loteria Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how loteria ("loteria," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you," "Player," or "User") who access or use the loteria online gaming platform at loteria.asia and all associated services, features, and content (collectively, the "Platform").

loteria is committed to protecting the privacy and personal data of all players, particularly in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

By registering an account or using the Platform, 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 with this Policy, please discontinue use of the Platform and contact us to close your account.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and applicable data protection legislation, loteria acts as the Personal Information Controller (PIC) with respect to the personal data collected through the Platform.

This means loteria determines the purposes and means of processing your personal data. Where loteria engages third-party service providers to process data on its behalf (for example, payment processors or KYC verification providers), those parties act as Personal Information Processors (PIPs) and are contractually bound to process data only in accordance with loteria's instructions and this Policy.

If you have any questions about how your data is controlled or processed, please contact our Data Protection Officer using the details provided in Section 15 of this Policy.

3. Personal Data We Collect

loteria collects the following categories of personal data from players:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., Philippine National ID, passport, driver's license, SSS/GSIS number).
• Contact Data: Email address, Philippine mobile number, and residential address (including barangay, city/municipality, province, and postal code).
• Account Data: Username, encrypted password, account registration date, account status, and communication preferences.
• Financial Data: Payment method details (e.g., GCash mobile number, PayMaya account, bank account name and number for BPI, BDO, Metrobank, or other accepted banks), transaction history, deposit and withdrawal records, and wallet balances.
• Gaming Data: Game history, wager amounts, win/loss records, session durations, bonus usage, and responsible gaming tool activations.
• Technical Data: IP address, device type and model, operating system, browser type and version, screen resolution, and unique device identifiers.
• Usage Data: Pages visited, features accessed, click patterns, session timestamps, and navigation paths within the Platform.
• Communications Data: Records of your interactions with our customer support team, including live chat transcripts and email correspondence.
• KYC Verification Data: Copies of government-issued identification documents, selfie photographs, and proof of address documents submitted during the verification process.

loteria does not intentionally collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

4. How We Collect Your Data

loteria collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs.
• Third-Party Sources: Identity and fraud-check data received from KYC verification providers, payment processors, and fraud prevention services engaged by loteria to verify player information and protect platform integrity.
• Regulatory Sources: Information received from PAGCOR or other regulatory bodies in connection with compliance obligations, including self-exclusion registers.

5. How We Use Your Personal Data

loteria processes your personal data for the following purposes:

• Account Management: To register, maintain, and administer your loteria account, including processing your loteria Login credentials and account settings.
• Service Delivery: To provide access to games, process deposits and withdrawals, credit bonuses, and deliver all Platform features and services.
• Identity Verification & KYC: To verify your identity and age (21+ requirement), comply with anti-money laundering (AML) obligations, and prevent fraud and unauthorized account access.
• Regulatory Compliance: To fulfill obligations under PAGCOR compliance guidelines, the Philippine Data Privacy Act, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws and regulations.
• 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, identify potential problem gambling indicators, and administer responsible gaming tools including deposit limits, cooling-off periods, and self-exclusion.
• Marketing & Promotions: To send you relevant promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct internal research, and improve the performance, security, and user experience of the Platform.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, unauthorized access, cheating, collusion, and other prohibited activities on the Platform.

loteria will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

6. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform the contract between you and loteria — specifically, to operate your account, deliver gaming services, and process financial transactions.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR compliance requirements, AML obligations, and tax reporting duties.
• Legitimate Interests: Processing is necessary for loteria's legitimate interests in preventing fraud, ensuring platform security, improving services, and conducting responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

loteria does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers engaged to process deposits and withdrawals. These providers receive only the data necessary to complete the relevant transaction.
• KYC & Identity Verification Providers: Third-party services engaged to verify player identity and age in compliance with regulatory requirements.
• Fraud Prevention & Security Services: Providers that assist loteria in detecting and preventing fraudulent activity, unauthorized access, and money laundering.
• Game Content Providers: Software providers whose games are hosted on the Platform may receive anonymized or pseudonymized gaming data for technical and licensing purposes.
• Regulatory & Law Enforcement Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where disclosure is required by law, court order, or regulatory directive.
• Professional Advisors: Legal counsel, auditors, and accountants engaged by loteria, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of loteria's business, your personal data may be transferred to the relevant successor entity, subject to equivalent data protection commitments.

