Privacy Policy – Escala Philippines Online Casino Data Protection

Escala is the data controller for all personal data processed through the escala.best platform. Escala operates under a licence issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the Philippine Data Privacy Act of 2012 (Republic Act 10173), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission (NPC).

Escala has appointed a Data Protection Officer (DPO) responsible for overseeing data protection compliance. You can contact the DPO at any time via email at privacy@escala.best or through the live chat available in your Escala account dashboard.

By registering an account and using the Escala platform, you acknowledge that your personal data will be processed in accordance with this Privacy Policy. If you do not agree with the terms of this policy, please do not use the Escala platform.

Escala collects several categories of personal data depending on how you interact with the platform. The table below summarises what we collect and why:

Escala does not collect sensitive personal information — such as racial or ethnic origin, political opinions, religious beliefs, or health data — unless it is directly relevant to responsible gaming obligations (for example, where a player voluntarily discloses a gambling-related health concern to access self-exclusion support).

Escala collects personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, respond to a survey, or participate in a promotion.
• Automatically through your use of the platform — through cookies, web beacons, server logs, and similar tracking technologies when you access escala.best or use the Escala app. See Section 9 for full details on cookies.
• From payment providers — GCash, Maya, and other payment processors may share transaction confirmation data and payment method details with Escala as part of the payment processing flow.
• From identity verification services — Escala uses third-party KYC and identity verification providers to cross-check information you provide against official Philippine government databases, consistent with PAGCOR licensing requirements.
• From fraud prevention services — Escala uses third-party fraud detection tools that may receive and process technical data (IP addresses, device fingerprints) to protect the platform and its players.

Under RA 10173, Escala processes your personal data on the following legal bases:

• Contractual necessity — processing required to create and manage your Escala account, process transactions, and deliver the gaming service you have requested.
• Legal obligation — processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160), the Data Privacy Act (RA 10173), and other applicable Philippine laws.
• Legitimate interests — processing conducted for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your data protection rights.
• Consent — for optional processing activities such as marketing communications and certain personalisation features, where Escala relies on your freely given, informed consent. You may withdraw consent at any time.

Your personal data is used by Escala for the following specific purposes:

• Account management — creating, maintaining, and securing your Escala account; processing password resets and security alerts.
• Financial transactions — processing deposits and withdrawals through GCash, Maya, and other supported payment channels; generating transaction records for your account history.
• Identity and age verification — confirming that you are who you say you are and that you meet the 21-years-minimum age requirement under Philippine law.
• Regulatory compliance — meeting Escala's obligations under PAGCOR conditions, the AMLA, and RA 10173; generating records required for regulatory audits and inspections.
• Fraud prevention and platform security — detecting and preventing cheating, multi-accounting, money laundering, and other prohibited conduct described in the Escala Terms and Conditions.
• Responsible gaming — monitoring gameplay patterns that may indicate problem gambling; delivering responsible gaming tools and communications; responding to self-exclusion requests.
• Customer support — handling account queries, payment disputes, game result questions, and complaints through live chat and email.
• Platform improvement — analysing usage data in aggregate to improve game selection, navigation, load times, and the overall Escala player experience.
• Marketing communications — where you have consented, sending promotional emails or in-platform notifications about Escala bonuses, new games, and events relevant to you.

Escala shares personal data only in the circumstances listed below. We do not sell your data to anyone, ever.

• Payment processors — GCash (GXI), Maya (PayMaya Philippines), GrabPay, Coins.ph, Bancnet member banks, Visa/Mastercard networks. Data shared is limited to what is necessary to process your specific transaction.
• KYC and identity verification providers — third-party services used to verify your identity documents against Philippine government databases. These providers process your data solely for verification purposes and are bound by strict confidentiality obligations.
• Fraud detection and security services — providers that help Escala identify suspicious account activity, multi-accounting, and potential money laundering. Technical and usage data may be processed by these providers.
• Game providers — JILI Games, Evolution Gaming, and other certified game providers receive minimum necessary technical data (e.g., player session tokens) to deliver their games within the Escala platform. They do not receive your full identity or financial data.
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies where disclosure is required by law or court order.
• Legal and compliance advisers — where Escala requires legal advice in connection with a regulatory matter, dispute, or litigation involving your account. These advisers are bound by professional confidentiality obligations.

Escala retains personal data for the minimum period required by our legal and regulatory obligations, after which it is securely deleted or anonymised.

• Account data — retained for the duration of your Escala account, plus a minimum of 5 years after account closure, as required by PAGCOR and AMLC regulations.
• Financial transaction records — retained for a minimum of 5 years after the transaction date, consistent with AMLA requirements.
• KYC and identity verification documents — retained for the duration of the account relationship plus 5 years after closure.
• Customer support communications — retained for 3 years after the support interaction is closed, to support dispute resolution and quality improvement.
• Technical and usage data — aggregated and anonymised after 13 months; raw logs retained for up to 6 months for security monitoring purposes.
• Marketing consent records — retained until consent is withdrawn, plus a reasonable period thereafter to demonstrate compliance.

Where a legal dispute, regulatory investigation, or formal complaint is active, Escala will retain relevant data for the duration of that proceeding regardless of standard retention periods.

Escala implements a layered security framework to protect your personal data from unauthorised access, disclosure, alteration, and destruction:

• Encryption in transit — all data between your device and Escala's servers is encrypted using TLS 1.3 with 256-bit cipher suites.
• Encryption at rest — databases containing personal and financial data are encrypted using AES-256.
• Access controls — access to personal data is restricted to Escala staff and contractors on a strictly need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Network security — Escala's infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and DDoS mitigation.
• Regular security audits — Escala undergoes regular penetration testing and security audits conducted by independent third-party specialists.
• Employee training — all Escala staff who handle personal data receive mandatory data privacy training and are bound by confidentiality obligations in their employment contracts.

No security system is completely infallible. In the event of a data breach, Escala will respond in accordance with RA 10173 obligations, notifying the National Privacy Commission and affected Players within 72 hours where required.

Escala uses cookies and similar tracking technologies when you visit escala.best. Cookies are small text files stored on your device that help the platform function properly and allow us to understand how players interact with the site.

Escala uses the following categories of cookies:

• Strictly necessary cookies — required for the platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. You cannot opt out of these without disabling the platform entirely.
• Functional cookies — remember your preferences such as language settings, game filter selections, and login status between sessions. Disabling these will affect platform convenience but not core functionality.
• Analytics cookies — collect aggregated, anonymised data about how players use escala.best, which pages are most visited, and where errors occur. This data is used to improve the platform. Analytics cookies require your consent.
• Security cookies — used by Escala's fraud detection systems to identify suspicious patterns across sessions. These are necessary for platform security and cannot be disabled.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Escala platform. Your browser's help documentation contains instructions for managing cookies on your specific browser and device.

As a data subject under RA 10173, you have the following rights regarding your personal data held by Escala. To exercise any of these rights, contact our DPO at privacy@escala.best. We will respond within 15 business days.