cosino Privacy Policy

1 Introduction & Scope

cosino ("we", "us", "our") is committed to protecting the privacy and personal data of all players who access or use the cosino platform. This Privacy Policy describes how cosino collects, uses, stores, shares, and protects your personal data in connection with your use of the cosino website, mobile-optimised platform, and all related services.

This policy applies to all registered cosino account holders, prospective players who have commenced but not completed registration, and any individual whose personal data cosino receives in the course of providing its services. It applies regardless of how you access the cosino platform — whether through a desktop browser, mobile browser, or any application provided by cosino.

This Privacy Policy should be read together with the cosino Terms & Conditions. Terms used in this policy that are defined in the Terms & Conditions carry the same meaning here unless otherwise stated.

cosino processes personal data in compliance with the Republic of the Philippines Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as overseen by the National Privacy Commission (NPC). cosino is also subject to applicable PAGCOR regulations governing the handling of player data in the context of licensed online gaming operations.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, cosino acts as the Personal Information Controller in respect of the personal data it collects and processes in connection with the cosino platform. cosino determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data privacy law.

Where cosino engages third-party service providers — such as payment processors, KYC verification partners, or licensed game providers — to process personal data on its behalf, those parties act as Personal Information Processors and are bound by data processing agreements that require them to handle your data only in accordance with cosino's instructions and applicable law.

If you have any questions about how your personal data is controlled or processed, you may contact cosino's designated Data Protection Officer (DPO) using the contact details provided in Section 14 of this policy.

3 Personal Data We Collect

cosino collects the following categories of personal data in connection with the operation of the cosino platform:

cosino does not intentionally collect sensitive personal information beyond what is strictly necessary for KYC compliance and the lawful operation of the platform. Where sensitive information (such as a copy of a government-issued ID bearing a PhilSys number) is collected, it is handled with an elevated level of protection consistent with the Data Privacy Act.

4 How We Collect Your Data

cosino collects your personal data through the following means:

• Directly from you — when you register a cosino account, complete KYC verification, make a deposit or withdrawal, contact cosino support, or participate in a promotion;
• Automatically during platform use — through cookies, server logs, and similar tracking technologies that record technical data such as your IP address, device identifiers, and session activity each time you use the cosino platform;
• From third-party KYC and identity verification providers — cosino may receive identity verification results and watchlist screening outcomes from licensed third-party KYC providers engaged to assist with compliance obligations;
• From payment processors — GCash, Maya, InstaPay, and bank partners may provide cosino with transaction confirmation data necessary to credit or debit your cosino account balance;
• From regulatory bodies — PAGCOR and other Philippine government authorities may provide cosino with information relevant to the lawful operation of its platform.

5 Legal Basis for Processing

cosino processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Performance of a contract — the majority of cosino's data processing is necessary to perform the contract formed between cosino and you when you register an account and accept the cosino Terms & Conditions. This includes processing your identity data, financial data, and gaming activity to provide the services you have signed up for;
• Legal obligation — cosino is required by Philippine law — including PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act — to collect and retain certain personal data. This includes KYC documentation and transaction records;
• Legitimate interests — cosino processes technical data and communications data on the basis of its legitimate interests in securing the platform, detecting and preventing fraud, improving its services, and managing disputes. cosino's legitimate interests do not override your rights where you have objected to such processing;
• Consent — where cosino sends you direct marketing communications or uses non-essential cookies, it relies on your consent. You may withdraw this consent at any time by contacting cosino support or using the opt-out mechanism provided in the relevant communication.

6 How We Use Your Data

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

• To create, verify, and manage your cosino account, including processing your cosino Login credentials securely;
• To process PHP deposits and withdrawals through GCash, Maya, BPI, BDO, Metrobank, InstaPay, QR Ph, and 7-Eleven CLiQQ;
• To verify your identity and age (21+) in compliance with PAGCOR licensing requirements and Philippine AML regulations;
• To monitor gaming activity for the purpose of delivering responsible gaming tools, including deposit limit enforcement, cooling-off periods, and self-exclusion;
• To detect, investigate, and prevent fraud, money laundering, collusion, and other prohibited conduct on the cosino platform;
• To respond to your customer support enquiries and resolve disputes;
• To send you transactional communications, including deposit confirmations, withdrawal updates, and account security alerts;
• To send you marketing communications about cosino promotions and offers, where you have consented to receive these;
• To personalise your cosino platform experience, including game recommendations and promotional targeting, based on your gaming activity and preferences;
• To maintain records required by PAGCOR, the Anti-Money Laundering Council (AMLC), and other applicable Philippine regulatory bodies.

7 Sharing Your Data

cosino does not sell, rent, or trade your personal data to unaffiliated third parties for their independent marketing purposes. cosino may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Licensed game providers — third-party providers of slot games, live dealer tables, video poker titles (including Jacks or Better), crash games (including Aviator), and bingo content may receive your account identifier and gaming session data for the purpose of delivering game content and recording results;
• Payment processors — GCash, Maya, BPI, BDO, Metrobank, InstaPay, and QR Ph partners receive the financial data necessary to process your PHP transactions;
• KYC and identity verification providers — cosino engages licensed third-party providers to assist with document verification and watchlist screening. These providers process your identity documents strictly for verification purposes;
• Fraud prevention and cybersecurity providers — technical data including IP addresses and device fingerprints may be shared with fraud detection services to protect the cosino platform and its players;
• Regulatory and law enforcement authorities — cosino will disclose personal data to PAGCOR, the AMLC, the National Privacy Commission, and other competent Philippine authorities where required to do so by law, court order, or valid regulatory request;
• Professional advisers — cosino's legal, audit, and compliance advisers may access personal data on a confidential basis in connection with the provision of professional services to cosino.