All third-party processors engaged by loteria are contractually required to implement appropriate technical and organizational security measures and to process personal data only in accordance with loteria's documented instructions.

8. Cookies & Tracking Technologies

The loteria Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze platform performance. The following types of cookies may be used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including maintaining your logged-in session, remembering your language preferences, and enabling secure transactions. These cookies cannot be disabled without affecting core Platform functionality.
• Performance & Analytics Cookies: Used to collect anonymized data about how players interact with the Platform, including pages visited, session duration, and error occurrences. This data helps loteria identify areas for improvement.
• Functional Cookies: Used to remember your preferences and personalize your experience, such as your preferred game categories or display settings.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the Platform.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality and performance of the Platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

9. Data Retention

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

• Active Account Data: Retained for the duration of your account's active status and for a period of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• 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 five (5) years following account closure or the last transaction date, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the relevant interaction.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years thereafter as evidence of consent.
• Technical & Usage Logs: Retained for up to twelve (12) months for security and performance analysis purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with loteria's data disposal procedures.

10. Data Security

loteria implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and the loteria Platform is encrypted using industry-standard Secure Socket Layer (SSL) / Transport Layer Security (TLS) protocols.
• Password Security: Account passwords are stored using strong one-way cryptographic hashing algorithms. loteria never stores passwords in plain text.
• Access Controls: Access to personal data is restricted to authorized loteria personnel and third-party processors on a strict need-to-know basis, enforced through role-based access controls.
• Secure Infrastructure: The Platform is hosted on secure, regularly audited server infrastructure with firewalls, intrusion detection systems, and continuous security monitoring.
• Regular Security Assessments: loteria conducts periodic security reviews and vulnerability assessments to identify and remediate potential risks to player data.

While loteria takes all reasonable precautions to protect your data, no online platform can guarantee absolute security. In the event of a personal data breach that poses a risk to your rights and freedoms, loteria will notify the National Privacy Commission and affected players in accordance with the requirements of the Philippine Data Privacy Act.

11. Your Data Privacy Rights

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

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of Access: The right to request a copy of the personal data loteria holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data in your account.
• Right to Erasure: 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 loteria's legal retention obligations.
• Right to Object: 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: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. loteria will respond to all verified data subject requests within thirty (30) days of receipt. We may require identity verification before processing your request to protect against unauthorized access to your data.

12. Children's Privacy

The loteria Platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gaming regulations applicable to casino-style online gaming. loteria does not knowingly collect personal data from individuals under the age of 21.

If loteria becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact our support team immediately so that we can investigate and take appropriate action.

Age verification is a mandatory step in the loteria registration and KYC process. Players who cannot provide satisfactory proof of age will not be permitted to access real-money gaming features on the Platform.

13. Third-Party Links

The loteria Platform may contain references to third-party services such as payment providers (GCash, PayMaya, BPI, BDO, Metrobank) and game software providers. While loteria takes care to engage reputable third-party partners, we are not responsible for the privacy practices or content of any third-party websites or services.

When you interact with a third-party service in connection with your use of the Platform (for example, completing a GCash payment), your data will be subject to that third party's own privacy policy. loteria encourages you to review the privacy policies of any third-party services you use in connection with the Platform.

14. Updates to This Privacy Policy

loteria reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. When material changes are made, we will notify registered players by email to the address on file and/or by displaying a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how loteria protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Policy.

15. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way loteria processes your personal data, please contact our Data Protection Officer through the following channels:

• Live Chat: Available 24/7 directly through the Platform — the fastest way to reach our team
• Email: [email protected]

Our support team serves Filipino players across all regions — from Metro Manila, Cebu, Davao, Quezon City, and Makati to every corner of the archipelago. We aim to acknowledge all data privacy requests within five (5) business days and to resolve them within thirty (30) days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines, the regulatory body responsible for enforcing the Data Privacy Act of 2012.