mlotto Privacy Policy

01Introduction

mlotto ("mlotto," "we," "us," or "our") operates the online gaming platform accessible at https://mlotto.lat (the "Platform"). As a data controller operating in the Republic of the Philippines and serving Filipino players, mlotto is subject to Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations, as administered and enforced by the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy ("Policy") governs the collection, use, storage, processing, sharing, and protection of personal information provided by or collected from individuals who access or use the mlotto Platform, including registered players, visitors, and prospective players ("Data Subjects," "you," or "your"). This Policy applies to all personal data processed by mlotto in connection with the operation of the Platform, regardless of the medium through which such data is provided.

By creating an mlotto account or using the Platform in any way, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue your use of the Platform immediately.

02Data Controller

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, the data controller responsible for your personal information is:

mlotto has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. You may contact the DPO at any time using the email address above for any privacy-related concerns, requests, or complaints.

03Personal Data We Collect

mlotto collects the following categories of personal data in connection with the operation of the Platform and the provision of gaming services to Filipino players:

3.1 Identity & Contact Information

• Full legal name as it appears on your government-issued Philippine identification document;
• Date of birth (used for 21+ age verification);
• Gender;
• Residential address, including barangay, city/municipality, province, and postal code;
• Valid email address;
• Philippine mobile phone number.

3.2 Identity Verification Documents

• Copy of government-issued Philippine ID (e.g., PhilSys National ID, passport, driver's license, SSS ID, GSIS ID, PhilHealth ID, voter's ID, or PRC ID);
• Proof of address (e.g., utility bill or bank statement issued within the past three months);
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account showing your name).

3.3 Financial Information

• GCash account details (mobile number associated with GCash);
• PayMaya account details;
• Bank account details for BPI, BDO, Metrobank, or UnionBank transactions;
• Cryptocurrency wallet addresses used for Bitcoin or USDT transactions;
• Transaction history including deposits, withdrawals, and bonus credits.

3.4 Gaming & Behavioral Data

• Game history, bet amounts, win/loss records, and session durations;
• Responsible gaming preferences and self-imposed limits;
• Bonus and promotional activity;
• Customer support interaction history.

3.5 Technical & Device Data

• IP address and geolocation data;
• Device type, operating system, and browser information;
• Mobile network operator (Globe, Smart, DITO, etc.);
• Login timestamps and session data;
• Cookies and similar tracking technologies (see Section 10).

04How We Collect Data

mlotto collects personal data through the following means:

05Purpose of Processing

mlotto processes your personal data for the following specific, legitimate, and lawful purposes:

• Account Management: Creating, verifying, maintaining, and administering your mlotto player account;
• Service Delivery: Providing access to games, processing bets and gaming results, and delivering player support;
• Identity Verification: Fulfilling KYC obligations under applicable gaming regulations and confirming the 21+ age requirement;
• Financial Processing: Processing deposits and withdrawal requests and maintaining accurate transaction records;
• Regulatory Compliance: Meeting obligations imposed by PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities;
• Fraud & Security: Detecting, investigating, and preventing fraudulent activity, cheating, money laundering, and other illegal conduct;
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviors and enforcing player-set limits and self-exclusion requests;
• Marketing & Promotions: Sending relevant offers, bonus notifications, and promotional communications to players who have consented to receive them;
• Platform Improvement: Analyzing usage data to improve the functionality, performance, and user experience of the Platform;
• Legal Defense: Establishing, exercising, or defending legal claims in connection with the mlotto Platform.

06Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, mlotto processes your personal data on the following legal bases:

• Consent: Processing for marketing communications is based on your freely given, specific, and informed consent. You may withdraw this consent at any time by contacting support or updating your account preferences;
• Contractual Necessity: Processing required to fulfill the Terms & Conditions agreement between you and mlotto, including account management, game delivery, and financial transactions;
• Legal Obligation: Processing required for mlotto to comply with applicable Philippine laws and regulatory requirements, including AML laws, PAGCOR licensing conditions, and the Data Privacy Act itself;
• Legitimate Interests: Processing necessary for mlotto's legitimate business interests, including fraud prevention, security monitoring, and Platform improvement, provided such interests are not overridden by your fundamental rights and freedoms.

07Data Sharing & Disclosure

mlotto does not sell, rent, or trade your personal data to any third party for commercial purposes. We may, however, share your personal information with the following categories of recipients where necessary and lawful:

7.1 Regulatory & Law Enforcement Authorities

mlotto is legally required to disclose relevant personal and financial data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other competent Philippine government bodies upon lawful request or as required by our operating license conditions.

