soloph Casino Privacy Policy

1. Data Controller

1.1 For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, soloph is the personal information controller in respect of the personal data collected through the soloph platform at soloph.app.

1.2 soloph is committed to processing your personal data lawfully, fairly, and transparently, and to implementing appropriate technical and organizational measures to protect your data against unauthorized access, loss, or destruction.

2. Personal Data We Collect

2.1 soloph collects the following categories of personal data from players:

• Identity Data: Full name, date of birth, nationality, and government-issued identification number (e.g., PhilSys ID, passport, driver's license, SSS/GSIS number).
• Contact Data: Email address, mobile number, and residential address (including city, province, and postal code).
• Account Data: Username, encrypted password, account preferences, and communication history with soloph support.
• Financial Data: Payment method details (e.g., GCash mobile number, Maya account reference, bank account details for BPI, BDO, Metrobank, UnionBank, Landbank, PNB, or Security Bank), transaction history, deposit and withdrawal records.
• Gaming Data: Game history, wagering activity, session duration, bonus usage, and responsible gaming tool settings.
• Technical Data: IP address, device type, browser type and version, operating system, and platform access logs.
• Usage Data: Information about how you navigate and interact with the soloph platform, including pages visited and features used.
• Verification Data: Copies of identity documents and selfies submitted for KYC (Know Your Customer) verification purposes.

3. How We Collect Your Data

3.1 soloph collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the soloph platform, including through cookies, web beacons, and server logs.
• Third parties: Identity verification data from KYC service providers; payment data from payment processors; fraud prevention data from anti-fraud service providers.

4. How We Use Your Personal Data

4.1 soloph uses your personal data for the following purposes:

• To register and maintain your soloph account and verify your identity and eligibility.
• To process deposits, withdrawals, and other financial transactions on the soloph platform.
• To provide customer support and respond to your inquiries and complaints.
• To administer bonuses, promotions, and loyalty programs.
• To comply with PAGCOR regulatory requirements, anti-money laundering (AML) obligations, and other applicable Philippine laws.
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited conduct.
• To enforce our Terms and Conditions and other platform policies.
• To send you service-related communications, including account notifications and security alerts.
• To send you marketing communications about soloph promotions and new features, where you have provided consent.
• To analyze platform usage and improve the soloph user experience.
• To implement and monitor responsible gaming tools and self-exclusion requests.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you, including account registration, payment processing, and game provision.
• Legal obligation: Processing required to comply with PAGCOR regulations, AML laws, tax obligations, and other applicable Philippine legal requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.

6. Data Sharing and Disclosure

6.1 soloph may share your personal data with the following categories of recipients:

• Service providers: Third-party vendors who provide KYC verification, payment processing, fraud detection, IT infrastructure, and customer support services on behalf of soloph. These providers are contractually bound to process your data only as instructed by soloph and in accordance with applicable data protection laws.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Game providers: Licensed game software providers whose games are available on the soloph platform, to the extent necessary for game operation and dispute resolution.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by soloph, subject to confidentiality obligations.

6.2 soloph does not sell, rent, or otherwise transfer your personal data to third parties for their own independent marketing or commercial purposes.

7. Cookies and Tracking Technologies

7.1 soloph uses cookies and similar tracking technologies on the soloph platform. Cookies are small text files placed on your device that help us recognize you, remember your preferences, and analyze how you use the platform.

7.2 soloph uses the following types of cookies:

• Strictly necessary cookies: Essential for the operation of the soloph platform, including session management and security. These cannot be disabled.
• Functional cookies: Remember your preferences and settings to improve your experience on soloph.
• Analytics cookies: Help us understand how players use the soloph platform so we can improve it. Data collected is aggregated and anonymized where possible.
• Marketing cookies: Used to deliver relevant promotional content about soloph. These are only placed with your consent.

7.3 You can manage or disable cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the soloph platform.

8. Data Retention

8.1 soloph retains your personal data for as long as your account is active and for a period thereafter as required by applicable Philippine law and PAGCOR regulations. In particular:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• KYC verification documents are retained for the period required by PAGCOR and AMLC regulations.
• Marketing consent records are retained for the duration of your consent and for a reasonable period thereafter for compliance purposes.

8.2 When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, soloph will securely delete or anonymize it.

9. Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the soloph platform.
• Encryption of sensitive data at rest, including financial and identity data.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing of the soloph platform.
• Incident response procedures for detecting and responding to data security breaches.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, soloph will notify the National Privacy Commission and affected data subjects in accordance with the requirements of the Data Privacy Act of 2012.

10. Your Data Protection Rights

10.1 Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by soloph:

• Right to be informed: The right to be informed of how your personal data is being processed by soloph.
• Right of access: The right to obtain a copy of the personal data soloph holds about you.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected.
• Right to erasure: The right to request deletion of your personal data, subject to applicable 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 format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe soloph has violated your data protection rights.

10.2 To exercise any of these rights, please contact the soloph Data Protection Officer using the contact details in Section 14. soloph will respond to your request within thirty (30) days.

11. Children's Privacy

11.1 The soloph platform is strictly intended for persons aged 21 years and above. soloph does not knowingly collect personal data from individuals under the age of 21. If soloph becomes aware that personal data has been collected from a person under 21, it will take immediate steps to delete such data and close the associated account.

11.2 If you believe that a minor has registered on the soloph platform, please contact us immediately using the details in Section 14.

12. International Data Transfers

12.1 Where soloph transfers your personal data to service providers or partners located outside the Philippines, soloph will ensure that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012 and its Implementing Rules and Regulations, including the use of contractual clauses approved by the National Privacy Commission where applicable.

13. Changes to This Privacy Policy

13.1 soloph reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Where changes are material, soloph will notify registered players via email or a prominent notice on the platform prior to the changes taking effect.

13.2 The date of the most recent revision of this Privacy Policy is indicated at the top of this page. Your continued use of the soloph platform following any update constitutes your acknowledgment of the revised Privacy Policy.

14. Contact Us

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or soloph's data processing practices, please contact our Data Protection Officer:

14.2 Email: support soloph.app

14.3 soloph's Data Protection Officer will acknowledge your inquiry within five (5) business days and endeavour to resolve it within thirty (30) days. For complaints that cannot be resolved directly with soloph, you may escalate the matter to the National Privacy Commission of the Philippines.