Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 9oklotto ("the Company," "we," "us," or "our") collects, uses, stores, and discloses personal information obtained from users ("Player," "User," or "you") of the 9oklotto online gaming platform, accessible at 9oklotto.one and all associated pages and services (the "Platform").

9oklotto operates in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations. We are committed to ensuring that your personal information is handled responsibly, transparently, and in accordance with applicable data protection law.

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, you must not use the Platform.

2 Data We Collect

9oklotto collects personal information that is necessary to provide you with a secure, compliant, and personalised gaming experience. The categories of data we collect include:

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by law or expressly provided by you in the context of responsible gaming self-assessment tools.

3 How We Use Your Data

9oklotto uses your personal information for the following purposes:

• Account Management: To create, verify, and maintain your 9oklotto account, including KYC identity verification as required by applicable regulations.
• Service Delivery: To process deposits and withdrawals, provide access to games, and deliver the core features of the Platform.
• Regulatory Compliance: To comply with anti-money laundering (AML) obligations, PAGCOR licensing requirements, and other applicable Philippine laws.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, unauthorised account access, and other illegal activity.
• Responsible Gaming: To monitor gaming behaviour and apply responsible gaming tools, including deposit limits and self-exclusion, where appropriate.
• Customer Support: To respond to your enquiries, resolve disputes, and improve our support services.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided consent or where permitted by law. You may opt out at any time.
• Platform Improvement: To analyse usage patterns and improve the performance, design, and features of the 9oklotto Platform.

4 Legal Basis for Processing

9oklotto processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and 9oklotto (i.e., to provide the gaming services you have registered for).
• Legal Obligation: Processing is required to comply with applicable laws, including AML regulations, PAGCOR requirements, and tax obligations.
• Legitimate Interests: Processing is necessary for the legitimate interests of 9oklotto, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights.
• 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.

5 Data Sharing & Disclosure

9oklotto does not sell your personal information to third parties. 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, BPI, BDO, Metrobank, UnionBank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory obligations.
• Game Software Providers: Licensed game developers and live casino operators whose games are hosted on the 9oklotto Platform.
• Regulatory Authorities: PAGCOR and other competent Philippine government agencies, where disclosure is required by law or court order.
• IT & Infrastructure Providers: Cloud hosting, cybersecurity, and analytics service providers who process data on our behalf under strict contractual obligations.

All third-party service providers engaged by 9oklotto are contractually required to process your data only for the specified purpose and to maintain appropriate security standards.

6 Data Retention

9oklotto retains your personal data for as long as your account is active and for a period thereafter as required by applicable law. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in accordance with AML and PAGCOR record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Marketing consent records are retained for the duration of your consent and for a reasonable period thereafter as evidence of compliance.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised in accordance with our data disposal procedures.

7 Security Measures

9oklotto implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 9oklotto Platform.
• Encrypted storage of sensitive data, including financial information and government ID details, at rest.
• Access controls limiting internal access to personal data on a strict need-to-know basis, with audit logging of all access events.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
• Two-factor authentication options available to all registered players to protect account access.

While 9oklotto takes all reasonable steps to protect your data, no system is entirely immune to risk. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the National Privacy Commission (NPC) in accordance with the Data Privacy Act of 2012.

8 Cookies & Tracking Technologies

9oklotto uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse usage patterns. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled without affecting core functionality such as login sessions and security tokens.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to personalise your experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Platform, helping us identify areas for improvement.
• Marketing Cookies: Used, with your consent, to deliver relevant promotional content. You may opt out of marketing cookies at any time via your browser settings or our cookie preference centre.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 9oklotto Platform.

9 Your Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 9oklotto:

• Right to be Informed: You have the right to know what personal data we collect, how we use it, and with whom we share it — as set out in this Policy.
• Right of Access: You may request a copy of the personal data we hold about you at any time.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• 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 our 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 a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 12 of this Policy. We will respond to all verified requests within thirty (30) days.

10 Minors & Age Restriction

The 9oklotto Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.

11 Changes to This Policy

9oklotto reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, we will update the "Last updated" date at the top of this page and, where required, notify you by email or in-platform notification.

Your continued use of the 9oklotto Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how we protect your data.

12 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the 9oklotto Data Protection Officer:

• Live Chat: Available 24/7 via the chat widget on the Platform. Average response time under 2 minutes.
• Privacy & Data Enquiries: [email protected]
• Partnerships & Business: [email protected]

Our support team includes Filipino-speaking agents available around the clock to assist players from Manila, Cebu, Davao, Quezon City, Makati, and across the Philippines. We aim to resolve all privacy-related enquiries promptly and transparently.