Responsible gaming — to monitor gaming patterns for signs of problem gambling, enforce player-requested limits and self-exclusions, and comply with responsible gaming obligations.
• Customer support — to handle your queries, complaints, and disputes, and to maintain records of support interactions for quality assurance and regulatory purposes.
• Legal and regulatory compliance — to fulfil cosino's obligations under Philippine law, PAGCOR regulatory requirements, and any other applicable legal obligations, including responding to lawful requests from competent authorities.
• Service communications — to send you transactional notifications, security alerts, and — where you have provided explicit consent — promotional communications about cosino offers.
• Platform improvement — to analyse anonymized or aggregated usage patterns to improve the cosino platform, optimize game performance, and enhance the mobile experience for Filipino players.

Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, cosino relies on the following legal bases to process your personal data, depending on the specific purpose:

• Contractual necessity — processing required to deliver the cosino service under the Terms & Conditions you accepted at registration (e.g., account management, payment processing, gaming services).
• Legal obligation — processing required to comply with cosino's obligations under Philippine law, including AML regulations, age verification requirements, and regulatory reporting (e.g., identity verification, transaction records).
• Legitimate interests — processing carried out for cosino's legitimate business interests where these are not overridden by your privacy rights (e.g., fraud detection, security monitoring, platform analytics).
• Consent — processing carried out on the basis of your explicit consent, where required (e.g., receiving promotional communications). You may withdraw consent for consent-based processing at any time without affecting the legality of prior processing.

Data Sharing & Disclosure

cosino does not sell, rent, or trade your personal data. We share your data only in the following circumstances and with the following categories of recipients:

• Payment processors (GCash, PayMaya, BPI, BDO, Metrobank) — receive only the transaction data necessary to process your deposit or withdrawal. They are bound by their own privacy policies and applicable financial regulations.
• Identity and KYC verification providers — receive document copies and identity data solely to perform age and identity checks on cosino's behalf, under strict data processing agreements.
• Game content providers — receive anonymized or pseudonymized session identifiers to deliver game content and record outcomes. They do not receive your full identity or payment details.
• IT infrastructure and cloud service providers — host cosino's platform data on servers operated under confidentiality agreements and appropriate security standards.
• Legal and regulatory authorities — cosino will disclose personal data to competent Philippine government bodies, law enforcement agencies, or courts when required by law, a valid court order, or a legitimate regulatory demand. Where permitted by law, cosino will notify you of such a disclosure.
• Professional advisers — lawyers, auditors, and compliance consultants who are bound by professional confidentiality obligations.

Cookies & Tracking Technologies

cosino uses cookies and similar tracking technologies to operate the platform reliably, maintain your logged-in session, and understand how players use the service in aggregate. The types of cookies we use are as follows:

• Strictly necessary cookies — required for the cosino platform to function. These include session authentication cookies that keep you logged into your account. You cannot opt out of these cookies without losing access to the platform.
• Functional cookies — remember your preferences, such as your preferred language or display settings, to improve your experience across sessions.
• Analytics cookies — collect anonymized data about how players navigate and use cosino, allowing us to identify performance issues and improve the mobile experience for Filipino users. This data is processed in aggregated, non-identifiable form.
• Security cookies — help detect and prevent fraudulent activity, such as identifying unusual device or network patterns during login attempts.

cosino does not currently use third-party advertising or retargeting cookies. You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to cosino.

Data Retention

cosino retains your personal data for as long as is necessary for the purpose for which it was collected, and for as long as required by applicable Philippine law and regulatory obligations. The following general retention guidelines apply:

• Active account data — retained for the duration of your cosino account's active status plus the applicable statutory retention period following account closure.
• Transaction and financial records — retained for a minimum of five (5) years following each transaction, as required under Philippine AML regulations and BSP guidelines applicable to e-money transactions.
• Identity verification documents — retained for the duration of the account plus a minimum of five (5) years following account closure, or longer if required by applicable law.
• Support and communication records — retained for three (3) years from the date of the last interaction, unless a longer period is required in connection with an ongoing dispute or regulatory matter.
• Gaming activity records — retained for five (5) years from the date of each game session, for audit, dispute resolution, and responsible gaming monitoring purposes.
• Anonymized analytics data — may be retained indefinitely, as it does not contain personal identifiers.

