twinkaboo Casino — Privacy Policy

twinkaboo ("we," "us," "our") operates the online casino platform available at twinkaboo.vip and is committed to protecting the privacy and personal data of all registered Players and visitors. This Privacy Policy ("Policy") describes how twinkaboo collects, uses, stores, shares, and protects personal data in connection with the twinkaboo Platform.

This Policy applies to all personal data processed by twinkaboo in connection with your use of the Platform, whether you are a registered Player, a visitor browsing the Platform without an account, or a person who contacts twinkaboo for support or inquiries.

By using the twinkaboo Platform or registering an Account, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree to this Policy, you must discontinue use of the Platform.

twinkaboo is the Data Controller for personal data collected through the twinkaboo Platform. As Data Controller, twinkaboo determines the purposes and means of processing your personal data. twinkaboo is a PAGCOR-licensed operator subject to the jurisdiction of the Republic of the Philippines.

For all data privacy matters, including requests to exercise your data subject rights, you may contact our Data Protection Officer (DPO) at: [email protected] (plain text — not a clickable link).

When you create a twinkaboo Account, we collect: full legal name, date of birth, Philippine mobile number, email address, and a chosen password (stored only in hashed form — never in plaintext).

As required by PAGCOR regulations and the Anti-Money Laundering Act (AMLA), we collect copies of government-issued identification documents (e.g., PhilSys National ID, driver's license, passport, UMID) and selfie photographs for identity verification prior to processing withdrawals.

We collect records of deposit and withdrawal transactions including payment method identifiers (e.g., GCash registered number, bank account number), transaction amounts in Philippine Pesos (₱), dates, and processing status. We do not store full bank account credentials or GCash PINs.

We maintain records of your gaming activity on the Platform, including: games played, bet amounts, game outcomes, session durations, and bonus usage history. This data is required for PAGCOR compliance, dispute resolution, and responsible gaming monitoring.

When you access the Platform, we automatically collect certain technical data including: IP address, browser type and version, operating system, device type, screen resolution, referring URL, and pages visited. This data is used for security monitoring, fraud detection, and Platform optimization.

If you contact twinkaboo support via live chat or email, we retain records of that correspondence, including the content of messages and the date and time of communication, for quality assurance and dispute resolution purposes.

twinkaboo collects personal data through the following means:

• Directly from you — when you register an Account, complete KYC verification, make deposits or withdrawal requests, contact support, or respond to promotions;
• Automatically — through cookies, server logs, and similar tracking technologies when you access and use the Platform;
• From third-party payment processors — GCash, Maya, BPI, BDO, Metrobank, and other payment providers share transaction confirmation data with twinkaboo to facilitate deposits and withdrawals;
• From identity verification services — where third-party KYC service providers are used to verify identity documents, they share verification results (not the raw document images) with twinkaboo.

twinkaboo processes your personal data on the following legal bases under the Data Privacy Act of 2012 (RA 10173):

• Contractual necessity — processing required to provide the Platform and fulfil our obligations under the Terms and Conditions, including account management, payment processing, and game provision;
• Legal obligation — processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), and other applicable Philippine laws;
• Legitimate interests — processing for fraud prevention, security monitoring, and Platform improvement, where such interests are not overridden by your data protection rights;
• Consent — processing for marketing communications, where we have obtained your explicit consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

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

• To create, maintain, and manage your twinkaboo Account;
• To verify your identity (KYC) and confirm your eligibility to use the Platform (21+ age requirement);
• To process deposits and withdrawal requests through GCash, Maya, and other payment channels;
• To deliver the games, promotions, and other services available on the twinkaboo Platform;
• To comply with PAGCOR licensing requirements, including game monitoring, AML reporting, and responsible gaming obligations;
• To detect, investigate, and prevent fraud, money laundering, unauthorized account access, and other prohibited activities;
• To provide customer support and resolve disputes;
• To send service-related communications (account confirmations, security alerts, withdrawal notifications) to your registered mobile number or email;
• To send promotional communications where you have provided consent;
• To analyze Platform usage data to improve the twinkaboo product experience.

twinkaboo does not sell your personal data. We share personal data only in the following circumstances:

Transaction data is shared with GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, and other payment processors strictly as required to process your deposit and withdrawal transactions.

twinkaboo is required to share player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities upon lawful request or as mandated by applicable regulations, including mandatory AML reporting obligations.

Certain game providers (e.g., JILI Games, Pragmatic Play) may receive limited technical data (such as a player session token) necessary to operate their games within the twinkaboo Platform. These providers do not receive your full personal identity data.

