Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how slo16 ("slo16," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "the Player") who access or use the slo16 platform, including the website at slo16.app and any associated mobile applications (collectively, the "Platform").

slo16 is committed to protecting the privacy and security of all personal data entrusted to us by our players. We process personal data in accordance with applicable data protection laws, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

By registering an account on slo16 or by continuing to use 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 slo16 Platform.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

slo16 acts as the data controller in respect of the personal data collected through the Platform. As data controller, slo16 determines the purposes and means by which your personal data is processed.

If you have any questions about how slo16 processes your personal data, or if you wish to exercise any of your data subject rights as described in this Policy, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

slo16 collects the following categories of personal data from players and prospective players:

Category	Examples
Identity Data	Full legal name, date of birth, gender, government-issued ID number (e.g., PhilSys ID, passport, driver's licence)
Contact Data	Email address, mobile number, residential address (including city, province, and postal code)
Account Data	Username, encrypted password, account preferences, communication preferences
Financial Data	GCash account details, PayMaya account details, BPI/BDO/Metrobank account information, transaction history, deposit and withdrawal records
Gaming Data	Game history, wager amounts, win/loss records, session duration, game preferences, VIP tier status
Technical Data	IP address, device type, operating system, browser type and version, time zone, location data, cookies and similar tracking data
Communications Data	Records of your communications with slo16 customer support, including chat logs and email correspondence
Verification Data	Copies of identity documents, proof of address documents, selfie photographs submitted for KYC verification

slo16 does not intentionally collect sensitive personal information (as defined under the Philippine Data Privacy Act) unless it is strictly necessary for compliance purposes, such as verifying your identity or complying with anti-money laundering obligations.

4. How We Collect Your Data

slo16 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, and browsing behaviour on the Platform.
• Third-party sources: Data received from payment processors (such as GCash and PayMaya), identity verification service providers, fraud prevention agencies, and regulatory bodies where permitted by law.
• Gameplay activity: Data generated through your use of games on the Platform, including wager history, session data, and game outcomes.

5. How We Use Your Personal Data

slo16 uses the personal data we collect for the following purposes:

• Account management: To register and maintain your slo16 player account, verify your identity, and manage your account preferences.
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the features and functionality of the Platform.
• KYC and compliance: To verify your identity and age (21+ requirement), comply with anti-money laundering (AML) obligations, and meet other regulatory requirements applicable to online gaming operators in the Philippines.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Customer support: To respond to your enquiries, resolve disputes, and provide assistance with your account.
• Responsible gaming: To monitor gaming patterns, identify potential problem gambling behaviour, and administer responsible gaming tools such as deposit limits and self-exclusion.
• Promotions and marketing: To send you information about slo16 promotions, bonuses, and new games, where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the Platform.
• Legal obligations: To comply with applicable laws, regulations, court orders, and regulatory directives.

6. Legal Basis for Processing

slo16 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary for the performance of the contract between you and slo16 (i.e., the Terms & Conditions), including account management, payment processing, and service delivery.
• Legal obligation: Where processing is necessary for slo16 to comply with a legal obligation, including KYC verification, AML compliance, and regulatory reporting.
• Legitimate interests: Where processing is necessary for the legitimate interests of slo16, such as fraud prevention, platform security, and improving our services, provided that such interests are not overridden by your rights and interests.

7. Sharing Your Personal Data

slo16 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and identity verification service providers engaged by slo16 to assist with player verification.
• Game software providers: Third-party game developers and live dealer platform providers whose games are made available on the slo16 Platform.
• Fraud prevention and security providers: Third-party agencies engaged to assist with fraud detection, AML screening, and platform security.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, law enforcement agencies, and other regulatory bodies, where disclosure is required by law or regulation.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by slo16, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of all or part of slo16's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

All third parties with whom slo16 shares personal data are required to process that data in accordance with applicable data protection laws and slo16's data protection standards.

8. Data Retention

slo16 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

• Account data and gaming records are retained for the duration of your account and for a minimum period of five (5) years following account closure, in accordance with applicable AML and regulatory requirements.
• KYC verification documents are retained for a minimum of five (5) years following account closure, or longer if required by applicable law or ongoing regulatory proceedings.
• Customer support communications are retained for a period of three (3) years from the date of the last interaction.
• Marketing consent records are retained for as long as you remain a registered player and for a period of two (2) years following account closure.
• Technical and usage data collected via cookies and server logs is retained for periods specified in our cookie settings, typically ranging from session-only to a maximum of twenty-four (24) months.

When personal data is no longer required for the purposes for which it was collected and no legal obligation requires its continued retention, slo16 will securely delete or anonymise that data.

9. Data Security

slo16 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the slo16 Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls limiting access to personal data to authorised personnel only, on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Staff training on data protection obligations and information security best practices.

While slo16 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, slo16 will notify you and the National Privacy Commission in accordance with applicable legal requirements.

10. Cookies & Tracking Technologies

slo16 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and support our security and fraud prevention measures. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the operation of the Platform, including maintaining your login session and enabling core functionality. These cookies cannot be disabled.
• Performance and analytics cookies: Used to collect information about how players use the Platform, such as which pages are visited most frequently and how players navigate between pages. This data is used in aggregate form to improve the Platform.
• Functionality cookies: Used to remember your preferences and settings, such as your preferred language and display options.
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

You may control the use of non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary and security cookies cannot be disabled as they are essential to the safe operation of the Platform.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by slo16:

• Right to be informed: You have the right to be informed about how your personal data is collected and processed. This Policy fulfils that obligation.
• Right of access: You have the right to request a copy of the personal data slo16 holds about you, along with information about how it is processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data slo16 holds about you.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to slo16's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to slo16's overriding legitimate grounds.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that slo16 has processed your personal data in violation of applicable data protection law.

To exercise any of the above rights, please contact slo16's Data Protection Officer using the contact details in Section 14. slo16 will respond to all valid requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified accordingly.

Please note that certain rights are subject to limitations. For example, slo16 may be unable to delete personal data that it is legally required to retain, or where deletion would prejudice an ongoing investigation.

12. Minors

The slo16 Platform is strictly intended for individuals who are 21 years of age or older. slo16 does not knowingly collect personal data from persons under the age of 21. If slo16 becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed.

If you are a parent or guardian and believe that a minor has registered on the slo16 Platform or provided personal data to slo16, please contact us immediately using the details in Section 14 so that we can take appropriate action.

13. Changes to This Privacy Policy

slo16 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. When material changes are made, slo16 will notify registered players via the Platform or by email to the address associated with their account.

The date of the most recent revision is displayed at the top of this page. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to stay informed about how slo16 protects your personal data.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way slo16 processes your personal data, please contact our Data Protection Officer:

Data Protection Officer – slo16
Email: [email protected] (plain text – not a clickable link)
General support: [email protected] (plain text – not a clickable link)

Our support team is available 24 hours a day, 7 days a week. For data subject rights requests, please include your registered username, a description of your request, and a copy of a valid government-issued ID so that we can verify your identity before processing your request.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with slo16's response to your data protection concerns.