Privacy Policy – lodi646ph

01 Introduction

lodi646ph ("we," "us," "our," or "the Platform") operates the online casino and sports betting platform accessible at lodi646ph.asia. We are committed to protecting the privacy and personal data of all players, visitors, and users of the lodi646ph platform ("you" or "Data Subject").

This Privacy Policy describes how lodi646ph collects, uses, stores, shares, and protects personal data in connection with the operation of the lodi646ph platform. It also describes the rights available to you as a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations ("IRR").

By registering a lodi646ph account, accessing the platform, or using any lodi646ph service, 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. If you do not agree with this Privacy Policy, you must not use the lodi646ph platform.

This Privacy Policy should be read alongside the lodi646ph Terms & Conditions, which govern the overall relationship between you and lodi646ph.

02 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, lodi646ph is the Personal Information Controller (PIC) responsible for the personal data collected through the lodi646ph platform.

lodi646ph operates under PAGCOR regulatory guidelines. All data processing activities conducted by lodi646ph are carried out in accordance with the DPA, its IRR, and the issuances of the National Privacy Commission (NPC) of the Philippines.

lodi646ph has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. Contact details for the DPO are provided in Section 15 of this Policy.

03 Personal Data We Collect

lodi646ph collects the following categories of personal data in connection with the operation of the platform:

lodi646ph does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly required for identity verification and regulatory compliance purposes.

04 How We Collect Your Data

lodi646ph collects personal data through the following means:

• Direct Collection: Information you provide when registering a lodi646ph account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the lodi646ph platform, including through cookies, web beacons, log files, and similar tracking technologies. See Section 8 for details on our cookie practices.
• Third-Party Sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment verification data from payment processors including GCash, PayMaya, BPI, BDO, and Metrobank.
• Publicly Available Sources: In limited circumstances, lodi646ph may supplement your data with information from publicly available sources for fraud prevention or regulatory compliance purposes.

05 How We Use Your Personal Data

lodi646ph uses your personal data for the following purposes:

• Account Management: Creating, maintaining, and managing your lodi646ph player account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: Providing access to lodi646ph games, processing bets and wagers, crediting winnings, and delivering all other platform services you use.
• Financial Transactions: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard; maintaining accurate transaction records; and reconciling account balances.
• Regulatory Compliance: Fulfilling KYC, AML, and other obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws. This includes reporting suspicious transactions to the Anti-Money Laundering Council (AMLC) where required.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behavior; administering deposit limits, loss limits, session limits, and self-exclusion requests; and complying with responsible gaming obligations under PAGCOR guidelines.
• Security and Fraud Prevention: Detecting, investigating, and preventing fraudulent activity, money laundering, collusion, and other prohibited conduct on the lodi646ph platform.
• Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance through the lodi646ph support team.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive marketing communications. You may opt out at any time by contacting customer support.
• Platform Improvement: Analyzing usage patterns and player behavior in aggregate to improve the lodi646ph platform, optimize game offerings, and enhance the overall player experience.
• Legal Proceedings: Establishing, exercising, or defending legal claims in connection with the lodi646ph platform or its players.

06 Legal Basis for Processing

lodi646ph processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• 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 use of non-essential cookies.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and lodi646ph — specifically, the Terms & Conditions governing your player account. This covers account management, transaction processing, and service delivery.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to lodi646ph, including KYC verification, AML reporting, PAGCOR regulatory requirements, and tax obligations under Philippine law.
• Legitimate Interests: Where processing is necessary for the legitimate interests of lodi646ph, provided those interests are not overridden by your rights and interests. This includes fraud prevention, platform security, responsible gaming monitoring, and platform improvement activities.

Where lodi646ph relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

07 Data Sharing and Disclosure

lodi646ph does not sell, rent, or trade your personal data to third parties. We share your personal data only in the following limited circumstances:

• Service Providers: lodi646ph shares data with trusted third-party service providers who assist in operating the platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard), KYC and identity verification providers, game software suppliers, cloud hosting providers, and customer support platform providers. All service providers are contractually bound to process your data only as instructed by lodi646ph and in accordance with applicable data protection laws.
• Regulatory Authorities: lodi646ph discloses personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine regulatory bodies where required by law or regulatory directive.
• Law Enforcement: lodi646ph may disclose personal data to law enforcement agencies, courts, or other government authorities where required by a valid legal order, warrant, or subpoena issued under Philippine law.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of lodi646ph's business, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and the privacy practices of the acquiring entity.
• With Your Consent: lodi646ph may share your data with third parties in other circumstances where you have given your explicit prior consent to such sharing.

