Privacy Policy — 291lodi Casino Philippines

291lodi ("we," "us," or "our") operates the online gaming platform accessible at https://291lodi.com (the "Platform"). We are committed to protecting the personal information of every user ("you," "your," or "User") who registers, browses, or interacts with our Platform. This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as well as applicable guidelines issued by the National Privacy Commission (NPC).

This Privacy Policy applies to all personal data collected through the 291lodi Platform, including data collected via our website, mobile-optimized interface, live chat support, email correspondence, and any other channel through which you interact with us. By creating an account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

291lodi collects personal data that is necessary for the operation of the Platform, the provision of gaming services, regulatory compliance, and the improvement of user experience. The categories of personal data we collect include the following:

We do not collect personal data beyond what is necessary for the purposes described in this Policy. You are not required to provide all categories of data to browse the Platform; however, certain services — including account registration, deposits, withdrawals, and bonus eligibility — require the provision of specific personal data.

291lodi uses the personal data we collect for the following specific purposes:

• Account Creation and Management: To register your account, verify your identity, and maintain your account in good standing on the 291lodi Platform.
• Service Delivery: To provide access to all gaming products available on 291lodi, including live casino, slots, bingo, sports betting, and Playtech Live games.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels.
• KYC and Fraud Prevention: To verify your identity, confirm your age (21+), detect and prevent fraudulent activity, money laundering, and other prohibited conduct.
• Regulatory Compliance: To fulfill our obligations under Philippine gaming regulations, PAGCOR requirements, and the Data Privacy Act of 2012, including record-keeping and reporting obligations.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support channels.
• Responsible Gaming: To monitor gaming behavior, enforce self-exclusion requests, apply deposit limits, and provide responsible gaming tools to users who request them.
• Marketing and Promotions: To send you information about 291lodi promotions, bonuses, and new game releases — but only where you have provided your consent to receive such communications.
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the overall performance and user experience of the 291lodi Platform.
• Security: To protect the integrity of the Platform, detect unauthorized access, and maintain the security of your account and personal data.

291lodi processes your personal data on the following legal bases, as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications or the processing of sensitive personal information for KYC purposes.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and 291lodi — specifically, the Terms & Conditions you agreed to upon registration. This includes account management, payment processing, and service delivery.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to 291lodi, including PAGCOR regulatory requirements, anti-money laundering (AML) obligations under Republic Act No. 9160 (Anti-Money Laundering Act), and tax reporting requirements.
• Legitimate Interests: Where processing is necessary for the legitimate interests of 291lodi, provided that such interests are not overridden by your rights and freedoms. This includes fraud prevention, platform security, and service improvement activities.

291lodi does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may, however, share your personal data with the following categories of recipients where necessary and lawful:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors require certain personal and financial data to process your transactions securely.
• Game Content Providers: Third-party game studios and live dealer providers (such as Playtech) may receive limited technical data necessary to deliver their games on the 291lodi Platform.
• KYC and Identity Verification Partners: Regulated third-party identity verification services may process your identity documents to assist with KYC compliance.
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities may receive your data where required by law or upon lawful request.
• IT and Security Service Providers: Cloud hosting providers, cybersecurity firms, and technical support partners who process data on our behalf under strict data processing agreements.
• Legal and Professional Advisors: Lawyers, auditors, and compliance consultants who are bound by professional confidentiality obligations.

All third parties with whom 291lodi shares personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

The 291lodi Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze Platform usage. A cookie is a small text file placed on your device by a website when you visit it.

We use the following types of cookies on the 291lodi Platform:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Performance and Analytics Cookies: These cookies collect anonymized information about how users interact with the Platform — such as which pages are visited most frequently and whether error messages are received — to help us improve Platform performance.
• Functional Cookies: These cookies remember your preferences (such as language settings and responsible gaming limits) to provide a more personalized experience on 291lodi.
• Marketing Cookies: Where you have consented, these cookies track your browsing activity to deliver relevant promotional content about 291lodi offers and games.

291lodi retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following retention periods apply:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and AML obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine AML regulations.
• KYC Documents: Retained for a minimum of five (5) years following the completion of the KYC process or account closure, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.
• Technical and Log Data: Retained for up to twelve (12) months for security and performance monitoring purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 291lodi's data disposal procedures. Anonymized data that can no longer be linked to an identifiable individual may be retained indefinitely for statistical and analytical purposes.

291lodi implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security framework includes:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the 291lodi Platform is encrypted using industry-standard 256-bit SSL/TLS protocols — the same level of encryption used by Philippine banks and financial institutions.
• Two-Factor Authentication (2FA): 291lodi supports two-factor authentication for account login, providing an additional layer of security beyond your password.
• Access Controls: Access to personal data within 291lodi's systems is restricted on a strict need-to-know basis. Staff members are granted access only to the data necessary to perform their specific job functions.
• Secure Data Storage: Personal data is stored on secure, access-controlled servers with regular security audits and vulnerability assessments.
• Incident Response: 291lodi maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) and affected users in accordance with the Data Privacy Act of 2012.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by 291lodi:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy.
• Right to Access: You have the right to request a copy of the personal data that 291lodi holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request the correction of any inaccurate or incomplete personal data that 291lodi holds about you.
• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to any overriding legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that your data protection rights have been violated.

The 291lodi Platform is strictly intended for users who are 21 years of age or older, in accordance with Philippine gaming regulations and PAGCOR guidelines. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any funds held in an underage account will be handled in accordance with applicable PAGCOR regulations.

291lodi primarily processes and stores personal data within the Philippines. However, in certain circumstances — such as when using internationally based cloud infrastructure, game content providers, or technical service partners — your personal data may be transferred to and processed in countries outside the Philippines.

Where such international transfers occur, 291lodi ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the National Privacy Commission.
• Implementing contractual clauses in agreements with international service providers that require them to protect your data to the same standard as required under Philippine law.
• Conducting due diligence on all international data processors to verify their data protection practices before engaging their services.

By using the 291lodi Platform, you acknowledge and consent to the transfer of your personal data to international service providers where necessary for the delivery of our services, subject to the safeguards described above.

291lodi reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will update the "Last Updated" date at the top of this Policy and, where appropriate, notify registered users via email or in-platform notification.

We encourage you to review this Privacy Policy periodically to stay informed about how 291lodi protects your personal data. Your continued use of the Platform following the posting of any updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with the updated Policy, you must cease using the Platform and may request account closure by contacting our support team.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 291lodi, please contact our Data Privacy Officer (DPO). Our DPO is responsible for overseeing 291lodi's compliance with the Data Privacy Act of 2012 and is your primary point of contact for all data protection matters.

You may also reach our general customer support team, available 24 hours a day, 7 days a week, in both English and Filipino, via the live chat feature on the Platform or by email.