All third parties to whom cosino discloses personal data are required to handle that data in a manner consistent with the Data Privacy Act of 2012 and applicable international data protection standards.

8 Cookies & Tracking Technologies

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

• Essential cookies — strictly necessary for the cosino platform to function, including session management and cosino Login authentication. These cookies cannot be disabled without impairing platform functionality;
• Performance cookies — used to collect anonymised statistics about how players use the cosino platform, helping cosino identify and fix technical issues and improve overall performance;
• Functional cookies — remember your preferences such as language settings and responsible gaming limit configurations to personalise your cosino experience;
• Analytics cookies — cosino uses analytics tools to understand player behaviour patterns and improve the platform. Data collected by analytics cookies is aggregated and does not identify you personally;
• Security cookies — used to detect suspicious login behaviour, bot activity, and other security threats targeting your cosino account.

You may manage non-essential cookie preferences through your browser settings at any time. Note that disabling certain cookies may affect the functionality of the cosino platform. For more information about managing cookies on Philippine-network devices, please refer to your browser's help documentation.

9 Data Security

cosino implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the cosino platform;
• Password hashing using industry-standard algorithms — your cosino Login password is never stored in plain text and is not accessible to cosino staff;
• Two-factor authentication (2FA) via SMS OTP, available to all cosino account holders and strongly recommended;
• Access controls limiting staff access to personal data strictly to those with a legitimate need in the performance of their duties;
• Regular security assessments and penetration testing of the cosino platform;
• Secure document storage for KYC materials submitted by players, with access limited to compliance personnel.

In the event of a personal data breach that poses a risk to your rights and freedoms, cosino will notify the National Privacy Commission and, where required, affected players, in accordance with the Data Privacy Act of 2012 and the NPC's breach notification guidelines.

10 Data Retention

cosino retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, subject to any longer retention periods required by applicable Philippine law.

Specifically, cosino applies the following retention periods:

• Active account data — retained for the duration of your cosino account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and Philippine AML regulations;
• KYC and identity documents — retained for a minimum of five (5) years from the date of submission or account closure, whichever is later, as required under the Anti-Money Laundering Act;
• Transaction records — PHP deposit, withdrawal, and betting records are retained for a minimum of five (5) years in compliance with AMLC reporting requirements;
• Customer support communications — retained for three (3) years from the date of the interaction for quality assurance and dispute resolution purposes;
• Marketing consent records — retained for the period of your account plus two (2) years, or until consent is withdrawn, whichever is earlier.

At the end of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification. Where data has been anonymised and can no longer be attributed to an identified individual, it is no longer considered personal data and may be retained indefinitely for analytical purposes.

11 Your Rights

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

• Right to be informed — you have the right to be notified of how your personal data is collected and processed. This Privacy Policy fulfils that obligation;
• Right of access — you may request a copy of the personal data cosino holds about you, including the categories of data, its sources, the purposes of processing, and any third parties with whom it has been shared;
• Right to rectification — you have the right to request correction of inaccurate or incomplete personal data held by cosino. You may update basic account information directly through your cosino account settings;
• Right to erasure — you may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to cosino's legal retention obligations under Philippine law;
• Right to object — you may object to cosino processing your personal data on the basis of legitimate interests, and to the use of your data for direct marketing purposes;
• Right to data portability — you may request that cosino provide your personal data in a structured, commonly used, machine-readable format;
• Right to damages — you are entitled to be indemnified for any damages sustained as a result of inaccurate, incomplete, outdated, false, or unlawfully obtained personal data held by cosino.

To exercise any of these rights, please contact cosino's Data Protection Officer using the details in Section 14. cosino will respond to all verified data subject requests within fifteen (15) working days of receipt, consistent with NPC guidelines.

Please note that certain rights are subject to limitations where cosino is required to retain or process data to comply with a legal obligation, to pursue or defend legal claims, or where the exercise of your rights would adversely affect the rights of other individuals.

12 Children & Minors

The cosino platform is strictly intended for individuals aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. cosino does not knowingly collect personal data from individuals under the age of 21.

During account registration, cosino collects your date of birth and requires submission of a valid Philippine government-issued ID to verify that you meet the minimum age requirement. Accounts found to belong to individuals under 21 years of age will be immediately suspended and all associated balances will be forfeited pending investigation.

If cosino becomes aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, it will take immediate steps to delete that data and close the associated account. If you believe that cosino has inadvertently collected data from a minor, please contact us immediately at the address provided in Section 14.

cosino actively implements age verification measures and maintains a zero-tolerance policy toward underage gambling. Parents and guardians are encouraged to use parental control tools and to monitor minors' internet access to prevent access to the cosino platform.

13 Changes to This Privacy Policy

cosino reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, platform functionality, or cosino's data processing practices. The "Last Updated" date at the top of this page will be revised accordingly whenever a material change is made.

Where changes to this Privacy Policy are material — meaning they significantly affect how cosino processes your personal data or alter your rights — cosino will provide advance notice to registered players via email to the address on file, a notification upon next login to the cosino platform, or both, at least seven (7) days before the changes take effect.

Continued use of the cosino platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the revised policy. If you do not agree with the changes, you should stop using the cosino platform and contact support to request account closure.

The current version of this Privacy Policy is always available at cosino.bet/privacy-policy. Previous versions may be obtained by contacting the cosino Data Protection Officer.

14 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or cosino's handling of your personal data, please contact our Data Protection Officer:

If you are not satisfied with cosino's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. Information about how to file a complaint with the NPC is available through official Philippine government channels.

cosino takes all privacy complaints seriously and will cooperate fully with the NPC in connection with any investigation into its data processing practices.

This Privacy Policy was last revised on 1 January 2026 and is effective immediately for all registered cosino accounts.