escala88 Privacy Policy

1. Introduction

escala88 is committed to protecting the privacy and personal data of all its registered members and platform visitors. This Privacy Policy has been prepared in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

This Policy applies to all personal information collected through the escala88 website at escala88.app, the official escala88 Android application, customer support interactions, and any other touchpoints through which escala88 collects personal data from users. It should be read in conjunction with the escala88 Terms and Conditions.

escala88 handles personal data responsibly — collecting only what is necessary, using it only for stated purposes, and protecting it with appropriate technical and organisational measures. We do not sell your personal information to third parties under any circumstances.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for personal information processed through the escala88 platform is the escala88 operating entity. Questions, concerns, or requests relating to personal data may be directed to the escala88 Data Privacy Officer via the contact details provided in Section 16 of this Policy.

3. Personal Data We Collect

escala88 collects the following categories of personal information from its users:

3.1 Registration & Identity Data

• Full legal name as it appears on a government-issued Philippine ID;
• Date of birth (to verify the 21+ age eligibility requirement);
• Philippine mobile number (used as primary contact and for OTP verification);
• Username and encrypted password;
• Email address (if provided during registration).

3.2 KYC & Verification Data

• Copy of a valid Philippine government-issued identification document (e.g., PhilSys card, passport, driver's license, UMID, SSS ID, Voter's ID, PRC ID);
• Selfie or liveness verification image for identity confirmation;
• Proof of address document where required by PAGCOR AML regulations.

3.3 Financial & Transaction Data

• GCash mobile number, Maya account reference, or bank account details used for deposits and withdrawals;
• Deposit and withdrawal transaction records including amounts, timestamps, and payment method identifiers;
• Wagering history including game names, bet amounts, outcomes, and session data.

3.4 Technical & Usage Data

• IP address and approximate geographic location at time of login;
• Device information including device model, operating system version, and browser type;
• Session timestamps, login history, and platform navigation data;
• Cookie identifiers and similar tracking technologies (see Section 10).

3.5 Communications Data

• Records of customer support conversations via live chat;
• Feedback, complaints, or enquiries submitted to escala88 support;
• Responses to escala88 surveys or promotional campaigns where participation is voluntary.

4. How We Collect Your Data

escala88 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion;
• Automatically — through cookies, server logs, and session tracking technology when you access and use the escala88 platform;
• From payment providers — transaction confirmation data from GCash, Maya, BPI, BDO, and other integrated payment channels, limited to what is necessary to process and verify your transactions;
• From identity verification partners — where escala88 uses a third-party KYC verification service, that service may process your identity documents and return a verification result to escala88.

5. How We Use Your Personal Data

escala88 uses personal data collected from players for the following purposes:

• Account management: Creating, maintaining, and securing your escala88 player account;
• Age & identity verification: Confirming that you meet the 21+ eligibility requirement under Philippine law and PAGCOR regulations;
• Transaction processing: Processing deposits and withdrawals through your designated payment method;
• Regulatory compliance: Fulfilling anti-money laundering (AML), counter-terrorism financing (CTF), and KYC obligations under PAGCOR licensing requirements and Philippine law;
• Customer support: Resolving queries, disputes, and technical issues raised through live chat or other support channels;
• Platform improvement: Analysing aggregated usage data to improve game performance, user interface design, and the overall player experience;
• Promotions & personalisation: Sending relevant bonus offers, game recommendations, and promotional notifications — only where you have not opted out of marketing communications;
• Fraud prevention and security: Detecting and preventing fraudulent activity, account takeovers, and prohibited conduct on the platform;
• Responsible gaming: Monitoring for patterns associated with problem gambling to support player welfare programmes.

6. Legal Basis for Processing

escala88 processes personal data on the following lawful bases under the Data Privacy Act of 2012:

• Consent: Where you have explicitly provided consent at the point of data collection, such as during account registration or voluntary participation in marketing campaigns;
• Contractual necessity: Processing required to fulfil the Terms and Conditions governing your escala88 account, including transaction processing and account management;
• Legal obligation: Processing required to comply with PAGCOR regulatory requirements, AML/CTF obligations, NPC directives, and other applicable Philippine laws;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your fundamental rights and freedoms.

7. Sharing of Personal Data

escala88 does not sell, rent, or trade your personal information to any third party for their independent marketing purposes. We may share your personal data only in the following limited circumstances:

• Payment processors: GCash, Maya, BPI, BDO, and other integrated payment providers, solely to the extent necessary to process your deposit and withdrawal transactions;
• KYC verification partners: Third-party identity verification service providers engaged to assist with age and identity verification, under strict data processing agreements;
• Game providers: Aggregated or pseudonymised session data may be shared with game providers (JILI, PG Soft, Evolution, Pragmatic Play, etc.) for the purposes of game performance monitoring and dispute resolution;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine government bodies, where disclosure is required by law or regulatory order;
• Legal proceedings: Where disclosure is required to establish, exercise, or defend legal claims, or to comply with a valid court order issued by a Philippine court;
• Business transfers: In the event of a merger, acquisition, or asset sale affecting the escala88 business, personal data may be transferred to the successor entity, subject to equivalent privacy protections.

