lol291 Privacy Policy

1. About This Policy

1.1 lol291 is committed to protecting the privacy and personal information of all individuals who interact with our platform — whether you are a registered player, a visitor browsing the Site, or a person who contacts our support team.

1.2 This Policy explains: what personal data we collect; the purposes for which we collect and use it; the circumstances in which we may share it with third parties; how long we retain it; the security measures we apply to protect it; and the rights available to you under Philippine law with respect to your personal data.

1.3 This Policy should be read together with the lol291 Terms & Conditions and our Responsible Gaming Policy. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

2.1 For the purposes of the Philippine Data Privacy Act of 2012, lol291 acts as the personal information controller ("PIC") in respect of personal data collected from users of the lol291.club platform.

2.2 As the PIC, lol291 determines the purposes and means of processing personal data of registered players and Site visitors. Where third-party service providers process personal data on our behalf (for example, payment processors, game providers, or fraud detection services), they do so as personal information processors ("PIP") acting under our written instructions and subject to appropriate data processing agreements.

2.3 Contact details for privacy-related inquiries are set out in Section 14 of this Policy.

3. Information We Collect

3.1 lol291 collects personal data in the following categories:

3.1.1 Registration & Identity Data: When you create a lol291 account, we collect your full legal name, date of birth, gender, nationality, residential address (including barangay, city, province, and ZIP code in the Philippines), email address, and mobile phone number.

3.1.2 Verification & KYC Data: To comply with anti-money laundering (AML) obligations and verify your identity and age, we may collect copies of government-issued identification documents (such as a Philippine passport, SSS ID, UMID, PhilSys ID, or driver's license), proof of address documents, and selfie photographs for facial verification.

3.1.3 Financial & Transaction Data: Details of deposits and withdrawals processed through your lol291 account, including transaction amounts in Philippine Peso (₱), dates, payment method identifiers (GCash mobile number, BDO/BPI/Metrobank account references), and transaction reference numbers. We do not store full bank card numbers or complete GCash credentials on our servers.

3.1.4 Gaming & Activity Data: Your game session history, bets placed, games accessed, tournament participation, bonus claims and wagering progress, login timestamps, session duration, and preference settings.

3.1.5 Technical & Device Data: IP address, device type and model, operating system, browser type and version, screen resolution, referring URLs, and Site navigation patterns collected automatically when you access the Site.

3.1.6 Communications Data: Records of your communications with lol291 support via live chat, email, or any other channel, including the content of those communications and any attachments submitted.

3.1.7 Responsible Gaming Data: Any responsible gaming preferences you set, including deposit limits, session timers, cool-down periods, or self-exclusion elections, and records of any responsible gaming interventions applied to your account.

4. How We Use Your Personal Data

4.1 lol291 processes your personal data for the following purposes:

4.2 lol291 will not process your personal data for purposes incompatible with those listed above without first obtaining your explicit consent or as otherwise permitted by the PDPA.

5. Legal Basis for Processing

5.1 lol291 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract between you and lol291 — including account registration, game provision, payment processing, and customer support;
• Legal Obligation: Processing required to comply with applicable Philippine law and regulatory requirements, including AML obligations, KYC verification, tax reporting, and PAGCOR-aligned compliance measures;
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where those interests do not override your fundamental rights;
• Consent: Processing for marketing communications and non-essential cookies, where your freely given, specific, informed, and unambiguous consent has been obtained. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

6.1 lol291 does not sell, rent, or trade your personal data to third parties for their independent marketing purposes.

6.2 We may share personal data with the following categories of recipients where necessary:

• Payment Processors: GCash (Mynt), PayMaya (Maya Bank), BDO Unibank, BPI, Metrobank, UnionBank, and other payment service providers — for the sole purpose of processing your financial transactions;
• Game Providers: Third-party game studios and live casino operators whose games are hosted on the lol291 platform — limited to data necessary for game session management;
• Identity Verification Services: KYC and AML compliance service providers who assist in verifying player identities and screening against sanctions and politically exposed persons (PEP) lists;
• Fraud Prevention Services: Technology partners who assist in detecting and preventing fraudulent activity, responsible gaming violations, and multi-accounting;
• Regulatory Authorities: PAGCOR and other Philippine government agencies, law enforcement, or judicial bodies, where we are legally required or compelled to disclose information;
• Professional Advisers: Legal counsel, auditors, and other professional service providers bound by confidentiality obligations.

