Privacy Policy

The data controller responsible for the personal data processed in connection with the sloph Casino platform is the operator of sloph.app. sloph is operated for the Philippine market and its data processing activities are subject to the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA") and the implementing rules and regulations issued by the National Privacy Commission of the Philippines.

sloph has appointed a Data Protection Officer (DPO) who is responsible for overseeing sloph's data protection obligations, handling data subject requests, and serving as the primary point of contact for the National Privacy Commission on privacy-related matters. Contact details for the sloph DPO are provided in Section 16 of this Policy.

This Privacy Policy applies to all personal data processed by sloph in connection with:

• The sloph.app website and all pages and subdomains operated by sloph;
• The sloph mobile application (where available);
• All communications between sloph and its Members or prospective Members, including via live chat, email, and SMS;
• All transactions processed through the sloph Platform, including deposits, withdrawals, and wagering activity;
• All marketing communications sent by sloph to Members who have opted in to receive them.

This Policy does not apply to third-party websites, payment processors, or game studios that may be accessible through or linked from the sloph Platform. Those entities operate under their own privacy policies, which sloph encourages you to review.

sloph collects and processes the following categories of personal data:

3.1 Identity and Registration Data

• Full legal name as it appears on a government-issued Philippine identification document;
• Date of birth;
• Gender (optional at registration, may be required for KYC);
• Registered residential address in the Philippines;
• Philippine mobile number;
• Email address.

3.2 Identity Verification (KYC) Data

• Scanned copies or photographs of government-issued Philippine identification documents (types listed in Section 5 of our Terms and Conditions);
• Selfie photograph for facial verification purposes, where required;
• Proof of address documentation (utility bills, bank statements, etc.), where requested;
• Source of funds declarations, where triggered by sloph's AML screening protocols.

3.3 Financial and Transaction Data

• GCash account number, Maya account number, and/or bank account details used for deposits and withdrawals;
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment methods;
• Wagering history including game names, bet amounts, outcomes, and session durations;
• Account balance records.

3.4 Technical and Usage Data

• IP address and geographic location data derived from IP;
• Device identifiers, browser type, operating system, and screen resolution;
• Session timestamps, session duration, and page navigation data;
• Login timestamps and access logs;
• Cookies and similar tracking data (see Section 10).

3.5 Communications Data

• Records of live chat conversations with sloph customer support;
• Email correspondence with sloph;
• SMS records where OTPs or account notifications are sent;
• Records of formal complaints or dispute submissions.

3.6 Responsible Gaming Data

• Deposit limits set by the Member;
• Session time limit preferences;
• Self-exclusion records and cool-off period activations;
• Responsible gaming interaction history with sloph support.

sloph collects personal data through the following channels and methods:

• Directly from you — during account registration, KYC document submission, deposit and withdrawal requests, customer support interactions, and any forms you complete on the sloph Platform;
• Automatically — through cookies, log files, and similar technologies that capture technical and usage data when you access and use the sloph Platform (see Section 10);
• From payment processors — confirmation of transaction outcomes, payment method ownership verification, and fraud signals received from payment partners including GCash, Maya, BPI, BDO, and Metrobank;
• From identity verification providers — results of automated document and facial verification checks performed as part of the KYC process;
• From anti-fraud and AML screening services — risk scores and screening outcomes generated when your details are checked against relevant watchlists and databases as required by Philippine AML law;
• From game studios — technical data relating to game session outcomes for dispute resolution and game integrity purposes.

sloph processes personal data for the following purposes, each grounded in a specific legal basis under the Philippine Data Privacy Act:

Where sloph processes data on the basis of legitimate interests, it has assessed that those interests are not overridden by your fundamental rights and freedoms as a data subject, having regard to your reasonable expectations and the nature of the data processed.

sloph does not sell, rent, or trade your personal data to any third party for their own commercial or marketing purposes. sloph shares personal data with third parties only in the following circumstances:

6.1 Service Providers and Data Processors

sloph engages third-party service providers who process personal data on sloph's behalf and under sloph's documented instructions. These include:

• Payment processors — GCash, Maya, BPI, BDO, Metrobank, and other payment partners — for transaction processing and payment method verification;
• KYC and identity verification providers — for document authentication and facial recognition checks;
• AML and fraud screening providers — for sanctions screening and risk scoring;
• Game studio partners — for game delivery, RNG certification, and session dispute resolution;
• Cloud infrastructure and data centre providers — for secure hosting of Platform data;
• Customer support platform providers — for live chat and ticketing system operation.

All third-party service providers who process personal data on sloph's behalf are bound by written data processing agreements that include appropriate data protection obligations consistent with the Philippine DPA.

6.2 Regulatory and Law Enforcement Disclosure

sloph may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, Philippine law enforcement agencies, or other competent authorities where required by law, court order, or formal regulatory request. sloph will not disclose more data than is strictly required to comply with any such request and will, where legally permitted, notify affected Members of any such disclosure.

6.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of sloph's business, personal data held by sloph may be transferred to the acquiring entity as part of that transaction, subject to the acquiring entity assuming the same data protection obligations contained in this Policy.

sloph's primary data processing infrastructure is located in certified data centres serving the Philippine and Southeast Asian market. Some of sloph's third-party service providers — particularly those providing cloud services, game studio platforms, and KYC verification technology — may process personal data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, sloph ensures that appropriate safeguards are in place, including:

• Transferring data only to jurisdictions that the National Privacy Commission has assessed as providing an adequate level of data protection;
• Implementing contractual clauses in service provider agreements that impose data protection obligations equivalent to those required under Philippine law;
• Limiting the scope and volume of data transferred to third-country processors to only what is strictly necessary for the contracted service.