08 Cookies and Tracking Technologies

lodi646ph uses cookies and similar tracking technologies on the lodi646ph platform to enhance your experience, maintain session security, and analyze platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the lodi646ph platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: These cookies collect anonymized information about how players use the lodi646ph platform, such as which pages are visited most frequently and whether error messages are received. This data helps lodi646ph improve platform performance.
• Functional Cookies: These cookies allow the lodi646ph platform to remember your preferences, such as your preferred language, display settings, and responsible gaming limits, to provide a more personalized experience.
• Analytics Cookies: lodi646ph uses analytics tools to understand aggregate player behavior and platform usage patterns. Analytics data is processed in anonymized or pseudonymized form and is not used to identify individual players.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the lodi646ph platform. Strictly necessary cookies cannot be disabled as they are required for the platform to operate securely.

09 Data Retention

lodi646ph retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account Data: Retained for the duration of your active lodi646ph account, plus a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and Philippine AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under the Anti-Money Laundering Act and PAGCOR regulations.
• KYC Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, or longer if the records are relevant to an ongoing dispute or legal proceeding.
• Marketing Preferences: Retained until you withdraw your consent to marketing communications, plus a reasonable period to process the opt-out request.
• Technical and Usage Data: Retained for up to twelve (12) months from collection, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, lodi646ph will securely delete or anonymize your personal data in accordance with its data disposal procedures.

10 Data Security

lodi646ph implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the lodi646ph platform is encrypted using TLS (Transport Layer Security). Sensitive data stored on lodi646ph servers is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to lodi646ph personnel and service providers who have a legitimate need to access it for their job functions. All access is logged and audited.
• Two-Factor Authentication: lodi646ph offers two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Regular Security Audits: lodi646ph conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in the platform.
• Incident Response: lodi646ph maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, lodi646ph will notify the National Privacy Commission (NPC) and affected players in accordance with the DPA's breach notification requirements.

While lodi646ph takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your lodi646ph account credentials and for notifying us immediately if you suspect unauthorized access to your account.

11 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by lodi646ph:

• Right to Be Informed: You have the right to be informed about how lodi646ph collects and processes your personal data. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data lodi646ph holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data lodi646ph holds about you.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to lodi646ph's 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 lodi646ph's 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) of the Philippines if you believe lodi646ph has violated your data privacy rights.

To exercise any of these rights, please contact the lodi646ph Data Protection Officer using the contact details provided in Section 15. lodi646ph will respond to all valid data subject requests within thirty (30) days of receipt, in accordance with the DPA's requirements.

12 Children's Privacy

The lodi646ph platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. lodi646ph does not knowingly collect personal data from individuals under the age of 21.

If lodi646ph discovers that personal data has been collected from a person under the age of 21, the relevant account will be immediately closed, all associated data will be deleted (subject to any legal retention obligations), and any deposits will be returned at lodi646ph's discretion after deducting applicable processing costs.

If you are a parent or guardian and believe that your child has registered a lodi646ph account or provided personal data to lodi646ph, please contact our Data Protection Officer immediately using the contact details in Section 15 so that we can take appropriate action.

13 International Data Transfers

lodi646ph's primary operations and data storage are based in the Philippines. However, some of lodi646ph's third-party service providers — including game software suppliers, cloud infrastructure providers, and KYC verification services — may process personal data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, lodi646ph ensures that appropriate safeguards are in place to protect your 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 with overseas service providers that require them to process personal data in accordance with the Philippine Data Privacy Act and this Privacy Policy.
• Conducting due diligence on overseas service providers to verify their data security practices before engaging them.

By using the lodi646ph platform, you consent to the transfer of your personal data to overseas service providers as described in this section, subject to the safeguards outlined above.

14 Changes to This Privacy Policy

lodi646ph 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, lodi646ph will:

• Post the updated Privacy Policy on the lodi646ph website with a revised "Last Updated" date.
• Notify registered players of material changes via email or an in-platform notification.
• Where required by law, obtain fresh consent from players before implementing changes that affect the legal basis for processing their personal data.

Your continued use of the lodi646ph platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Privacy Policy, you must stop using the platform and close your account.

lodi646ph recommends that you review this Privacy Policy periodically to stay informed of how your personal data is being handled.

15 Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by lodi646ph, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 via the lodi646ph website
• Response Time: lodi646ph aims to acknowledge all data privacy inquiries within 48 hours and to provide a substantive response within 30 days

If you are not satisfied with lodi646ph's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the government body responsible for administering and enforcing the Data Privacy Act of 2012.

lodi646ph's Data Protection Officer and customer support team are available to assist players across Manila, Cebu, Davao, Quezon City, Makati, and all other regions of the Philippines in both English and Filipino.