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Privacy Policy

Last updated: July 12, 2026

1. Introduction

ProlegoPH (“we,” “our,” or “us”) operates the ProlegoPH prediction market platform (the “Service”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service. We are committed to complying with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (“DPA”), and its implementing rules and regulations.

By accessing or using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please discontinue use of the Service immediately.

2. Information We Collect

2.1 Personal Information You Provide

When you register an account or use the Service, we may collect:

  • Account data: Your display name, email address, and hashed password.
  • Transaction data: Records of your predictions, including amounts, outcomes, market participation, and wallet balance history.
  • Communications: Any messages, feedback, or support requests you send to us.

2.2 Information Collected Automatically

When you access the Service, we may automatically collect:

  • Log data: IP address, browser type, operating system, referring URLs, pages visited, and timestamps.
  • Device information: Device type, unique device identifiers, and mobile network information.
  • Usage data: Interaction patterns with markets, features used, and session duration.
  • Cookies and similar technologies: Session tokens for authentication and preference storage.

3. How We Use Your Information

We use the collected information for the following purposes:

  • To create, maintain, and secure your account.
  • To process your predictions and maintain accurate ledger records.
  • To calculate and display market probabilities, portfolio values, and winnings.
  • To communicate with you about your account, transactions, and Service updates.
  • To detect, prevent, and address fraud, abuse, or technical issues.
  • To comply with applicable laws, regulations, and legal process.
  • To improve and optimize the Service based on aggregated usage analytics.

4. Legal Basis for Processing (Philippine DPA)

Under the Data Privacy Act of 2012, we process your personal data based on one or more of the following lawful criteria:

  • Consent: You have given your freely-given, specific, and informed consent at the point of registration.
  • Contractual necessity: Processing is necessary to perform our obligations under the Terms of Service you have accepted.
  • Legitimate interests: Processing is necessary for our legitimate business interests, including fraud prevention, security, and Service improvement, except where overridden by your data privacy rights.
  • Legal obligation: Processing is necessary to comply with a legal obligation under Philippine law.

5. Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share information only in the following limited circumstances:

  • Service providers: With third-party vendors who perform services on our behalf (e.g., hosting, database management, email delivery), bound by confidentiality obligations.
  • Legal compliance: If required by law, court order, subpoena, or governmental authority in the Philippines.
  • Protection of rights: To investigate, prevent, or take action regarding violations of our Terms of Service, fraud, or threats to the safety of any person.
  • Business transfers: In connection with a merger, sale of assets, or acquisition, provided the receiving party agrees to this Privacy Policy.
  • Aggregated data: We may share non-personally identifiable, aggregated, or de-identified data for research, analytics, or public market statistics.

6. Data Retention

We retain your personal information only for as long as your account is active or as needed to provide the Service. Transaction and ledger records are retained indefinitely to maintain the integrity of the prediction market system. Upon account deletion, we will delete or anonymize your personal data within a reasonable timeframe, except where retention is required by law or for legitimate business purposes such as fraud prevention and audit trails.

7. Data Security

We implement reasonable and appropriate organizational, physical, and technical security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of passwords using industry-standard hashing algorithms.
  • Transport Layer Security (TLS) for data in transit.
  • Database access controls and least-privilege principles.
  • Regular security assessments of our infrastructure.

However, no method of electronic storage or transmission is 100% secure. While we strive to protect your data, we cannot guarantee its absolute security.

8. Your Rights Under the Philippine Data Privacy Act

As a data subject under the DPA, you have the following rights:

  • Right to be informed: You have the right to know how your personal data is being processed.
  • Right to access: You may request access to your personal data in our possession.
  • Right to rectification: You may request correction of inaccurate or incomplete personal data.
  • Right to erasure or blocking: You may request the removal or blocking of your personal data, subject to legal retention requirements.
  • Right to object: You may object to the processing of your personal data in certain circumstances.
  • Right to data portability: You may request a copy of your data in a commonly used electronic format.
  • Right to file a complaint: You may file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, contact us using the information in Section 11.

9. Cookies

We use essential cookies and local storage to maintain your authenticated session and remember your preferences. These are strictly necessary for the Service to function. We do not use third-party tracking cookies, advertising cookies, or analytics cookies that track you across other websites. You may configure your browser to refuse cookies, but this may prevent you from using certain features of the Service.

10. Children's Privacy

The Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that a minor has provided us with personal data, we will take steps to delete such information promptly.

11. Contact Information

If you have questions, concerns, or wish to exercise your data privacy rights, you may contact the Data Protection Officer at:

Email: [email protected]

You may also lodge a complaint with the National Privacy Commission through their website at https://www.privacy.gov.ph.

12. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. We will notify you of material changes by posting the updated policy on this page and updating the “Last updated” date. Your continued use of the Service after any modification constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically.