1xlote Privacy Policy

1. Data Controller

1xlote ("we," "us," or "our") operates the online gaming platform accessible at 1xlote.org and is the data controller responsible for the personal information collected through this platform. As a data controller, 1xlote determines the purposes and means of processing your personal data in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA) of the Philippines, and its Implementing Rules and Regulations.

By registering an account on 1xlote or by 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.

2. Data We Collect

1xlote collects personal data that is necessary to provide you with a safe, legal, and enjoyable gaming experience. The categories of data we collect include:

2.1 Registration & Identity Data

• Full legal name as it appears on your Philippine government-issued ID
• Date of birth (used to verify you are 21 years of age or older)
• Gender
• Nationality and country of residence
• Government-issued ID type and number (e.g., PhilSys ID, passport, driver's license, UMID)

2.2 Contact Data

• Philippine mobile number
• Email address
• Residential address (city, province, region)

2.3 Financial Data

• GCash or PayMaya/Maya account reference (masked)
• Bank account details for withdrawal processing (bank name, account name, account number — stored in encrypted form)
• Transaction history: deposits, withdrawals, bonus credits, and wager records

2.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session timestamps, login history, and session duration
• Game activity logs: games played, wager amounts, outcomes, and session data
• Clickstream and navigation data within the 1xlote platform

2.5 Communications Data

• Records of your communications with 1xlote customer support (chat transcripts, email correspondence)
• Survey responses and feedback submitted through the platform
• Promotional opt-in preferences

3. How We Use Your Data

1xlote processes your personal data for the following purposes:

1xlote 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 permitted by applicable Philippine law.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 1xlote processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the 1xlote Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with Philippine laws and regulations, including anti-money laundering obligations, PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for direct marketing communications and non-essential cookies, where you have provided explicit, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Sharing Your Data

1xlote does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: GCash, PayMaya/Maya, and participating Philippine banks, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Game software providers: Licensed game studios and RNG certification bodies whose games are hosted on the 1xlote platform.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory directive.
• IT and security service providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged to operate and secure the 1xlote platform.
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third-party service providers engaged by 1xlote are contractually required to process your personal data only for the specified purpose, to maintain appropriate security standards, and to comply with applicable Philippine data protection law.

6. Data Retention

1xlote retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and regulatory record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing preferences: Retained until you withdraw consent or close your account, whichever is earlier.
• Technical and usage data: Retained in aggregated or anonymized form for up to three (3) years for analytics purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 1xlote's data disposal procedures.

7. Data Security

1xlote implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 1xlote platform.
• Encryption at rest for sensitive financial data, including bank account details and payment method references.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the 1xlote platform.
• Multi-factor authentication (MFA) for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

8. Cookies & Tracking Technologies

1xlote uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyze usage patterns. The categories of cookies we use are:

• Strictly necessary cookies: Required for the platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and display options. These improve your experience but are not essential.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the 1xlote platform, helping us identify areas for improvement. These are only set with your consent.
• Marketing cookies: Used to deliver relevant promotional content within the 1xlote platform. These are only set with your explicit consent.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies may affect the functionality of the 1xlote platform. Withdrawing consent for analytics or marketing cookies will not affect your ability to use core platform features.

9. Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 1xlote:

• Right to be informed: The right to know what personal data 1xlote collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data 1xlote holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to 1xlote's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact the 1xlote Data Protection Officer using the contact details in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days, as required by the DPA.

10. Minors

The 1xlote platform is strictly intended for persons who are 21 years of age or older, in accordance with Philippine law governing casino-style gambling. 1xlote does not knowingly collect personal data from persons under the age of 21.

If 1xlote becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted immediately and the associated account will be closed. If you believe that a minor has registered on 1xlote, please contact us immediately using the details in Section 13.

11. Cross-Border Data Transfers

Some of 1xlote's service providers, including cloud infrastructure and game software providers, may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to the Philippines, 1xlote will ensure that appropriate safeguards are in place, such as contractual clauses approved by the National Privacy Commission, to protect your personal data in accordance with the DPA.

By using the 1xlote platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

12. Changes to This Policy

1xlote reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via email or in-platform notification at least seven (7) days before taking effect.

The current version of this Privacy Policy is always available on this page. The "Last updated" date at the top of this document indicates when the most recent revision was made. Your continued use of the 1xlote platform following the effective date of any revision constitutes your acceptance of the updated Policy.

13. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or need to contact 1xlote's Data Protection Officer, please reach out using the details below:

• Data Protection Officer: 1xlote Privacy Team
• Email: [email protected]
• Platform: 1xlote.org

We aim to respond to all data rights requests and privacy inquiries within thirty (30) days of receipt. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.