lodi291 Privacy Policy

This Privacy Policy ("Policy") describes how lodi291 ("lodi291," "we," "us," "our") collects, uses, stores, discloses, and otherwise processes personal information about individuals who register for, access, or use the lodi291 online gaming platform at lodi291.bio and any associated sub-domains or interfaces (collectively, the "Platform").

lodi291 takes its data protection obligations seriously. We are committed to handling your personal information responsibly, transparently, and in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) ("DPA"), its Implementing Rules and Regulations, and any applicable issuances of the National Privacy Commission (NPC) of the Philippines. Where lodi291 processes data of players located in other jurisdictions, we also apply appropriate international standards as required.

This Policy applies to all personal information collected in connection with the lodi291 Platform — whether collected online through the website, through live chat communications, through email correspondence, through telephone or SMS interactions, or through any other channel by which you communicate with lodi291. Please read this Policy carefully. By creating a lodi291 account and/or using the Platform, you confirm that you have read and understood this Policy and agree to the processing of your personal information as described herein. If you do not agree, please do not register for or use the lodi291 Platform.

For the purposes of the Philippine Data Privacy Act of 2012, lodi291 is the Personal Information Controller with respect to the personal data processed in connection with the Platform. This means lodi291 determines the purposes and means of processing your personal information.

lodi291 operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). As a PAGCOR-regulated platform, lodi291 is subject to applicable PAGCOR-imposed data handling requirements in addition to the obligations imposed by the DPA.

If you have any questions, concerns, or requests relating to the processing of your personal data by lodi291, please contact our Data Protection Officer (DPO) using the contact information provided in Section 15 of this Policy. lodi291 is committed to responding to all data subject enquiries within a reasonable timeframe consistent with the requirements of the DPA and NPC issuances.

lodi291 collects personal data from you directly (when you provide it to us) and automatically (through your use of the Platform). The categories of personal data we collect are described below:

lodi291 uses the personal data it collects for the following specific purposes. We will not use your personal data for any purpose that is incompatible with the purposes listed here without first obtaining your additional consent or establishing another lawful basis for processing:

• Account Registration and Management: To create, verify, maintain, and administer your lodi291 player account.
• Identity Verification and KYC: To verify your identity, confirm your age (minimum 21 years old as required by PAGCOR), and fulfil mandatory Know Your Customer obligations under PAGCOR regulations and the Anti-Money Laundering Act.
• Platform Operation: To provide access to lodi291 games, process bets and transactions, manage bonuses and promotions, and deliver the core gaming services offered on the Platform.
• Payment Processing: To process deposits to and withdrawals from your lodi291 wallet via GCash, Maya, and other supported Philippine payment methods.
• Regulatory Compliance: To meet lodi291's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act of the Philippines (AMLA), the Data Privacy Act of 2012, and any other applicable Philippine laws and regulations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, money laundering, and other illegal conduct on the lodi291 Platform.
• Responsible Gaming: To identify patterns of play that may indicate problem gambling, to enforce responsible gaming tools (deposit limits, self-exclusion), and to comply with PAGCOR's responsible gaming requirements.
• Customer Support: To respond to enquiries, complaints, and support requests submitted through live chat, email, or other channels.
• Marketing Communications: Where you have given consent, to send you promotional offers, bonus notifications, and updates about new games or features on lodi291. You may opt out of marketing communications at any time.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the performance, user experience, and content of the lodi291 Platform.

Under the Philippine Data Privacy Act of 2012, lodi291 relies on the following lawful bases for the processing of your personal information:

• Contractual Necessity: Processing is necessary for the performance of the agreement between you and lodi291 — specifically, the Terms and Conditions governing your use of the Platform. This covers account registration, game operation, payment processing, and customer support.
• Legal Obligation: Processing is required for lodi291 to comply with applicable legal and regulatory obligations, including PAGCOR licensing requirements, the Anti-Money Laundering Act, the Data Privacy Act, and other mandatory Philippine laws.
• Legitimate Interests: Processing is necessary for the purposes of lodi291's legitimate interests, including fraud detection and prevention, platform security, responsible gaming enforcement, and platform improvement — provided that these interests are not overridden by your own rights and interests.
• Consent: For certain non-essential processing activities — specifically, the sending of direct marketing communications — lodi291 relies on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

lodi291 does not sell, rent, or trade your personal data to third parties for their own independent commercial purposes. lodi291 shares your personal data only in the following limited circumstances and only to the extent necessary for the specified purpose:

lodi291 uses cookies and similar tracking technologies to enhance your experience on the Platform, to maintain your login session, to remember your preferences, and to gather analytics data that helps us improve the Platform. The types of cookies lodi291 uses are as follows:

• Strictly Necessary Cookies: These cookies are essential for the lodi291 Platform to function and cannot be disabled. They include session cookies that keep you logged in to your lodi291 account and security cookies that protect against cross-site request forgery attacks.
• Performance and Analytics Cookies: These cookies collect information about how you use the lodi291 Platform — which pages you visit, how long you spend on them, and any errors you encounter. This data is used in aggregated, anonymised form to improve the Platform.
• Functional Cookies: These cookies remember your preferences and settings on the lodi291 Platform, such as your preferred game category, language settings, or display preferences.
• Marketing Cookies: Where you have given consent, lodi291 may use cookies to deliver relevant promotional content about lodi291 offers. You may opt out of marketing cookies via your browser settings or by contacting our DPO.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair the functionality of the lodi291 Platform. Browsers commonly used by Filipino players (Chrome on Android, Safari on iOS) provide cookie management options in their privacy settings menus.

lodi291 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable Philippine law and regulatory requirements. The following general retention periods apply to the main categories of data held by lodi291:

• Account and Identity Data: Retained for the duration of your active lodi291 account plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• KYC and Verification Documents: Retained for a minimum of five (5) years from the date of the last transaction on your lodi291 account, as required by AMLA regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by PAGCOR and AMLA.
• Gameplay and Activity Data: Retained for the duration of your lodi291 account plus three (3) years following account closure.
• Communications Data: Live chat transcripts and support email records are retained for three (3) years from the date of the communication.
• Marketing Consent Records: Retained until consent is withdrawn or for two (2) years from the date of last marketing engagement, whichever is longer.

Upon expiry of the applicable retention period, lodi291 will securely delete or anonymise your personal data in accordance with our data disposal procedures. Anonymised data that can no longer be linked to you personally may be retained indefinitely for statistical and analytical purposes.

lodi291 implements a comprehensive suite of technical, organisational, and administrative security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our key security measures include:

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, lodi291 will notify the National Privacy Commission and, where required, the affected individuals, in accordance with the timeframes and procedures prescribed by the DPA and NPC Circular No. 16-03.

While lodi291 takes all reasonable steps to protect your personal data, no data transmission over the internet or data storage system is completely secure. Players are responsible for maintaining the security of their own lodi291 account credentials and should notify lodi291 immediately at [email protected] if they suspect any unauthorised access to their account.

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data processed by lodi291. To exercise any of these rights, please submit a written request to our Data Protection Officer at the contact details in Section 15:

• Right to Be Informed: You have the right to be informed of how lodi291 processes your personal data, as set out in this Privacy Policy.
• Right to Access: You may request a copy of the personal data that lodi291 holds about you, together with information about how it is used and with whom it has been shared.
• Right to Rectification: You may request that lodi291 correct any inaccurate or incomplete personal data it holds about you. You may also update much of your account information directly through your lodi291 account settings page.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (for consent-based processing), or where processing is otherwise unlawful. Note that this right is subject to lodi291's legal and regulatory data retention obligations under PAGCOR licensing conditions and AMLA.
• Right to Data Portability: You may request that lodi291 provide your personal data in a structured, commonly used, machine-readable format so that you may transfer it to another service provider.
• Right to Object: You may object to certain processing activities, including the processing of your personal data for direct marketing purposes. Objections to marketing will be acted upon immediately.
• Right to Lodge a Complaint: If you believe lodi291 has not handled your personal data in compliance with the DPA, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

lodi291 will respond to all verified data subject requests within thirty (30) calendar days of receipt, in accordance with the DPA. In cases of complex requests, lodi291 may extend this period by a further thirty (30) days, with notification provided to you.

