croyale Privacy Policy

croyale ("croyale," "we," "us," or "our") is committed to protecting the privacy and personal data of all players who use the croyale platform at croyale.net. This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you access or use our website, games, and related services (collectively, the "Platform").

This Privacy Policy is governed by the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations. By registering an account or using the croyale Platform, 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.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference. If you do not agree with any part of this Privacy Policy, please discontinue use of the Platform immediately.

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, croyale acts as the Personal Information Controller (PIC) in respect of the personal data you provide when using the Platform.

As the Personal Information Controller, croyale is responsible for determining the purposes and means of processing your personal data, and for ensuring that such processing is carried out in accordance with applicable law and this Privacy Policy.

If you have any questions or concerns about how croyale handles your personal data, you may contact our designated Data Protection Officer (DPO) using the contact details provided in Section 15 of this Privacy Policy.

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

croyale collects personal data through the following means:

• Direct Interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Technologies: Data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and similar tracking technologies. See Section 10 for more details on our cookie practices.
• Third-Party Sources: Data received from identity verification providers, payment processors (such as GCash and PayMaya), fraud prevention services, and regulatory databases, where permitted by law.
• Publicly Available Sources: In limited circumstances, croyale may supplement your profile with data from publicly available sources for fraud prevention and regulatory compliance purposes.

croyale processes your personal data for the following purposes:

• Account Management: To create, verify, maintain, and manage your croyale player account, including processing your registration and verifying your identity in accordance with KYC requirements.
• Service Delivery: To provide you with access to croyale's games, betting markets, and platform features, and to process your deposits, withdrawals, and wagers.
• Legal and Regulatory Compliance: To comply with our obligations under Philippine law, PAGCOR regulations, anti-money laundering (AML) legislation, and other applicable legal requirements, including reporting obligations to regulatory authorities.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal or prohibited conduct on the Platform.
• Responsible Gaming: To monitor player activity for signs of problem gambling, enforce responsible gaming tools such as deposit limits and self-exclusion, and comply with our duty of care obligations.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonuses, and platform updates, where you have provided your consent to receive such communications. You may withdraw your consent at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the croyale Platform.
• Personalization: To tailor your croyale experience, including game recommendations and promotional offers relevant to your preferences and activity.

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

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual Necessity: Where processing is necessary for the performance of our contract with you, including providing access to the Platform and processing financial transactions.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to croyale, including KYC, AML, and PAGCOR regulatory requirements.
• Legitimate Interests: Where processing is necessary for the purposes of croyale's legitimate interests, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and freedoms.

croyale does not sell your personal data. 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: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and identity verification services used to verify your identity and age in compliance with regulatory requirements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulatory obligation.
• Fraud Prevention Services: Third-party fraud detection and prevention providers used to protect the Platform and its players from fraudulent activity.
• Technology Service Providers: Cloud hosting providers, data analytics platforms, customer support software providers, and other technology vendors who process data on our behalf under strict data processing agreements.
• Game Providers: Third-party game software providers whose games are available on the croyale Platform, to the extent necessary for game operation and dispute resolution.
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors, where necessary for legal proceedings, compliance audits, or professional advice.

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

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AML regulatory requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML legislation.
• KYC and Identity Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with croyale's data disposal procedures.

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the croyale Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Strict access controls and role-based permissions limiting employee access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication options for player accounts;
• Continuous monitoring of the Platform for suspicious activity and potential security incidents;
• Staff training on data protection and information security best practices.

While croyale takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, croyale will notify you and the National Privacy Commission (NPC) in accordance with the requirements of the Data Privacy Act of 2012.

croyale uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver relevant content. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the Platform, including maintaining your login session and enabling core functionality. These cookies cannot be disabled.
• Performance and Analytics Cookies: Used to collect anonymized information about how visitors use the Platform, helping croyale identify areas for improvement. These cookies do not identify you personally.
• Functionality 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, protect against unauthorized access, and maintain the security 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. By continuing to use the Platform after being informed of our cookie practices, you consent to the use of cookies as described in this section.

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights in relation to your personal data held by croyale:

To exercise any of these rights, please contact croyale's Data Protection Officer using the details in Section 15. croyale will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

The croyale Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine law and PAGCOR regulations governing online gaming. 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 the age of 21, we will take immediate steps to delete such data and close the associated account. All winnings accrued by an underage player will be forfeited in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that your child has registered on the croyale Platform, please contact us immediately using the details in Section 15 so that we can take appropriate action.

In the course of operating the croyale Platform, your personal data may be transferred to and processed in countries outside the Philippines, for example where our technology service providers or game software providers are based in other jurisdictions.

Where such international transfers occur, croyale ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012 and its implementing rules. These safeguards may include:

• Transferring data only to countries that have been recognized as providing an adequate level of data protection;
• Implementing standard contractual clauses or data processing agreements with the recipient that impose equivalent data protection obligations;
• Obtaining your explicit consent to the transfer where required by law.

By using the croyale Platform, you acknowledge and consent to the transfer of your personal data to other countries as described in this section, subject to the safeguards outlined above.

croyale reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, croyale will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect.

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

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

• Email: [email protected]
• General Support: [email protected]
• Response Time: We aim to respond to all privacy-related inquiries within 30 days

If you are not satisfied with croyale's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines, the independent authority responsible for enforcing the Data Privacy Act of 2012.