Privacy Policy — How gl16 Protects Your Data

gl16 is an online gaming platform serving Filipino players, accessible at gl16.net. We offer a comprehensive range of online gaming products including slot games, live casino, sports betting, bingo, and fishing games. All real-money transactions on the platform are conducted in Philippine Peso (PHP) and are accessible through local payment channels including GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT TRC20.

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), gl16 acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes in connection with the gl16 platform and its services. A designated Data Protection Officer (DPO) oversees gl16's data governance practices and is reachable at the contact details provided in Section 14.

gl16 collects personal data only to the extent necessary for operating the platform, verifying player identity, processing financial transactions, and complying with applicable Philippine laws. The categories of personal data we collect are as follows:

gl16 collects personal data through the following channels and mechanisms:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, participate in a promotion, or submit any form on the gl16 platform.
• Automatically during platform use: When you visit or use gl16.net, we automatically collect technical data such as your IP address, device identifiers, browser details, and session activity through server logs and cookies. This data is collected passively as part of normal platform operation.
• From payment providers: When you process a GCash, Maya, BPI, BDO, or other payment transaction, the relevant payment provider shares transaction confirmation data (such as a transaction reference number and sender account name) with gl16 for the purpose of crediting or debiting your gl16 wallet. gl16 does not receive your full account credentials from any payment provider.
• From identity verification services: Where gl16 uses a third-party KYC or document verification provider to assist with identity checks, that provider may return a verification result and associated metadata to gl16. The underlying ID document is processed in accordance with the provider's own privacy policy, which is consistent with Philippine DPA requirements.
• From other players (limited): In specific dispute resolution contexts, another player may provide information referencing your account. Such data is handled in accordance with this Privacy Policy and is not shared beyond the investigation.

gl16 uses the personal data it holds about you for the following specific purposes. We do not use your data for any purpose that has not been disclosed to you in this Privacy Policy:

• Account management: To create, maintain, and administer your gl16 account, including processing login sessions, managing your PHP wallet balance, and applying account settings.
• Identity and age verification: To confirm that you are who you say you are and that you meet the 21+ age requirement for online gaming under Philippine law. This is a regulatory obligation gl16 cannot waive.
• Financial transaction processing: To process PHP deposits from and withdrawals to your registered payment methods. This includes record-keeping of all financial transactions for at least five (5) years as required under the Anti-Money Laundering Act (AMLA).
• Fraud detection and prevention: To identify and investigate suspicious account activity, attempted multi-accounting, bonus abuse, unauthorised access, and money laundering. This may involve automated screening of transaction patterns and IP data.
• Regulatory compliance: To fulfil gl16's obligations under the Data Privacy Act, the Anti-Money Laundering Act, PAGCOR regulations, and any other applicable Philippine law, including responding to lawful requests from regulatory or law enforcement authorities.
• Customer support: To respond to your queries, resolve disputes, and provide technical assistance. Support communications may be recorded and retained for quality assurance and dispute evidence purposes.
• Responsible gaming: To monitor gaming patterns that may indicate problem gambling behaviour and to apply self-exclusion, deposit limit, or cool-off requests promptly and accurately.
• Platform improvement: To analyse aggregated, anonymised usage data for the purpose of improving gl16's platform performance, game selection, and user experience. This analysis does not involve personally identifiable data.
• Marketing communications (opt-in only): If you have explicitly opted in to receive promotional communications from gl16, we may send you personalised offers, bonus alerts, and game announcements via email or SMS. You may withdraw this consent at any time from within your account settings.