The lodi291 Platform is strictly intended for individuals who are twenty-one (21) years of age or older, as mandated by PAGCOR regulations governing online gambling in the Republic of the Philippines. lodi291 does not knowingly collect, process, or store personal data from individuals under the age of 21.

All player accounts are subject to age verification as part of the KYC process. If lodi291 discovers or is notified that personal data has been collected from a person under the age of 21, lodi291 will immediately suspend the relevant account, delete all associated personal data, and refund any real-money deposits in the account to the source payment method, in accordance with PAGCOR requirements.

If you are a parent or guardian and believe that a minor may have registered on lodi291 without authorisation, please contact us immediately at [email protected]. We take underage gambling seriously and will act swiftly on all such notifications.

The lodi291 Platform may contain links to third-party websites, payment processors, or services. This Privacy Policy applies solely to the lodi291 Platform and does not extend to any third-party websites or services. lodi291 has no control over the privacy practices, data handling policies, or content of third-party websites and is not responsible for how those third parties collect or use your personal data.

When you interact with a third-party payment processor (such as GCash or Maya) to make a deposit or withdrawal, your interaction with that processor is governed by that processor's own privacy policy and terms of service. lodi291 encourages you to review the privacy policies of all third-party services you interact with in connection with your lodi291 account.

Game providers such as JILI, PG Soft, and Pragmatic Play operate game servers that process certain technical data in connection with your gameplay on lodi291. The processing of such data by game providers is conducted under data processing agreements with lodi291 and is subject to each provider's own applicable privacy policies.

lodi291's primary operations and data infrastructure are based in the Philippines. However, certain service providers and game providers engaged by lodi291 may operate from or maintain data infrastructure in other countries. In such cases, personal data may be transferred to and processed in jurisdictions outside the Philippines.

Where lodi291 transfers personal data internationally, we ensure that appropriate safeguards are in place to protect such data in accordance with the requirements of the Philippine Data Privacy Act, including: requiring receiving parties to execute Data Processing Agreements incorporating the NPC's standard contractual clauses or other equivalent contractual protections; transferring data only to countries that the NPC has recognised as providing adequate levels of data protection; or relying on binding corporate rules, certifications, or other approved transfer mechanisms.

If you have questions about the international transfer of your personal data or wish to obtain copies of the relevant safeguards in place, please contact our Data Protection Officer using the contact details in Section 15.

lodi291 reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements, or business operations. The most current version of this Policy will always be accessible at lodi291.bio/privacy-policy, with the effective date of the most recent revision clearly displayed at the top of the document.

For material changes to this Policy that significantly affect how lodi291 processes your personal data or materially alter your rights as a data subject, lodi291 will provide advance notice via your registered email address and/or via a prominent in-Platform notification, at least seven (7) calendar days before the revised Policy takes effect.

Your continued use of the lodi291 Platform following the effective date of any revision to this Policy constitutes your acceptance of the updated Policy. If you do not agree with any changes, you have the right to close your lodi291 account and request deletion of your personal data, subject to applicable legal retention requirements.

lodi291 has designated a Data Protection Officer (DPO) as required under the Philippine Data Privacy Act of 2012 and NPC Circular No. 17-01. The DPO is responsible for overseeing lodi291's compliance with the DPA and for handling data subject enquiries and requests.

If you wish to exercise any of your data subject rights under Section 10 of this Policy, have a question about how lodi291 processes your personal data, wish to opt out of marketing communications, or have a concern or complaint about lodi291's privacy practices, please contact our Data Protection Officer through the following channels:

If you are not satisfied with lodi291's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information on how to file a complaint with the NPC is available on the NPC's official website and through their public assistance channels.

lodi291 takes all data privacy complaints seriously and is committed to resolving them fairly, promptly, and in full compliance with the Philippine Data Privacy Act of 2012 and all applicable NPC issuances and circulars.