gokens Privacy Policy – Protecting Filipino Player Data & Privacy

Last Updated: January 15, 2024

1. Introduction and Scope

This Privacy Policy ("Policy") describes how gokens ("Company," "we," "us," or "our") collects, uses, processes, stores, shares, and protects personal information obtained from users ("User," "Player," "you," or "your") of the gokens online casino and sports betting platform (the "Platform"). This Policy applies to all personal data collected through our website, mobile applications, customer support channels, and any other services we provide.

By registering an account with gokens, accessing the Platform, or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with any provision of this Policy, you must immediately cease using the gokens Platform and refrain from providing any personal information.

gokens is committed to complying with the Republic of the Philippines Data Privacy Act of 2012 (R.A. 10173), its implementing rules and regulations, and all other applicable data protection laws governing the processing of personal information of Filipino citizens and residents.

2. Information We Collect

2.1 Personal Information Provided by You

When you register a gokens account, make deposits, request withdrawals, or interact with our customer support, we collect the following categories of personal information:

• Identity Information: Full legal name, date of birth, gender, nationality, government-issued identification numbers (e.g., Philippine passport number, driver's license number, or other valid ID);
• Contact Information: Philippine mobile phone number, email address, residential address, postal code;
• Financial Information: Payment method details including GCash account information, Maya account information, bank account numbers (BPI, BDO, Metrobank, etc.), credit/debit card information, transaction history, deposit and withdrawal records;
• Account Credentials: Username, password (stored in encrypted form), security questions and answers, two-factor authentication preferences;
• Verification Documents: Copies of government-issued IDs, utility bills, bank statements, selfies or photographs for identity verification purposes.

2.2 Information Automatically Collected

When you access or use the gokens Platform, we automatically collect certain technical and usage information through cookies, web beacons, log files, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address, advertising ID);
• Connection Data: IP address, internet service provider, geographic location (based on IP address), time zone settings;
• Usage Data: Pages visited, games played, bets placed, time spent on the Platform, clickstream data, referring URLs, search queries within the Platform;
• Communication Records: Chat logs with customer support agents, email correspondence, phone call recordings (with your consent where required by law).

2.3 Information from Third-Party Sources

In certain circumstances, gokens may obtain information about you from third-party sources to verify your identity, prevent fraud, or comply with legal obligations:

• Credit reference agencies and fraud prevention services;
• Payment processors (GCash, Maya, GrabPay, banks, credit card networks);
• Marketing and analytics partners;
• Publicly available databases and social media platforms (where you have consented to share such information).

3. How We Use Your Information

3.1 Account Management and Service Provision

gokens uses your personal information to create and manage your account, process your registration, verify your identity, facilitate deposits and withdrawals, maintain transaction records, and provide you with access to our casino games, sports betting markets, and other gaming services. This processing is necessary for the performance of our contract with you and to fulfill our legal obligations.

3.2 Security and Fraud Prevention

We process your personal information to detect, investigate, and prevent fraudulent activity, money laundering, underage gambling, bonus abuse, collusion, and other prohibited conduct. This includes monitoring betting patterns, analyzing device and IP information, conducting background checks, and sharing information with fraud prevention services. This processing is necessary to protect our legitimate interests and comply with anti-money laundering regulations.

3.3 Compliance with Legal Obligations

gokens uses your personal data to comply with legal and regulatory requirements, including but not limited to:

• Verifying your age and eligibility to participate in online gambling activities (21+ requirement);
• Reporting suspicious transactions to the Anti-Money Laundering Council (AMLC) of the Philippines;
• Responding to lawful requests from government authorities, law enforcement agencies, and courts;
• Maintaining records for tax reporting purposes as required by the Bureau of Internal Revenue (BIR);
• Implementing responsible gaming measures and enforcing self-exclusion requests.

3.4 Customer Support and Communication

We use your contact information to respond to your inquiries, provide technical assistance, resolve disputes, send you account notifications (e.g., deposit confirmations, withdrawal updates, security alerts), and communicate important changes to our Terms and Conditions or Privacy Policy. This processing is necessary to fulfill our contractual obligations and maintain a high standard of customer service.

3.5 Marketing and Promotional Communications

With your consent, gokens may use your email address, mobile phone number, and usage data to send you promotional offers, bonus notifications, newsletters, and marketing messages about our products and services. You may opt out of marketing communications at any time by clicking the "unsubscribe" link in our emails, adjusting your communication preferences in your account settings, or contacting our customer support team.

3.6 Platform Improvement and Analytics

gokens uses aggregated and anonymized data to analyze Platform performance, understand player behavior, improve user experience, develop new features, conduct market research, and optimize our gaming offerings. This processing is based on our legitimate interest in enhancing the quality and functionality of the gokens Platform.

4. How We Share Your Information

4.1 Service Providers and Business Partners

gokens shares your personal information with trusted third-party service providers who assist us in operating the Platform, processing payments, verifying identities, preventing fraud, providing customer support, conducting marketing campaigns, and performing data analytics. These service providers include:

• Payment processors (GCash, Maya, GrabPay, Philippine banks, international payment gateways);
• Identity verification and KYC (Know Your Customer) service providers;
• Cloud hosting and data storage providers;
• Customer relationship management (CRM) platforms;
• Email and SMS communication services;
• Marketing and advertising partners;
• Fraud detection and prevention services;
• Game providers and sports betting data suppliers.

All service providers are contractually obligated to protect your personal information, use it only for the purposes specified by gokens, and comply with applicable data protection laws. We conduct due diligence to ensure that our partners maintain adequate security measures.

4.2 Legal and Regulatory Authorities

gokens may disclose your personal information to government agencies, regulatory bodies, law enforcement authorities, courts, and other public officials when required by law or in response to valid legal process, including:

• Compliance with court orders, subpoenas, or search warrants;
• Reporting to the Anti-Money Laundering Council (AMLC) as mandated by Philippine AML laws;
• Cooperation with criminal investigations or prosecution of illegal activities;
• Enforcement of our Terms and Conditions and protection of our legal rights;
• Protection of the safety, property, or rights of gokens, our users, or the public.

4.3 Business Transfers

In the event that gokens undergoes a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity or acquiring party. We will notify you via email and/or prominent notice on the Platform before your personal information is transferred and becomes subject to a different privacy policy.

4.4 With Your Consent

In circumstances not covered by this Policy, gokens will seek your explicit consent before sharing your personal information with third parties. You have the right to withdraw such consent at any time by contacting our Data Protection Officer.

5. Data Security Measures

gokens implements robust technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• Encryption: All data transmitted between your device and gokens servers is encrypted using 256-bit SSL/TLS protocols. Passwords are hashed and salted using industry-standard cryptographic algorithms. Sensitive financial data is encrypted at rest.
• Access Controls: Access to personal data is restricted to authorized personnel on a need-to-know basis. All employees and contractors with access to personal information undergo background checks and sign confidentiality agreements.
• Firewalls and Intrusion Detection: Our servers are protected by enterprise-grade firewalls, intrusion detection systems, and real-time security monitoring to prevent unauthorized access and cyberattacks.
• Regular Security Audits: gokens conducts periodic security assessments, vulnerability scans, and penetration testing to identify and remediate potential weaknesses in our systems.
• Data Minimization: We collect only the personal information necessary to provide our services and delete or anonymize data that is no longer needed for legitimate business purposes.
• Incident Response Plan: In the event of a data breach, gokens has established procedures to contain the incident, assess the impact, notify affected individuals, and report the breach to the National Privacy Commission (NPC) as required by Philippine law.

6. Data Retention

gokens retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods vary depending on the type of information and applicable legal requirements:

• Account Information: Retained for the duration of your active account and for a minimum of five (5) years after account closure to comply with anti-money laundering and tax record-keeping requirements.
• Transaction Records: Maintained for at least five (5) years from the date of the transaction as required by Philippine financial regulations.
• Communication Records: Customer support chat logs, emails, and call recordings are retained for up to three (3) years for quality assurance and dispute resolution purposes.
• Marketing Consents: Retained until you withdraw consent or for two (2) years of inactivity, after which we will seek renewed consent to continue sending marketing communications.
• Verification Documents: Government-issued IDs and other verification documents are retained for the duration of your account and up to seven (7) years after closure to comply with regulatory obligations.
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After the applicable retention period, gokens will securely delete or anonymize your personal information in accordance with our data disposal procedures. Anonymized data that cannot be used to identify you may be retained indefinitely for statistical and analytical purposes.

7. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal information:

• Right to Access: You may request confirmation of whether gokens processes your personal data and obtain a copy of such data in a commonly used electronic format.
• Right to Rectification: You may request correction of inaccurate or incomplete personal information. You can update most information directly through your account settings.
• Right to Erasure: You may request deletion of your personal information when it is no longer necessary for the purposes for which it was collected, subject to legal retention requirements.
• Right to Object: You may object to the processing of your personal information for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: You may request transfer of your personal information to another service provider in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw such consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe gokens has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] or through the contact information provided in Section 11 below. We will respond to your request within fifteen (15) days as required by Philippine law. Certain requests may require identity verification to protect your personal information from unauthorized access.

8. Cookies and Tracking Technologies

gokens uses cookies, web beacons, pixel tags, and similar technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device that help us recognize you, remember your preferences, maintain your session, and collect usage statistics.

We use the following types of cookies:

• Essential Cookies: Required for the Platform to function properly, including session management, security features, and account authentication. These cookies cannot be disabled.
• Performance Cookies: Collect information about how you use the Platform, such as pages visited and errors encountered, to help us improve functionality and user experience.
• Functional Cookies: Remember your preferences (e.g., language settings, display options) to provide enhanced features and personalized content.
• Advertising Cookies: Track your browsing activity to deliver targeted advertisements and measure the effectiveness of marketing campaigns. These cookies are subject to your consent.

You can manage your cookie preferences through your browser settings. However, disabling certain cookies may limit your ability to use some features of the gokens Platform. For more information about cookies and how to control them, visit your browser's help documentation or www.allaboutcookies.org.

9. International Data Transfers

While gokens primarily serves Filipino players and maintains servers within the Philippines, certain service providers and business partners may be located outside the Philippines. When we transfer your personal information to countries that do not provide an adequate level of data protection as recognized by the National Privacy Commission, we implement appropriate safeguards such as:

• Contractual data protection clauses based on international standards;
• Verification that the recipient country has been recognized by the NPC as providing adequate data protection;
• Obtaining your explicit consent where required by law;
• Implementing technical and organizational measures to protect data during transfer and storage.

gokens ensures that all international data transfers comply with the Data Privacy Act of 2012 and that your personal information receives the same level of protection regardless of where it is processed.

10. Children's Privacy

The gokens Platform is intended for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21 years of age. If you are under 21, you are not permitted to register an account or use our services.

If we become aware that we have inadvertently collected personal information from a person under 21 years of age, we will take immediate steps to delete such information from our systems and close any associated account. Parents or guardians who believe their child has provided personal information to gokens should contact us immediately at [email protected].

11. Changes to This Privacy Policy

gokens reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. The most current version will always be available on the gokens website with the "Last Updated" date displayed at the top of the document.

Material changes that significantly affect your privacy rights will be communicated to you via email or prominent notice on the Platform at least thirty (30) days before the changes take effect. Your continued use of the gokens Platform after the effective date of any amendments constitutes acceptance of the updated Privacy Policy.

12. Contact Information and Data Protection Officer

If you have questions, concerns, or complaints regarding this Privacy Policy, our data processing practices, or wish to exercise your privacy rights, please contact:

• Data Protection Officer
• Email: [email protected]
• Customer Support: [email protected]
• Live Chat: Available 24/7 through the gokens website and mobile app

We are committed to addressing your privacy concerns promptly and transparently. For data subject access requests or complaints, we will respond within the timeframes mandated by the Philippine Data Privacy Act.

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe gokens has violated your data privacy rights. Contact details for the NPC are available at www.privacy.gov.ph.