Under the Philippine Data Privacy Act of 2012, gl16 processes your personal data on the following lawful bases:

• Contractual necessity: Processing your registration data, KYC documents, and financial transaction data is necessary for gl16 to fulfil its contractual obligations to you as a registered player — specifically, to provide you with a functional, secure gaming account and to process your PHP deposits and withdrawals.
• Legal obligation: Certain processing activities — including AMLA-mandated transaction record retention, age verification, and regulatory reporting — are required by Philippine law. gl16 must perform these activities regardless of your preference.
• Legitimate interests: gl16 processes technical data (IP addresses, device data, session logs) on the basis of its legitimate interest in maintaining platform security, detecting fraud, and protecting the integrity of the gaming environment for all players.
• Consent: For optional processing activities — such as sending promotional emails or SMS, or using non-essential cookies — gl16 relies on your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

gl16 does not sell your personal data. We share personal data with third parties only where necessary, proportionate, and in accordance with this Privacy Policy and applicable Philippine law. The third parties with whom gl16 may share your data are:

• Payment service providers: GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT processing partners receive the minimum data necessary to process your deposit or withdrawal transaction (typically your registered name and transaction reference). Each provider is independently subject to BSP and Philippine financial data protection regulations.
• KYC and identity verification providers: Third-party document verification services may process your submitted ID documents on gl16's behalf. These providers operate under data processing agreements that require compliance with the Philippine DPA and restrict them from using your data for any purpose other than the verification service.
• Game content providers: Game studios (such as JILI, PG Soft, and Pragmatic Play) whose games are hosted on gl16 receive anonymised session data for game logging and RTP auditing purposes. They do not receive your name, contact details, or financial information.
• Regulatory and law enforcement authorities: gl16 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine authorities when required to do so by law, court order, or regulatory directive. gl16 will only disclose the minimum data required by the relevant legal obligation.
• Platform infrastructure providers: Cloud hosting and infrastructure providers that store and process gl16's data on its behalf operate under strict data processing agreements requiring them to treat gl16 player data with the same protections as described in this policy.

gl16.net uses cookies and similar tracking technologies to ensure the platform functions correctly, maintain your login session, and understand how players use the site. The categories of cookies gl16 uses are as follows:

• Essential cookies: These are strictly necessary for the platform to function. They maintain your authenticated session, preserve your language preference, and ensure secure navigation between pages. Essential cookies cannot be disabled without rendering the platform non-functional.
• Functional cookies: These remember your preferences — such as your preferred game lobby view or notification settings — to personalise your experience on return visits. They do not track activity across other websites.
• Analytics cookies: gl16 uses anonymised analytics to understand aggregate traffic patterns, popular game categories, and platform performance. Analytics data is processed in aggregate and does not identify individual players. You may opt out of analytics cookies from your cookie preference settings.
• Security cookies: These are used by gl16's fraud detection systems to identify unusual patterns that may indicate account compromise or coordinated abuse. They are essential for platform security.

gl16 does not use third-party advertising cookies or tracking pixels that monitor your activity outside of the gl16 platform. Your browser settings allow you to manage or delete cookies at any time, though disabling essential cookies will affect your ability to use the platform.

gl16 retains your personal data for as long as is necessary for the purpose for which it was collected, subject to minimum retention periods required by Philippine law. The specific retention periods gl16 applies are:

Upon expiry of the applicable retention period, gl16 will securely delete or anonymise your personal data. Anonymised data (from which you cannot be identified) may be retained indefinitely for aggregate statistical analysis.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by gl16. gl16 is committed to honouring these rights promptly and without requiring you to engage legal counsel:

• Right to be informed: You have the right to know that gl16 is collecting and processing your personal data, for what purposes, and on what legal basis. This Privacy Policy fulfils that right.
• Right of access: You may request a copy of all personal data gl16 holds about you. gl16 will provide this within 10 business days of receiving a verified request. A reasonable administrative fee may apply for excessive or repeat requests.
• Right to rectification: If any personal data gl16 holds about you is inaccurate or incomplete, you have the right to request correction. You may update basic account details (name, address, contact number) directly in your account settings; KYC-linked data changes require support assistance.
• Right to erasure: You may request that gl16 delete your personal data. Note that this right is subject to gl16's legal retention obligations — data that must be retained under AMLA or PAGCOR regulations cannot be deleted upon request until the mandatory retention period expires. gl16 will clearly explain any such limitations when processing your erasure request.
• Right to object: You have the right to object to gl16's processing of your data for marketing purposes or any processing based on legitimate interests. Where you object to marketing, gl16 will stop processing your data for that purpose immediately.
• Right to data portability: Upon request, gl16 will provide your personal data in a structured, commonly used, and machine-readable format (such as CSV or JSON) where technically feasible.
• Right to lodge a complaint: If you believe gl16 has violated your data privacy rights, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines. gl16 encourages players to contact gl16's DPO first to attempt resolution before escalating to the NPC.