Where third-party identity verification or fraud detection services are used, personal data necessary for those verification processes is shared under data processing agreements that require those providers to process data solely on twinkaboo's instructions and in accordance with the Data Privacy Act.

In the event of a merger, acquisition, or transfer of all or substantially all of twinkaboo's business, player data may be transferred to the acquiring entity, subject to equivalent data protection obligations and notification to affected Players.

8.1 The twinkaboo Platform uses cookies and similar tracking technologies (such as local storage and session identifiers) to operate the Platform, maintain your login session, detect fraud, and analyze usage patterns.

8.2 The following categories of cookies are used:

• Essential cookies — required for the Platform to function, including session management and security tokens. These cannot be disabled without affecting Platform functionality.
• Analytical cookies — used to collect aggregated, anonymized data on how visitors use the Platform to help us improve performance and user experience.
• Security cookies — used for fraud detection, bot prevention, and suspicious activity monitoring.

8.3 twinkaboo does not use advertising or retargeting cookies that track you across third-party websites. Your browser settings allow you to block or delete cookies; however, blocking essential cookies will impair Platform functionality.

9.1 twinkaboo retains personal data for the following periods:

• Active Account data — retained for the duration of your Account and for five (5) years following Account closure, as required by PAGCOR and AMLA record-keeping obligations;
• KYC documents — retained for five (5) years following Account closure or the last transaction date, whichever is later, in compliance with AMLA requirements;
• Transaction records — retained for five (5) years following each transaction, in compliance with AMLA requirements;
• Support communications — retained for two (2) years from the date of the last communication;
• Technical/device data — retained for twelve (12) months from collection for security and fraud analysis purposes.

9.2 Data subject to ongoing legal proceedings, regulatory investigations, or dispute resolution will be retained for the duration of those proceedings regardless of the standard retention period.

10.1 twinkaboo implements industry-standard technical and organizational security measures to protect personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• TLS 1.2/1.3 encryption for all data transmitted between your browser and twinkaboo's servers;
• AES-256 encryption for sensitive data stored at rest;
• Password hashing using bcrypt — plaintext passwords are never stored;
• Two-factor authentication (2FA) available to all Players and required for all administrative access;
• Regular security penetration testing and vulnerability assessments;
• Strict access controls limiting personal data access to authorized personnel on a need-to-know basis;
• 24/7 security monitoring and automated anomaly detection.

10.2 In the event of a personal data breach that is likely to result in risk to your rights and freedoms, twinkaboo will notify affected Players and the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by twinkaboo:

• Right to be informed — the right to be told what personal data twinkaboo holds about you and how it is processed;
• Right of access — the right to request a copy of the personal data twinkaboo holds about you;
• Right to rectification — the right to request correction of inaccurate or incomplete personal data;
• Right to erasure — the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations;
• Right to object — the right to object to processing based on legitimate interests, including profiling for direct marketing;
• Right to data portability — the right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint — the right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, contact twinkaboo's DPO at: [email protected] (plain text — not a clickable link). twinkaboo will respond to all verified data subject requests within thirty (30) days.

The twinkaboo Platform is strictly for individuals aged 21 years and above. twinkaboo does not knowingly collect personal data from individuals under 21 years of age. If twinkaboo becomes aware that personal data has been collected from an underage individual, such data will be deleted immediately and the associated Account closed. Parents or guardians who believe their child has registered an Account should contact twinkaboo support immediately.

13.1 Certain game providers, technology infrastructure providers, and security service providers used by twinkaboo may process data in jurisdictions outside the Philippines. In such cases, twinkaboo ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act.

13.2 Cross-border transfers of personal data by twinkaboo are made only to countries with an adequate level of data protection, or subject to binding contractual clauses that impose data protection obligations equivalent to those applicable in the Philippines.

14.1 twinkaboo reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material updates will be communicated via a prominent notice on the Platform and, where practicable, via SMS or email to your registered contact details.

14.2 The "Last Updated" date at the top of this Policy indicates the date of the most recent revision. Continued use of the twinkaboo Platform following the effective date of an updated Policy constitutes your acceptance of the revised terms.

For all privacy-related inquiries, data subject requests, or to contact twinkaboo's Data Protection Officer:

Email: [email protected] (plain text — not a clickable link)

twinkaboo's support team is available 24/7 via live chat on the Platform. For data privacy complaints not resolved to your satisfaction by twinkaboo, you may file a complaint with the National Privacy Commission (NPC) of the Philippines.