You may request information about the specific safeguards applied to any international data transfer involving your personal data by contacting sloph's DPO using the contact details in Section 16.

sloph retains personal data for as long as necessary to fulfil the purposes described in Section 5 of this Policy, subject to the minimum retention periods required by applicable Philippine law. The following general retention periods apply:

After the applicable retention period has elapsed, personal data is securely deleted or anonymised in accordance with sloph's data disposal procedures. Anonymised or aggregated data that cannot be used to identify any individual may be retained indefinitely for analytics and reporting purposes.

sloph implements a comprehensive suite of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• Encryption in transit: All data transmitted between your device and sloph's servers is encrypted using TLS 1.2 or higher (256-bit encryption);
• Encryption at rest: Personal data stored in sloph's databases is encrypted at rest using AES-256 encryption;
• Access controls: Access to personal data is restricted to authorised sloph personnel on a role-based, need-to-know basis. All access is logged and subject to periodic review;
• Two-factor authentication: Internal systems handling personal data require multi-factor authentication for all user accounts;
• Intrusion detection and prevention: sloph's infrastructure includes real-time monitoring, intrusion detection systems, and automated alerts for anomalous activity;
• Penetration testing: sloph commissions regular third-party penetration testing of its Platform and data systems;
• Vendor security assessments: Third-party service providers are subject to security due diligence before engagement and periodic reassessment;
• Data breach response: sloph maintains a documented data breach response plan. In the event of a personal data breach, sloph will notify affected Members and the National Privacy Commission within the timeframes required by the DPA.

sloph uses cookies and similar technologies to operate and improve the Platform, to personalise your experience, and where applicable and with your consent, to deliver targeted advertising. The following types of cookies are used:

You may manage your cookie preferences through your browser settings. Disabling strictly necessary or functional cookies may affect the operation of certain features of the sloph Platform. Withdrawal of consent for analytics or marketing cookies will be respected by sloph on a going-forward basis. Existing data collected before withdrawal remains subject to the retention periods in Section 8.

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights as a data subject. sloph is committed to facilitating the exercise of each of these rights without undue burden or delay:

The sloph Platform is strictly intended for adults aged 21 years and above, in compliance with Philippine law and PAGCOR regulations governing online gaming. sloph does not knowingly collect personal data from persons under the age of 21.

sloph employs age verification measures during registration and as part of the KYC process to prevent underage individuals from accessing the Platform. If sloph discovers or has reasonable cause to believe that a registered Account belongs to a person under 21 years of age, the Account will be immediately suspended, personal data will be reviewed by sloph's compliance team, and the matter will be handled in accordance with sloph's underage access protocol.

If you have reason to believe that a minor has registered an Account on sloph, please contact sloph's support team or DPO immediately. We take such reports seriously and will investigate promptly.

sloph sends promotional and marketing communications — including bonus offers, tournament announcements, deposit match promotions, and Platform updates — only to Members who have expressly consented to receive such communications at the time of registration or in their account settings.

Marketing communications from sloph may be delivered via SMS to your registered Philippine mobile number, by email to your registered email address, and via push notifications if you have enabled notifications in the sloph mobile application.

You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in your sloph account settings;
• Clicking the unsubscribe link included in any marketing email from sloph; or
• Contacting sloph's customer support team and requesting removal from marketing lists.

Withdrawal of consent for marketing communications does not affect your right to receive service and transactional communications from sloph, such as deposit confirmations, withdrawal notifications, and security alerts. These communications are sent on the basis of contract performance and are not subject to marketing opt-out.

The sloph Platform integrates with third-party services including payment processors (GCash, Maya, BPI, BDO, Metrobank, GrabPay, CLiQQ) and game studio providers. While sloph carefully selects all third-party partners and requires them to operate to appropriate data protection standards, sloph is not responsible for the privacy practices of third parties whose services you access in connection with using the sloph Platform.

When you initiate a GCash deposit or Maya withdrawal, for example, you will interact with GCash's or Maya's own systems, which are governed by their respective privacy policies. sloph encourages you to review the privacy policies of any third-party service you use in connection with the sloph Platform.

sloph reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable Philippine law, PAGCOR regulatory requirements, sloph's data processing practices, or Platform features. The "Effective" date at the top of this Policy will be updated to reflect the date of the most recent revision.

Where any amendment to this Policy materially affects how sloph processes your personal data or materially affects your rights as a data subject, sloph will notify you in advance by email to your registered address or by a prominent notice on the Platform prior to the change taking effect. For non-material updates — such as clarifications, corrections, or formatting changes — the Policy will simply be updated and the revised version published at sloph.app/privacy-policy.

Your continued use of the sloph Platform after the publication of any amended Policy constitutes your acknowledgement of the updated terms, subject to your right to object or withdraw consent as provided for in Section 11.

If you have any questions, concerns, or requests relating to this Privacy Policy or sloph's data processing practices, you may contact sloph's Data Protection Officer using the contact information below. All data subject requests and privacy-related correspondence should be directed to the DPO to ensure proper handling and response within the timeframes prescribed by the Philippine Data Privacy Act.

If you are not satisfied with sloph's response to your data subject request, or if you believe sloph has processed your personal data in violation of the Philippine Data Privacy Act, you have the right to file a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint is available on the National Privacy Commission's official website.

This Privacy Policy was last reviewed and updated on 1 January 2026. It supersedes all previous versions. The current version is always available at sloph.app/privacy-policy.