8. Data Retention

escala88 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation:

• Active account data: Retained for the duration of the account relationship;
• Transaction and wagering records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with PAGCOR AML record-keeping requirements;
• KYC documents: Retained for a minimum of five (5) years from the date of account closure or the last transaction, whichever is later;
• Customer support records: Retained for two (2) years from the date of the last interaction;
• Closed or terminated accounts: Core identity and transaction data is retained for the legally mandated period and then securely deleted or anonymised.

9. Data Security

escala88 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and escala88 servers;
• Encryption of sensitive data at rest, including stored passwords (hashed and salted) and financial identifiers;
• Role-based access controls limiting internal access to personal data to authorised personnel only;
• Server-side rate limiting and intrusion detection systems to prevent brute-force and unauthorised access attempts;
• Regular security assessments and vulnerability testing of the escala88 platform infrastructure;
• Incident response procedures in the event of a confirmed personal data breach, including notification to the NPC and affected individuals within the timeframes required by the DPA.

While escala88 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for keeping your account credentials confidential and for using a secure, private device when accessing your escala88 account.

10. Cookies & Tracking Technologies

The escala88 platform uses cookies and similar tracking technologies to enhance your browsing experience and to support platform functionality. The categories of cookies used by escala88 are as follows:

• Strictly necessary cookies: Essential for core platform functionality, including session authentication, login persistence, and security features. These cookies cannot be disabled without impairing platform access;
• Functional cookies: Used to remember your preferences, such as language settings and your last-played game category, to personalise your experience;
• Analytics cookies: Aggregated and anonymised data used to understand how players navigate and use the escala88 platform, enabling us to improve design and performance;
• Marketing cookies: Used to display relevant promotional content within the escala88 platform. escala88 does not use third-party advertising networks on its platform.

You may manage cookie preferences through your device browser settings. Disabling strictly necessary cookies may affect your ability to access and use certain features of the escala88 platform.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by escala88:

• Right to be informed: The right to be notified 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 escala88 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data in your escala88 account;
• Right to erasure: The right to request deletion of your personal data where retention is no longer legally required — subject to escala88's mandatory regulatory retention obligations;
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to object: The right to object to processing of your personal data for direct marketing purposes at any time;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, contact the escala88 Data Privacy Officer using the contact details in Section 16. escala88 will respond to verified data subject requests within thirty (30) days of receipt.

12. Children's Privacy

The escala88 platform is strictly intended for individuals who are twenty-one (21) years of age or older, in compliance with Philippine gambling regulations. escala88 does not knowingly collect personal data from individuals under the age of 21. If escala88 becomes aware that personal data has been collected from a person under the eligible age, that account will be immediately suspended, all personal data associated with the account will be deleted, and any funds deposited will be returned subject to verification. Parents or guardians who believe a minor has created an escala88 account should contact escala88 support immediately via live chat.

13. Third-Party Links

The escala88 platform may reference or display the names and logos of third-party game providers and payment services in the context of describing games and payment options available to members. The escala88 Privacy Policy applies solely to data processing activities conducted by escala88. escala88 does not control the privacy practices of third-party game providers, payment processors, or other service partners and accepts no responsibility for their privacy practices. You are encouraged to review the privacy policies of any third-party services you interact with independently of the escala88 platform.

14. Cross-Border Data Transfers

In connection with the provision of game content from international game providers (such as Evolution Gaming, Pragmatic Play, and PG Soft), certain aggregated gameplay session data may be processed on servers located outside of the Philippines. Where such cross-border data transfers occur, escala88 ensures that appropriate contractual safeguards are in place — including data processing agreements with standard contractual clauses — to ensure that your personal data receives an equivalent level of protection to that afforded under the Philippine Data Privacy Act of 2012.

Identifiable personal data (such as your full name, Philippine mobile number, and financial information) is stored on servers located in or accessible from the Philippines and is not transferred cross-border except where required by law or with your explicit consent.

15. Updates to This Privacy Policy

escala88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, or escala88's data processing practices. Material changes to this Policy will be communicated to registered players via their registered Philippine mobile number and by posting an updated version of this Policy on this page, with a revised "Last updated" date at the top. Your continued use of the escala88 platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. escala88 recommends that you review this Policy periodically.

16. Contact — Data Privacy Officer

For any questions, concerns, or requests relating to this Privacy Policy or escala88's personal data processing activities, please contact the escala88 Data Privacy Officer through the following channels:

• Email: [email protected] (Subject line: "Data Privacy Request" — plain text, not a clickable link)
• Live Chat: Available 24/7 via the escala88 platform — indicate "Data Privacy" as the subject of your query
• Response time: Written data privacy requests will be acknowledged within five (5) business days and fully addressed within thirty (30) calendar days

If you are not satisfied with escala88's response to your data privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines.