Privacy Policy – How Primo Game Protects Your Personal Data

1 Who We Are

Primo Game is the operator of primogame.net, an online betting and gaming platform serving players in the Philippines. As the data controller, Primo Game determines the purposes and means of processing the personal data of its registered players and website visitors. All references to "Primo Game," "we," "us," or "our" in this Privacy Policy refer to the operator of the primogame.net platform.

Our designated Data Protection Officer (DPO) oversees all privacy compliance activities and serves as the primary point of contact for data-related enquiries and complaints from Filipino players. Contact details for our DPO are provided in Section 14 of this policy.

2 Personal Data We Collect

The categories of personal data Primo Game collects about players and website visitors are set out in the table below. We collect only what is necessary for the purposes stated in this policy.

3 How We Collect Your Data

Primo Game collects personal data through three main channels:

3.1 Data You Provide Directly

This is information you actively submit to us — when you register an account, complete KYC verification, make a deposit, contact our support team, or respond to a survey. You are always in control of what you provide through these channels.

3.2 Data Collected Automatically

When you visit and use the Primo Game platform, we automatically collect certain technical data. This includes your IP address, the device and browser you're using, pages visited, time spent on the platform, and error logs. This data is primarily used to maintain platform security and improve user experience. See Section 7 for our cookies policy.

3.3 Data from Third Parties

Primo Game may receive limited personal data from third-party sources in specific circumstances, including:

• Identity verification service providers during the KYC process (such as document authentication services).
• Payment processors confirming the status of deposit or withdrawal transactions.
• Fraud prevention and anti-money laundering screening services required under regulatory obligations.

4 Why We Use Your Data

Primo Game processes your personal data for specific, legitimate purposes. Here is a plain-language explanation of what we do with your information and why:

• Account setup and management: To create and maintain your Primo Game account, including authenticating your identity at login and managing your account settings.
• Identity verification (KYC): To confirm that you meet the age and eligibility requirements under Philippine gaming regulations, and to prevent the use of false identities on the platform.
• Payment processing: To credit deposits to your Real Money Balance, process withdrawal requests, and maintain accurate financial records for your account and for regulatory reporting.
• Game and betting services: To operate the sports betting, fishing games, live casino, and other gaming services you access on the Primo Game platform, including recording your wagers and settling your bets correctly.
• VIP Club management: To track your loyalty points, determine your VIP tier, calculate and credit monthly cashback, and administer tier-specific benefits.
• Promotions and bonuses: To determine your eligibility for promotions, credit bonus funds, track rollover progress, and ensure fair use of promotional offers.
• Customer support: To respond to your queries, resolve account issues, process complaints, and maintain records of our communications with you.
• Fraud prevention and security: To detect and prevent fraudulent activity, money laundering, underage gambling, and abuse of our platform or promotional offers.
• Regulatory compliance: To fulfil reporting obligations to relevant Philippine regulatory authorities and to cooperate with lawful requests from law enforcement agencies.
• Platform improvement: To analyse usage patterns (in anonymised or aggregated form where possible) and improve the technical performance, design, and product offering of the Primo Game platform.
• Communications: To send you transaction confirmations, security alerts, account notifications, and — where you have opted in — promotional communications about Primo Game offers and updates.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012 (Republic Act 10173) of the Philippines, Primo Game processes personal data based on the following legal grounds:

• Contractual necessity: Processing that is required to perform the contract between Primo Game and the player — i.e., operating your account, processing payments, and delivering the gaming services you have registered to use.
• Legal obligation: Processing required to comply with Philippine laws and regulations, including KYC requirements, anti-money laundering obligations, and regulatory reporting requirements.
• Legitimate interests: Processing carried out to pursue the legitimate interests of Primo Game or third parties, including fraud detection, platform security, and improving our services — provided that these interests are not overridden by your privacy rights.
• Consent: For certain processing activities — specifically, sending you marketing communications about Primo Game promotions and offers — we will only proceed where you have given us clear, informed consent. You may withdraw this consent at any time by updating your communication preferences in your account settings or by contacting our support team.

6 Data Sharing and Third Parties

Primo Game does not sell your personal data. We share personal data with third parties only in the limited circumstances described below, and only to the extent necessary for the specific purpose:

6.1 Service Providers

We engage third-party service providers who process personal data on our behalf and under our instructions. These include payment processors (such as the technical operators behind GCash, Maya, and bank transfer infrastructure), identity verification services, cloud hosting providers, and customer support platform operators. All service providers are contractually required to handle your data in accordance with applicable Philippine privacy law and our instructions.

6.2 Regulatory and Legal Authorities

Primo Game may be required to share personal data with Philippine government agencies, regulatory bodies, law enforcement authorities, or courts where required by law or in response to a lawful legal process. We will notify affected players of such disclosures where we are legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of the Primo Game business, player personal data may be transferred to the acquiring entity as part of that transaction. Players will be notified prior to such a transfer and the new operator will be required to honour the commitments in this Privacy Policy.

