Privacy Policy

This Privacy Policy ("Policy") describes how lode291 ("we," "us," or "our") collects, uses, stores, and discloses personal information about individuals ("you" or "the player") who access or use the lode291 platform, including our website, mobile interface, and all associated services.

By registering an account on lode291 or otherwise using our services, 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, you must not use the lode291 platform.

This Policy applies to all personal data collected by lode291 in connection with the provision of our online gaming services to players in the Philippines and other permitted jurisdictions.

lode291 collects the following categories of personal data:

Identity Data:

• Full legal name as it appears on a government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Gender (optional, for personalization purposes)
• Nationality and country of residence
• Government-issued ID number (e.g., Philippine passport, SSS, UMID, PhilSys)

Contact Data:

• Email address
• Mobile number (used for OTP verification and account security)
• Residential address (city, province, postal code)

Financial Data:

• GCash or PayMaya account number linked to your lode291 account
• Bank account details (BPI, BDO, Metrobank, or other approved banks) where applicable
• Transaction history including deposits, withdrawals, and wager records

Technical Data:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session logs, login timestamps, and activity records

Gaming Data:

• Game history, bet amounts, win/loss records
• Responsible gaming preferences and self-imposed limits
• Bonus and promotion usage history

lode291 collects personal data through the following means:

• Direct interactions: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions.
• Automated technologies: When you use the lode291 platform, we automatically collect technical data through cookies, server logs, and similar tracking technologies.
• Third-party sources: We may receive data from payment processors (e.g., GCash, PayMaya, BPI), identity verification providers, fraud prevention services, and analytics partners.
• KYC verification: During the identity verification process, you may be required to submit copies of government-issued identification documents. These are processed securely and retained only as long as required by law.

lode291 uses your personal data for the following purposes:

• Account management: To create, maintain, and secure your lode291 account, including identity verification and password recovery.
• Service delivery: To process deposits and withdrawals, settle bets, award bonuses, and provide customer support.
• Legal compliance: To comply with PAGCOR regulations, anti-money laundering (AML) obligations, and other applicable Philippine laws, including the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized access, and other prohibited conduct.
• Responsible gaming: To monitor gaming patterns and enforce responsible gaming tools such as deposit limits and self-exclusion where requested or required.
• Communications: To send transactional notifications (e.g., deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about lode291 offers.
• Platform improvement: To analyze usage patterns and improve the lode291 platform, user experience, and game offerings.

lode291 will not use your personal data for any purpose incompatible with those listed above without first obtaining your explicit consent.

lode291 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform our contract with you — i.e., to provide the lode291 gaming services you have registered for.
• Legal obligation: Processing is required to comply with applicable laws and regulations, including PAGCOR licensing conditions, AML obligations, and tax reporting requirements.
• Legitimate interests: Processing is necessary for lode291's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights.
• Consent: For certain processing activities — such as sending promotional communications — we rely on your explicit consent, which you may withdraw at any time.

lode291 does not sell your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment providers, to process your financial transactions.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and comply with regulatory requirements.
• Regulatory authorities: PAGCOR and other competent Philippine government agencies, where disclosure is required by law or regulation.
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and analytics service providers who process data on our behalf under strict data processing agreements.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers where necessary for legal proceedings or compliance purposes.

All third parties with whom lode291 shares personal data are required to maintain appropriate security standards and to process data only in accordance with our instructions and applicable law.

lode291 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law.

• Account data and transaction records are retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AML regulatory requirements.
• KYC documents are retained for the duration of your account and for five (5) years thereafter.
• Technical and session log data is retained for up to twelve (12) months for security and fraud prevention purposes.
• Marketing preference data is retained until you withdraw your consent or request deletion.

Upon expiry of the applicable retention period, lode291 will securely delete or anonymize your personal data.

lode291 implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the lode291 platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Multi-factor authentication (MFA) options for account login.
• Regular security audits and penetration testing by independent third parties.
• Strict access controls limiting employee access to personal data on a need-to-know basis.

While lode291 takes all reasonable steps to protect your data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your lode291 account credentials.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by lode291:

• Right to be informed: You have the right to know what personal data lode291 holds about you and how it is being processed.
• Right of access: You may request a copy of the personal data lode291 holds about you at any time.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to lode291's legal retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You may request that lode291 provide your personal data in a structured, commonly used, machine-readable format.
• 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 your data rights have been violated.

To exercise any of these rights, please contact lode291's Data Protection Officer via the contact details provided in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days.

lode291 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how you use the lode291 platform.

We use the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function. These cannot be disabled and do not require your consent.
• Performance cookies: Collect anonymized data about how players use lode291, helping us improve platform performance and user experience.
• Functional cookies: Remember your preferences such as language settings and display options.
• Targeting cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the lode291 platform.

lode291 strictly prohibits the use of our platform by persons under 21 years of age, in accordance with Philippine law. We do not knowingly collect personal data from individuals under 21.

If lode291 discovers that personal data has been collected from a person under 21, we will immediately suspend the associated account, delete the data, and return any deposited funds at our sole discretion.

lode291 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email or an in-platform notification prior to the changes taking effect.

The updated Policy will be published on this page with a revised "Last updated" date. Your continued use of the lode291 platform after the effective date of any revised Policy constitutes your acceptance of the changes.

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact lode291's Data Protection Officer:

Data Protection Officer: [email protected]

General Support: [email protected]

Email addresses above are displayed as plain text for reference only. Our primary support channel is live chat, available 24/7 inside your lode291 account dashboard. We aim to respond to all data privacy requests within 30 days.