Following the expiry of the applicable retention period, cosino will securely delete or permanently anonymize your personal data unless a specific legal obligation requires continued retention.

Data Security

cosino implements technical and organizational security measures designed to protect your personal data from unauthorized access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your browser or mobile device and the cosino platform.
• Encryption of sensitive data fields (including identity document references and financial account identifiers) at rest in cosino's databases.
• Multi-factor authentication (MFA) for cosino staff accessing systems that contain player personal data.
• Role-based access controls ensuring that staff members access only the player data necessary for their specific job function.
• Regular internal and external security assessments and penetration testing of cosino's platform infrastructure.
• Incident response procedures designed to detect, contain, and report data breaches within the timeframes required by the National Privacy Commission.

While cosino takes all reasonable steps to protect your data, no online platform can guarantee absolute security against all threats. You play an important role in account security by using a strong unique password, keeping your OTP codes private, and logging out of shared devices after use.

Your Data Rights

Under the Philippine Data Privacy Act of 2012, you hold the following rights with respect to your personal data held by cosino. To exercise any of these rights, contact the cosino DPO at [email protected] with the subject line "Data Privacy Request."

Children & Minors

cosino's gaming services are strictly restricted to individuals who are 21 years of age or older, in accordance with Philippine regulations for casino-style online gaming. cosino does not knowingly collect personal data from persons under the age of 21.

If cosino becomes aware that personal data has been collected from a person under 21 years of age, all data associated with that individual will be deleted promptly and the account will be permanently closed. Any balances in an underage account will be handled in accordance with cosino's Terms & Conditions and applicable law.

If you have reason to believe that a person under 21 may have accessed cosino using your account or another account, please contact [email protected] immediately.

Cross-Border Data Transfers

cosino primarily stores and processes player data within server infrastructure serving the Philippines. In some cases, cosino's third-party service providers (such as cloud platform vendors, game content providers, or KYC verification services) may process data outside of the Philippines.

Where such transfers occur, cosino takes appropriate steps to ensure that the recipient provides an adequate level of data protection, including through contractual safeguards that comply with the cross-border transfer requirements of the Philippine Data Privacy Act of 2012. cosino will not transfer your personal data to a country or organization that fails to provide adequate protection without first putting in place additional safeguards or obtaining your explicit consent.

Updates to This Privacy Policy

cosino may update this Privacy Policy from time to time to reflect changes in our data processing practices, new regulatory requirements, or improvements to our platform. When material updates are made, cosino will notify active players through one or more of the following channels: a notification within the cosino platform dashboard, an email or SMS to your registered contact details, or a prominent notice on the cosino homepage.

The effective date of the most recent version of this Policy is shown at the top of this page. Your continued use of cosino following the effective date of an updated Policy constitutes your acceptance of the changes. If you do not agree with the updated Policy, you may request voluntary account closure by contacting the cosino support team.

Previous versions of this Privacy Policy are available upon request from the cosino DPO.

Contact & Complaints

For any questions, requests, or concerns regarding this Privacy Policy or cosino's handling of your personal data, please contact the cosino Data Protection Officer:

• Email: [email protected] — use subject line "Data Privacy Request" for all data protection matters.
• Live Chat: Available 24/7 from within your cosino account dashboard. Mention "data privacy" so the query is routed to the appropriate team.

cosino aims to acknowledge all data privacy requests within three (3) business days and to provide a substantive response within fifteen (15) calendar days. For complex requests, this period may be extended by up to an additional thirty (30) days, in which case we will notify you.

If you are not satisfied with cosino's response to your data privacy complaint, you may escalate the matter to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority for data protection matters in the Philippines. Information on how to file a complaint is available on the NPC's official website.