6.3 All third-party processors engaged by lol291 are subject to written data processing agreements requiring them to process personal data only on our documented instructions and to maintain appropriate security measures.

6.4 In the event of a merger, acquisition, or sale of all or substantially all of lol291's assets, personal data held by the platform may be transferred to the successor entity, subject to equivalent data protection obligations.

7. Cookies & Tracking Technologies

7.1 The lol291 platform uses cookies and similar tracking technologies to provide core platform functionality, maintain session state, prevent fraud, and analyze platform usage.

7.2 The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function — including session management, login state, and security tokens. These cannot be disabled without impairing core functionality;
• Functional Cookies: Remember your preferences (language settings, game filters, responsible gaming choices) to improve your experience;
• Analytics Cookies: Collect anonymized data about how users navigate the Site, helping us identify areas for improvement. Analytics data is aggregated and not linked to individual player profiles;
• Marketing Cookies: Used only where you have explicitly consented, to deliver relevant promotional communications related to lol291.

7.3 You may manage non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the lol291 platform.

8. Data Retention

8.1 lol291 retains personal data for as long as necessary to fulfil the purposes outlined in this Policy, subject to the following retention periods:

• Account and Transaction Data: Retained for a minimum of five (5) years following account closure, or for the period required by applicable Philippine law (including AML record-keeping obligations under Republic Act No. 9160, as amended), whichever is longer;
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship or transaction, in accordance with AML requirements;
• Support Communications: Retained for three (3) years from the date of the communication, or longer if relevant to ongoing disputes or regulatory inquiries;
• Marketing Data (consented): Retained until consent is withdrawn or until two (2) years of inactivity, whichever occurs first;
• Technical & Log Data: Typically retained for twelve (12) months, subject to security and fraud investigation requirements.

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data destruction procedures. Anonymized data may be retained indefinitely for aggregated analytics purposes.

9. Data Security

9.1 lol291 implements technical and organizational security measures appropriate to the risks associated with processing personal data on an online casino platform, including:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the lol291 platform;
• Encryption of sensitive data fields (including identity document data and financial account references) at rest in our databases;
• Role-based access controls limiting employee access to personal data to those with a legitimate business need;
• Two-factor authentication (2FA) available for all player accounts and required for all internal administrative access;
• Regular penetration testing and security vulnerability assessments of the platform;
• Incident response procedures including breach notification protocols aligned with NPC (National Privacy Commission) reporting requirements under the PDPA.

9.2 Notwithstanding these measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own account credentials. Please notify lol291 support immediately if you suspect unauthorized access to your account.

12. Third-Party Services & Links

12.1 The lol291 platform integrates services provided by third-party game studios, live dealer operators, and payment processors. These third parties operate under their own privacy policies and data handling practices. lol291 is not responsible for the data practices of third-party services beyond the data processing agreements we have in place with them as processors.

12.2 The Site does not contain links to external third-party websites for the purpose of directing users to other online services. Any internal links on the platform point exclusively to pages within lol291.club.

13. Updates to This Privacy Policy

13.1 lol291 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or the services we provide. Material updates will be notified to registered users via their registered email address or through a prominent notice on the platform prior to the effective date of the change.

13.2 The "Effective Date" at the top of this Policy indicates when it was last revised. Continued use of the lol291 platform following notification of a material update constitutes your acceptance of the revised Policy.

13.3 We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information.

14. Contact & Data Protection Officer

14.1 lol291 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Policy.

14.2 For all privacy-related inquiries, requests to exercise your data rights, or to report a potential data breach, please contact:

• Data Protection Officer, lol291
• Email: [email protected] (Subject: "Data Privacy Request")
• Live Chat: Available 24/7 at lol291.club

14.3 For formal complaints that cannot be resolved directly with lol291, you may contact the National Privacy Commission (NPC) of the Philippines. The NPC's contact details are available on the official NPC website (npc.gov.ph).