tracksino Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how tracksino ("tracksino," "we," "us," or "our"), the operator of the online gaming platform accessible at tracksino.cc, collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who register for or use the tracksino platform.

tracksino is committed to protecting the privacy and personal data of all its players, particularly those based in the Philippines. This Policy is drafted in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations ("IRR"), as overseen by the National Privacy Commission ("NPC").

By registering an account on tracksino, completing the tracksino login process, or otherwise using any feature of the 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. If you do not agree with any part of this Policy, you must discontinue use of the tracksino platform immediately.

2 Personal Data We Collect

tracksino collects the following categories of personal data from players. The specific data collected depends on how you interact with the platform and the services you use.

2.1 Identity and Registration Data

• Full legal name as it appears on your government-issued identification
• Date of birth (used to verify that you meet the 21+ age requirement)
• Gender
• Nationality and country of residence
• Government-issued identification number (e.g., Philippine passport number, driver's license number, SSS/UMID/PhilSys ID number)
• Username and encrypted password used for tracksino login

2.2 Contact Data

• Email address
• Mobile phone number
• Residential address (including barangay, city/municipality, province, and postal code)

2.3 Financial and Transaction Data

• Payment method details (e.g., GCash account name and number, PayMaya account details, BPI/BDO/Metrobank account details, Visa/Mastercard card details — stored in tokenized form only)
• Deposit and withdrawal history
• Transaction amounts in Philippine Peso (₱)
• Bonus and promotional credit history

2.4 KYC Verification Documents

• Copies of government-issued photo identification documents
• Proof of address documents (e.g., utility bills, bank statements)
• Proof of payment method ownership
• Any additional documentation requested as part of enhanced due diligence

2.5 Gaming and Behavioral Data

• Game history, bet amounts, win/loss records, and session durations
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
• Platform navigation patterns and feature usage data
• Customer support interaction records

2.6 Technical and Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type and version
• Unique device identifiers
• Session timestamps and access logs
• Cookie identifiers and similar tracking technology data (see Section 11)

3 How We Collect Your Data

tracksino collects personal data through the following means:

• Directly from you — when you complete the registration form, submit KYC documents, make deposits or withdrawals, contact customer support, or update your account profile.
• Automatically — when you access the tracksino platform, our servers and analytics tools automatically record technical and device data, including your IP address, browser type, and session activity.
• Through cookies and similar technologies — as described in Section 11 of this Policy.
• From third-party payment processors — when you make a deposit or withdrawal via GCash, PayMaya, BPI, BDO, Metrobank, or card networks, we receive transaction confirmation data from those providers.
• From identity verification providers — tracksino may use third-party KYC and anti-money laundering (AML) service providers to verify the identity documents you submit. These providers may return verification results and risk scores to tracksino.
• From publicly available sources — where permitted by law, tracksino may supplement your profile with information from publicly available government databases or sanctions lists for AML compliance purposes.

4 How We Use Your Personal Data

tracksino uses the personal data it collects for the following purposes:

tracksino will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable Philippine law.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, tracksino processes your personal data on the following legal bases:

• Contractual necessity — processing is necessary to perform the contract between you and tracksino (i.e., to provide the gaming services you have registered for, process your transactions, and manage your account).
• Legal obligation — processing is necessary for tracksino to comply with applicable Philippine laws and regulations, including KYC/AML obligations, PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate interests — processing is necessary for tracksino's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and improving the quality of our services, provided those interests are not overridden by your rights and interests.
• Consent — where tracksino relies on your consent as the legal basis for processing (e.g., for sending promotional communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

tracksino 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 only to the extent necessary for the purposes described in this Policy:

• Payment processors and e-wallet providers (e.g., GCash, PayMaya, BPI, BDO, Metrobank, Visa/Mastercard networks) — to process your deposits and withdrawals.
• KYC and identity verification providers — to verify your identity documents and conduct AML screening as required by applicable regulations.
• Game software providers and platform technology partners — to deliver the games and platform features you use on tracksino. These providers process data only on tracksino's instructions and are bound by data processing agreements.
• Customer support platform providers — to facilitate the delivery of customer support services to tracksino players.
• Regulatory and law enforcement authorities — where tracksino is required by law, court order, or regulatory directive to disclose your personal data, including to PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), or other competent Philippine authorities.
• Fraud prevention and security service providers — to detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the tracksino platform.
• Professional advisers — including lawyers, auditors, and accountants, where necessary for tracksino to obtain professional advice or in connection with legal proceedings.