7 Cookies and Tracking Technologies

Primo Game uses cookies and similar tracking technologies to operate the platform and improve your experience. Here is a breakdown of the types of cookies we use:

• Essential cookies: Required for the platform to function. These handle login sessions, security tokens, and basic navigation. You cannot disable these without affecting your ability to use the platform.
• Functional cookies: Remember your preferences such as language settings and display options so you don't have to re-enter them each visit.
• Analytics cookies: Help us understand how players use the platform — which pages are visited most, where players encounter issues, and how the platform performs across different devices. This data is aggregated and does not identify individual players.
• Session management cookies: Maintain your logged-in state securely while you are active on the platform.

You can manage cookie preferences through your browser settings. However, disabling essential cookies will prevent you from logging in to and using the Primo Game platform. We do not use advertising or cross-site tracking cookies.

8 How Long We Keep Your Data

Primo Game retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to minimum retention periods required by Philippine law. Our general retention schedule is as follows:

• Active account data: Retained for the duration of your account and for five years after account closure, in accordance with anti-money laundering record-keeping requirements.
• KYC verification documents: Retained for five years from the date of the most recent transaction on your account.
• Financial transaction records: Retained for five years from the transaction date, as required under Philippine financial regulations.
• Gaming session records: Retained for three years from the date of each session.
• Customer support communications: Retained for two years from the date of the most recent communication in each support case.
• Technical and server logs: Retained for 90 days unless required to be preserved longer for security investigation purposes.

When the applicable retention period expires, Primo Game securely deletes or anonymises your personal data so that it can no longer be associated with you.

9 How We Protect Your Data

Primo Game implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, and destruction. Our security framework includes:

• Encryption in transit: All data transmitted between your device and the Primo Game platform is encrypted using TLS (Transport Layer Security).
• Encryption at rest: Sensitive personal data stored on Primo Game servers — including identity documents and financial records — is encrypted using industry-standard algorithms.
• Access controls: Access to personal data is restricted on a need-to-know basis. Staff members who can access player data are subject to strict confidentiality obligations and are trained in data handling procedures.
• Regular security audits: We conduct periodic security assessments and penetration tests to identify and address vulnerabilities in our systems.
• Incident response: Primo Game maintains a documented data breach response procedure. In the event of a breach that poses a risk to affected players, we will notify relevant Philippine authorities and affected players in accordance with legal requirements.

10 Your Data Rights Under Philippine Law

As a Filipino player and data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by Primo Game:

To exercise any of these rights, contact our Data Protection Officer at privacy@primogame.net. We will respond to all rights requests within 15 business days. We may need to verify your identity before processing your request — this is to protect your data from unauthorised access by third parties.

If you believe that Primo Game has not handled your personal data in accordance with this policy or Philippine law, you also have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.

11 Children's Privacy

The Primo Game platform is strictly for adults aged 21 years and above, in accordance with Philippine gaming regulations. We do not knowingly collect, store, or process the personal data of anyone under the age of 21.

If we become aware that a person under the age of 21 has created an account or provided personal data to Primo Game, we will immediately close the account, delete all associated personal data, and return any deposited funds in accordance with applicable law. If you believe a minor may have accessed our platform, please contact us immediately at support@primogame.net.

12 Cross-Border Data Transfers

In the course of operating the Primo Game platform, some personal data may be processed by service providers located outside the Philippines — for example, cloud infrastructure providers or identity verification services with data centres in other countries.

Where such transfers occur, Primo Game ensures that appropriate safeguards are in place to protect your personal data to the same standard required under Philippine law. These safeguards include contractual clauses that obligate overseas processors to maintain equivalent data protection standards and to process data only on Primo Game's instructions.

Primo Game will not transfer your personal data to countries that the National Privacy Commission has identified as providing inadequate levels of data protection without implementing additional appropriate safeguards.

13 Updates to This Privacy Policy

Primo Game may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable Philippine law. When we make material changes — changes that meaningfully affect how your personal data is used or your rights as a data subject — we will:

• Post the updated policy on this page with a revised effective date.
• Send a notification to your registered email address at least seven days before the changes take effect.
• Display a prominent notice on the Primo Game platform for a reasonable period after the changes go live.

We encourage you to review this page periodically. Your continued use of the Primo Game platform after a Privacy Policy update takes effect constitutes your acknowledgment of the revised terms. If you have concerns about any proposed changes, please contact our DPO before the effective date.

14 Contact Us & Data Protection Officer

If you have any questions about this Privacy Policy, want to exercise your data rights, or need to report a privacy concern, please reach out through the following channels:

• Data Protection Officer email: privacy@primogame.net
• General support email: support@primogame.net
• Live chat: Available on the primogame.net platform when you are logged in to your account
• Response time: We aim to acknowledge all privacy-related communications within 48 hours and to provide a substantive response within 15 business days.

For complaints that cannot be resolved directly with Primo Game, Filipino players have the right to approach the National Privacy Commission of the Philippines for independent review. The NPC's contact information is publicly available on their official government website.