d10d Privacy Policy – How We Collect, Use, and Protect Your Personal Data

1. Scope & Application

This Privacy Policy applies to all personal data collected and processed by d10d ("d10d," "we," "us," "our") in connection with the registration, operation, and maintenance of user accounts on the d10d platform, including its website, mobile browser interface, games, payment services, customer support functions, and promotional activities. It applies to all users who access d10d from the Philippines or who are Philippine nationals or residents accessing d10d from abroad.

This Policy does not apply to the data practices of third-party game providers, payment processors, or other external service providers, each of which operates under its own privacy policy. d10d recommends that users review the privacy policies of any third-party services they interact with.

2. Data We Collect

d10d collects personal data in the following categories:

• Registration Data: Full legal name, date of birth, email address, mobile number, and chosen username collected when you create a d10d account.
• Identity Verification (KYC) Data: Government-issued identification (e.g., Philippine passport, SSS ID, driver's licence), proof of address, and source of funds documentation collected during verification processes required by applicable law or requested in connection with withdrawal processing.
• Financial Data: Payment method details (e.g., GCash mobile number, Maya account reference, bank account details), transaction amounts, deposit and withdrawal histories. d10d does not store full card numbers or complete banking credentials.
• Usage Data: IP address, device type, operating system, browser type, session duration, pages visited, game history, wagering patterns, and login timestamps, collected automatically when you use the platform.
• Communications Data: Records of support conversations, emails, and chat transcripts related to your d10d account.
• Responsible Gaming Data: Self-imposed limit settings, self-exclusion requests, and related account annotations.

3. How We Use Your Data

d10d processes your personal data for the following purposes:

• Creating and managing your d10d account, including identity verification and age verification (21+ requirement).
• Processing deposits, withdrawals, and other financial transactions on the platform.
• Providing customer support services, including resolving account queries and disputes.
• Complying with legal obligations, including anti-money laundering (AML), counter-terrorism financing (CTF), and PAGCOR regulatory requirements.
• Detecting and preventing fraud, unauthorized access, bonus abuse, and other prohibited conduct as described in the d10d Terms & Conditions.
• Administering bonuses, promotions, and loyalty rewards programs.
• Personalizing your gaming experience and providing relevant promotional communications where you have consented to receive them.
• Enforcing responsible gaming obligations, including monitoring for signs of problem gambling and processing self-exclusion requests.
• Improving platform performance, security, and user experience through aggregated and anonymized analytics.

4. Legal Basis for Processing

d10d processes personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012 (RA 10173):

• Contractual Necessity: Processing required to enter into and perform the contract between you and d10d, including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML/CTF obligations, PAGCOR licensing requirements, and age verification mandates.
• Legitimate Interests: Processing for fraud prevention, platform security, and the prevention of prohibited conduct, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

d10d does not sell your personal data. 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: GCash, Maya, BPI, BDO, UnionBank, and other payment service providers, to process deposits and withdrawals. Each processor handles your financial data under its own privacy policy and security framework.
• Game Content Providers: Licensed game developers and live casino operators whose content is hosted on d10d, to the extent required for game functionality and fair play monitoring.
• Identity Verification Services: Third-party KYC service providers engaged to assist with age and identity verification in compliance with regulatory requirements.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, anti-money laundering authorities, and law enforcement agencies, where disclosure is required by law, court order, or regulatory direction.
• Professional Advisors: Legal, accounting, and compliance professionals engaged by d10d, subject to professional confidentiality obligations.

Any third parties with whom d10d shares personal data are required to process that data only for the specified purpose and in accordance with applicable data protection law.

6. Data Retention

d10d retains personal data for the following periods, or longer where required by law:

• Account Data: Retained for the duration of the account relationship and for five (5) years following account closure, in compliance with AML record-keeping requirements.
• KYC Documentation: Retained for five (5) years from the date of collection or the date of the last transaction, whichever is later.
• Transaction Records: Retained for five (5) years from the date of the transaction.
• Support Communications: Retained for two (2) years from the date of the interaction.
• Usage Logs: Retained for twelve (12) months from collection in identifiable form, after which they may be retained in anonymized, aggregated form.

Upon expiry of the applicable retention period, d10d will securely delete or anonymize your personal data unless retention is required by a continuing legal obligation.

7. Data Security

d10d implements appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data in transit between your device and d10d servers.
• Encryption of sensitive data at rest, including financial and identity verification records.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments.
• Multi-factor authentication for administrative access to d10d systems.
• Staff training on data protection obligations and secure data handling practices.

Despite these measures, no data transmission over the internet or electronic storage system is completely secure. d10d cannot guarantee absolute security but is committed to promptly addressing any identified vulnerabilities and notifying affected parties in the event of a confirmed breach, as required by RA 10173.

8. Cookies & Tracking Technologies

d10d uses cookies and similar tracking technologies on its platform for the following purposes:

• Essential Cookies: Required for core platform functionality, including maintaining your login session and remembering your preferences. These cannot be disabled without impairing platform use.
• Analytics Cookies: Used to collect aggregated, anonymized data about how users navigate the platform, helping d10d identify and fix usability issues and improve the gaming experience.
• Preference Cookies: Used to remember your settings and language preferences across sessions.

You may manage non-essential cookie preferences through your browser settings. Disabling certain cookies may affect platform functionality. d10d does not use third-party advertising cookies or cross-site tracking cookies.

9. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, registered d10d users who are data subjects have the following rights with respect to their personal data:

• Right to be Informed: The right to be notified of how your personal data is collected and used — fulfilled by this Privacy Policy.
• Right of Access: The right to request a copy of the personal data d10d holds about you.
• Right to Correction: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of personal data where it is no longer necessary for the purpose for which it was collected, subject to overriding legal obligations.
• Right to Object: The right to object to the processing of your personal data on the basis of legitimate interests, particularly for direct marketing purposes.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Damages: The right to claim compensation for damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized processing of personal data.

To exercise any of the above rights, please contact d10d's Data Privacy Officer via the contact details set out in Section 12. d10d will respond to all verified data subject requests within thirty (30) days of receipt.

10. Children & Minors

d10d does not knowingly collect personal data from individuals under 21 years of age. The d10d platform is strictly for adults aged 21 and above in compliance with Philippine gaming law. If d10d becomes aware that personal data has been collected from a minor, the relevant account will be immediately suspended, the data deleted, and any deposits returned where feasible in accordance with d10d's Terms & Conditions.

If you believe that a minor has created a d10d account or provided personal data to d10d, please contact our support team immediately via live chat so that the matter can be addressed promptly.

11. Amendments to This Policy

d10d reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered users via email or platform notification at least seven (7) days before the changes take effect, except where immediate amendment is required by law or regulatory direction. The "Last Updated" date at the top of this Policy will reflect the effective date of the most recent revision. Your continued use of d10d after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

12. Contact & Data Privacy Officer

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or need to report a potential privacy concern, please contact d10d's Data Privacy Officer through the following channels:

• Live Chat: Available 24/7 on the d10d platform. Average response time under two minutes.
• Email: [email protected] — please include "Privacy Request" in the subject line.

d10d is committed to resolving all privacy-related queries and complaints in a timely and transparent manner. If you are not satisfied with d10d's response to a privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.