All third parties with whom tracksino shares personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

7 International Data Transfers

Some of tracksino's third-party service providers may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that afforded under Philippine law, tracksino will implement appropriate safeguards to protect your data, such as contractual clauses approved by the National Privacy Commission or other legally recognized transfer mechanisms.

By using the tracksino platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines in accordance with this Policy and applicable law.

8 Data Retention

tracksino retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law and regulatory obligations. 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 after account closure, in accordance with AML record-keeping requirements under Philippine law.
• Transaction and financial data — retained for a minimum of five (5) years from the date of the transaction, as required by applicable tax and AML regulations.
• KYC documents — retained for a minimum of five (5) years after the end of the business relationship, or longer if required by a specific regulatory directive.
• Gaming and behavioral data — retained for the duration of your account and for up to two (2) years after account closure for dispute resolution and responsible gaming monitoring purposes.
• Technical and device data — retained for up to twelve (12) months from the date of collection for security and fraud prevention purposes.
• Customer support records — retained for up to three (3) years from the date of the interaction.

When personal data is no longer required for the purposes for which it was collected and no legal obligation requires its continued retention, tracksino will securely delete or anonymize the data.

9 Security Measures

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

• SSL/TLS encryption for all data transmitted between your device and the tracksino platform
• Encryption at rest for sensitive data stored on tracksino servers, including payment method tokens and KYC documents
• Access controls limiting access to personal data to authorized tracksino personnel on a need-to-know basis
• Multi-factor authentication options for player accounts to protect against unauthorized tracksino login attempts
• Regular security assessments and penetration testing of the tracksino platform
• Incident response procedures for detecting, reporting, and responding to personal data breaches in accordance with NPC notification requirements

10 Your Data Privacy Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by tracksino. To exercise any of these rights, please contact the tracksino Data Protection Officer as described in Section 14.

tracksino will respond to all data privacy rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case you will be notified of the extension and the reasons for it.

11 Cookies & Similar Technologies

tracksino uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file placed on your device when you visit the tracksino website. The following categories of cookies are used:

• Strictly necessary cookies — essential for the tracksino platform to function. These include session cookies that maintain your logged-in state after tracksino login and security cookies that help protect against fraudulent activity. These cookies cannot be disabled.
• Functional cookies — used to remember your preferences and settings on the tracksino platform, such as your preferred language and responsible gaming tool configurations.
• Analytics cookies — used to collect aggregated, anonymized data about how players use the tracksino platform, helping us identify areas for improvement. This data does not identify individual players.
• Security and fraud prevention cookies — used to detect and prevent fraudulent activity, including the use of multiple accounts and automated bot activity.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the tracksino platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the platform.

12 Minors and Age Restriction

If tracksino becomes aware that personal data has been collected from an individual under the age of 21, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the tracksino platform, please contact our support team immediately.

Parents and guardians are encouraged to use parental control tools and to monitor the online activities of minors in their care to prevent access to age-restricted platforms such as tracksino.

13 Changes to This Privacy Policy

tracksino 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. When material changes are made to this Policy, tracksino will notify registered players by email or through a prominent notice on the platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the tracksino platform following notification of changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with the revised Policy, you must discontinue use of the platform and may request account closure in accordance with the Terms & Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how tracksino protects your personal data.

14 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by tracksino, please contact our Data Protection Officer (DPO) or customer support team using the details below.

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

For responsible gaming concerns, including self-exclusion requests, please visit our Responsible Gaming page.