7.2 Payment Service Providers

To process your deposits and withdrawals, mlotto shares necessary financial data with payment processors including GCash (G-Xchange, Inc.), PayMaya Philippines, Inc., and licensed banking institutions such as BPI, BDO, Metrobank, and UnionBank. These entities are bound by their own data protection obligations under Philippine law.

7.3 Game Software Providers

Third-party game providers (such as Pragmatic Play, Evolution Gaming, and SA Gaming) may process limited session and gameplay data as necessary to deliver their games on the mlotto Platform. All providers are contractually required to handle such data in compliance with applicable privacy laws.

7.4 Technology & Infrastructure Providers

mlotto works with trusted technology vendors for hosting, cloud storage, cybersecurity, customer support software, and analytics. These vendors act as data processors under written data processing agreements and are permitted to use your data only for the specific services they provide to mlotto.

08Data Retention

mlotto retains your personal data for as long as necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce agreements. The following general retention periods apply:

Upon expiry of the applicable retention period, mlotto will securely delete or anonymize your personal data in accordance with our data disposal procedures.

09Data Security

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

• 256-bit Secure Socket Layer (SSL) encryption for all data transmitted between your device and the mlotto Platform;
• Encryption at rest for sensitive data stored on mlotto servers, including identity documents and financial information;
• Two-factor authentication (2FA) available for all player accounts;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Real-time intrusion detection and fraud monitoring systems;
• Regular third-party security audits and penetration testing;
• Secure data centers with physical access controls;
• Staff training on data protection obligations and security best practices.

While mlotto employs industry-standard security measures, no method of electronic transmission or storage is entirely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, mlotto will notify affected players and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with the Data Privacy Act of 2012.

10Cookies & Tracking Technologies

mlotto uses cookies and similar tracking technologies to operate the Platform, analyze usage, and improve your experience. A cookie is a small text file placed on your device when you visit the Platform. mlotto uses the following types of cookies:

10.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function correctly. They enable core features such as account authentication, session management, and security verification. These cookies cannot be disabled without significantly impairing your ability to use the Platform.

10.2 Analytics & Performance Cookies

These cookies collect aggregated, anonymized information about how players use the Platform — such as which games are most popular, how long sessions last, and which pages generate the most errors. This data helps mlotto improve the Platform's performance and user experience.

10.3 Functional Cookies

These cookies remember your preferences and settings, such as your preferred language, last visited game category, and notification preferences, so you don't have to reconfigure them on every visit.

10.4 Managing Cookies

You may control cookie preferences through your browser settings. Most modern browsers allow you to view, delete, and block cookies from specific websites. Please note that disabling certain cookies may affect the functionality of the mlotto Platform. For mobile devices, you can manage cookie and tracking preferences through your device's privacy settings.

11Your Data Subject Rights

Under the Data Privacy Act of 2012, you are entitled to exercise the following rights with respect to your personal data held by mlotto. To exercise any of these rights, please contact our Data Protection Officer at [email protected]. mlotto will respond to all verified requests within fifteen (15) business days.

12Minors & Age Restriction

Parents and guardians who believe their child may have registered on the mlotto Platform are encouraged to contact our Data Protection Officer immediately at [email protected]. mlotto will investigate all such reports promptly and take appropriate remedial action.

13Cross-Border Data Transfers

Some of mlotto's technology partners and game providers are located outside of the Republic of the Philippines. Where personal data is transferred to a recipient in another country, mlotto ensures that adequate safeguards are in place in accordance with Section 21 of the Data Privacy Act of 2012 and the relevant NPC Circular on cross-border data flow. Such safeguards may include standard contractual clauses, binding corporate rules, or reliance on the recipient country's recognition by the NPC as providing an adequate level of data protection.

mlotto does not transfer your personal data to jurisdictions that have not been assessed as providing an adequate level of protection without implementing appropriate contractual or technical safeguards.

14Changes to This Privacy Policy

mlotto reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes to this Policy will be communicated to registered players via email to the address on file and via a prominent notice on the Platform, no less than seven (7) days before the amended Policy takes effect, except where immediate change is required by law.

The date at the top of this Policy indicates when it was last updated. Your continued use of the mlotto Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how mlotto protects your data.

15Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way mlotto handles your personal data, please contact our Data Protection Officer:

If you are not satisfied with mlotto's response to your privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines. The NPC is the government authority responsible for enforcing the Data Privacy Act of 2012 and can be reached through their official website and hotline. mlotto cooperates fully with all NPC investigations and inquiries.