The gl16 platform is strictly for individuals aged 21 years and above. This is the minimum legal age for online gambling in the Philippines under PAGCOR regulations. gl16 does not knowingly collect personal data from any person under the age of 21.

If gl16 discovers or has reasonable grounds to believe that a registered account belongs to a person under 21 years of age, the account will be immediately suspended. All winnings associated with the account will be voided, all deposited real-money funds will be returned to their source, and the matter will be referred to PAGCOR as required by its regulatory framework.

gl16 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or alteration. Key security controls in place include:

• Transport encryption: All data transmitted between your browser or device and gl16's servers is encrypted using TLS 1.2 or higher. Connections using outdated protocols are rejected at the server level.
• Data-at-rest encryption: Sensitive personal data — including KYC documents, identity numbers, and financial records — is encrypted at rest using AES-256 encryption in gl16's database infrastructure.
• Access controls: Access to player personal data within gl16's internal systems is restricted on a strict need-to-know basis. Staff access is governed by role-based permissions, and all access events are logged and audited regularly.
• Two-factor authentication: gl16 supports and strongly encourages 2FA for player accounts. Internally, 2FA is mandatory for all gl16 staff accessing systems that contain player personal data.
• Intrusion detection: gl16's infrastructure is monitored 24/7 by automated intrusion detection systems that alert the security team to anomalous access patterns, brute-force attempts, and other threat indicators.
• Penetration testing: gl16 conducts regular independent security assessments, including penetration testing of platform infrastructure and web application vulnerability scanning, to identify and remediate security weaknesses proactively.
• Staff training: All gl16 staff who handle player personal data receive mandatory data privacy and security training upon joining and on an annual basis thereafter.

While gl16 applies industry-standard security measures, no system is completely immune from security risks. Players are encouraged to use a strong, unique password for their gl16 account, enable 2FA, and report any suspicious account activity immediately to gl16 support.

gl16 primarily processes and stores player data on infrastructure located within or serving the Philippines. However, certain service providers — including cloud infrastructure vendors and game studio back-end systems — may process data in data centres located outside the Philippines.

Where such cross-border transfers occur, gl16 ensures that the receiving entity provides an adequate level of data protection by requiring one or more of the following safeguards:

• A data processing agreement containing standard contractual clauses aligned with NPC guidelines on cross-border data transfers.
• The recipient country or entity maintains data protection standards recognised as adequate by the National Privacy Commission of the Philippines.
• The transfer is necessary for the performance of a contract with you (for example, processing a USDT TRC20 transaction through a blockchain network).

gl16 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, or NPC regulatory guidance. When updates are made, the following process applies:

• For material changes — those that significantly affect how we use your personal data or your rights as a data subject — gl16 will notify registered players via email at least seven (7) days before the updated policy takes effect.
• For minor clarifications — such as updated contact details, corrected typographical errors, or re-worded sections that do not change the substance of gl16's data practices — the policy will be updated without prior individual notice. The updated effective date at the top of this document will reflect the change.
• For legally mandated changes — those required by an NPC directive, new legislation, or court order — the updated policy may take effect immediately, with notification provided as soon as practicable thereafter.

Continued use of the gl16 platform after the effective date of an updated Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with any updates to this policy, you may close your account by contacting gl16 support and requesting account closure.

For any questions, concerns, or requests relating to this Privacy Policy or the personal data gl16 holds about you, please contact the gl16 Data Protection Officer using the details below. Our support team is available 24 hours a day, seven days a week, in both English and Filipino.

If you are not satisfied with gl16's response to your data privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for enforcing the Data Privacy Act of 2012 and protecting the data privacy rights of all Filipinos.