lodi29 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how lodi29 ("lodi29," "we," "us," or "our"), operator of the online gaming platform at lodi29.cam (the "Platform"), collects, uses, discloses, and safeguards personal information relating to registered players, visitors, and other individuals who interact with our Platform or services.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and relevant issuances of the National Privacy Commission ("NPC"). It also takes into account applicable requirements under PAGCOR's regulatory framework for online gaming operators.

By accessing the Platform, registering an account, or using any lodi29 service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, you must discontinue use of the Platform.

2. Data Controller Identity

For the purposes of the Data Privacy Act of 2012, lodi29 is the Personal Information Controller (PIC) in respect of the personal data collected through the Platform. This means lodi29 determines the purposes for which, and the means by which, your personal data is processed.

lodi29 operates the Platform under PAGCOR oversight and is responsible for ensuring that all data processing activities on the Platform comply with the DPA and applicable privacy regulations.

For privacy-related enquiries, please contact our Data Protection Officer as described in Section 14 of this Policy.

3. Personal Data We Collect

lodi29 collects only the personal data that is necessary and proportionate to the purposes described in this Policy. The categories of personal data we collect include the following:

4. How We Collect Your Data

lodi29 collects your personal data through the following means:

• Direct Provision: Information you submit when registering an account, completing KYC verification, making a deposit or withdrawal, contacting our support team, or updating your account settings.
• Automated Collection: Technical and gameplay data collected automatically through cookies, server logs, and analytics tools when you use the Platform. See Section 7 for details on our cookie practices.
• Payment Processors: Confirmation data received from GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT TRC20 network nodes when transactions are processed.
• Identity Verification Providers: Results of identity and document verification checks conducted by authorised third-party KYC service providers in connection with your account registration or verification process.
• Fraud Prevention Services: Risk signals and fraud indicators from third-party fraud detection platforms used to protect the integrity of the lodi29 Platform and its players.

5. Purpose & Legal Basis for Processing

lodi29 processes your personal data only where there is a lawful basis to do so under the Data Privacy Act of 2012. The primary purposes for which we process your data, and the corresponding legal basis, are set out below:

• Contract Performance: Processing necessary to create and manage your lodi29 account, process deposits and withdrawals, deliver gaming services, and fulfil our obligations under the lodi29 Terms & Conditions.
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), Know Your Customer (KYC) obligations, tax reporting requirements, and other applicable Philippine laws and regulations.
• Legitimate Interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and improving the lodi29 Platform — where such interests are not overridden by your rights and freedoms.
• Consent: Processing for direct marketing communications (email, SMS, or push notifications about promotions and new lodi29 features) where you have given your explicit consent. You may withdraw this consent at any time through your account preferences or by contacting support.

6. Sharing & Disclosure of Your Data

lodi29 does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients, solely to the extent necessary and in accordance with this Policy:

6.1 Service Providers (Personal Information Processors)

Third-party vendors who provide services on our behalf, including payment processing, KYC and identity verification, fraud detection, IT infrastructure, analytics, and customer support. All such processors are bound by written data processing agreements requiring them to protect your data to at least the standard required by the DPA.

6.2 Game Software Providers

Game providers whose titles are made available on lodi29 (such as live casino and slot studios) receive limited technical data necessary to operate the game session. These providers are contractually prohibited from using such data for independent marketing or profiling purposes.

6.3 Regulatory & Law Enforcement Authorities

lodi29 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), Philippine law enforcement agencies, or other competent authorities where required by law, court order, or regulatory direction.

6.4 Corporate Transactions

In the event of a merger, acquisition, or sale of all or substantially all assets of lodi29, your personal data may be transferred to the relevant successor entity, subject to that entity assuming obligations equivalent to those in this Policy. You will be notified of any such transfer via email or a prominent notice on the Platform.

7. Cookies & Tracking Technologies

lodi29 uses cookies and similar tracking technologies on the Platform to provide core functionality, improve user experience, and monitor Platform performance. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the Platform to function. These enable you to log in to lodi29, maintain your session, navigate between game pages, and use the wallet. These cookies cannot be disabled without breaking core functionality.
• Performance & Analytics Cookies: Used to collect aggregated, anonymised data about how players use lodi29 — such as which games are played most, common navigation paths, and page load times — so we can improve the Platform.
• Functional Cookies: Remember your preferences such as language, responsible gaming settings, and display options to personalise your lodi29 experience across sessions.
• Security Cookies: Used for fraud detection, bot prevention, and identifying unusual login patterns to protect your lodi29 account.

You may manage cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality. Strictly necessary and security cookies are exempt from consent requirements under applicable law.

8. Data Retention

lodi29 retains your personal data for the period necessary to fulfil the purposes outlined in this Policy, subject to the following retention guidelines:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping obligations and AMLA requirements.
• Transaction & Financial Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and BIR regulations.
• KYC & Identity Documents: Retained for the duration of the account and for five (5) years post-closure to support regulatory compliance and dispute resolution.
• Technical & Log Data: Typically retained for up to twelve (12) months for security, fraud monitoring, and Platform performance purposes.
• Marketing Consent Records: Retained for as long as the consent is active and for three (3) years thereafter as evidence of your consent or withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with your identity.

9. Security Measures

lodi29 implements a layered security architecture to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Our security measures include, but are not limited to:

• Transport Layer Security (TLS 1.2/1.3) encryption for all data transmitted between your device and lodi29 servers.
• Encryption of sensitive data fields (including financial identifiers) at rest using AES-256 encryption.
• Multi-factor authentication (OTP via SMS) for account login from new or unrecognised devices.
• Role-based access controls limiting lodi29 staff access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments of Platform infrastructure.
• Automated monitoring systems for suspicious login activity, unusual transaction patterns, and potential data breach indicators.
• Staff training on data privacy obligations and secure data handling practices.

While lodi29 employs all reasonable technical and organisational measures to protect your data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the security of your own login credentials and for promptly notifying lodi29 if you suspect any unauthorised access to your account.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by lodi29. You may exercise these rights by contacting our Data Protection Officer as described in Section 14:

lodi29 will respond to data subject requests within thirty (30) days of receipt, or within such other period as may be prescribed by NPC guidelines. We may request proof of identity before processing a data subject request to ensure your data is not disclosed to an unauthorised person.

11. Minors & Age Restriction

The lodi29 Platform is strictly restricted to individuals who are 21 years of age or older in accordance with PAGCOR regulations. lodi29 does not knowingly collect personal data from persons under 21 years of age.

lodi29 employs age verification measures during registration, including date-of-birth capture and document-based KYC verification. If lodi29 becomes aware that it has inadvertently collected personal data from a person under 21, we will take immediate steps to delete that data, close the associated account, and return any deposited funds to their source.

12. Cross-Border Data Transfers

lodi29 primarily stores and processes your personal data on servers located in the Philippines or in jurisdictions that provide an adequate level of data protection. Where your data is transferred to a third country (i.e., outside the Philippines) for service delivery purposes — for example, to a game studio or payment processor operating in another jurisdiction — lodi29 ensures that such transfers are:

• Made to countries or organisations that provide an adequate level of data protection as recognised under Philippine law or international standards;
• Governed by appropriate contractual safeguards, such as standard data protection clauses aligned with NPC guidelines; and
• Subject to lodi29 conducting due diligence on the recipient's data protection practices before transfer.

By using lodi29, you acknowledge and consent to such transfers where they are necessary for the delivery of Platform services.

13. Changes to This Policy

lodi29 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. Any material changes will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before the revised Policy takes effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. We encourage you to review this Policy periodically. Your continued use of lodi29 after the effective date of any amendment constitutes acceptance of the revised Policy.

14. Contact Us & Data Protection Officer

If you have questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by lodi29, please contact our Data Protection Officer (DPO) or support team through the following channels:

• Email (DPO): [email protected] — please use subject line "Privacy / DPA Request" for faster routing
• Live Chat: Available 24/7 on lodi29.cam — Tagalog and English supported, average response under 5 minutes

lodi29 will acknowledge data-related requests within 72 hours and provide a substantive response within 30 days unless the complexity of the request requires additional time, in which case we will notify you of the extension.

If you are not satisfied with lodi29's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through official government channels.