skylot Privacy Policy

1. Introduction and Scope

skylot ("we," "us," "our," or "the Company") is committed to protecting the privacy and security of your personal information. This Privacy Policy (hereinafter "Policy") describes how we collect, use, disclose, store, and protect personal data when you access or use our online casino platform located at https://skylot.cam (hereinafter "the Platform," "Website," or "Services").

This Policy applies to all users ("you," "User," "Player") of skylot and governs our data processing practices in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines (hereinafter "DPA"), and its implementing rules and regulations issued by the National Privacy Commission (NPC).

By registering for an account, accessing the Platform, or using our Services, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with any part of this Policy, you must discontinue use of skylot immediately.

2. Data Controller Information

skylot acts as the data controller for the personal information collected through the Platform. For inquiries, requests, or complaints regarding your personal data, you may contact our Data Protection Officer:

• Company Name: skylot
• Email Address: [email protected]
• Mailing Address: [Physical business address would be provided here]
• Data Protection Officer Email: [email protected]

3. Personal Information We Collect

skylot collects various categories of personal information necessary to provide our Services, comply with legal obligations, and enhance user experience. The types of personal data we collect include:

3.1 Information You Provide Directly

When you register for a skylot account, deposit funds, withdraw winnings, or communicate with our customer support, you voluntarily provide personal information including:

• Identity Information: Full legal name, date of birth, gender, nationality, government-issued identification numbers (passport number, driver's license number, UMID, SSS, TIN).
• Contact Information: Residential address, email address, mobile phone number, alternative contact details.
• Account Credentials: Username, password, security questions and answers, two-factor authentication details.
• Financial Information: Payment method details (GCash account, PayMaya account, bank account numbers), transaction history, deposit and withdrawal records, source of funds documentation.
• Verification Documents: Copies of government-issued IDs, proof of address documents (utility bills, bank statements), selfies for identity verification, source of wealth documentation.
• Communication Records: Customer support chat logs, email correspondence, phone call recordings, feedback and survey responses.

3.2 Information Collected Automatically

When you access skylot, we automatically collect technical and behavioral data through cookies, web beacons, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), mobile network information.
• Usage Data: Pages visited, games played, bet amounts, session duration, clickstream data, referring URLs, search queries within the Platform.
• Location Information: IP address, geolocation data (country, region, city), time zone, GPS coordinates (if mobile app permissions granted).
• Gaming Activity: Game preferences, betting patterns, win/loss records, bonus claims, wagering history, jackpot participation.

3.3 Information from Third-Party Sources

skylot may receive personal information from third-party service providers including:

• Payment Processors: GCash, PayMaya, banks, and other financial institutions providing transaction verification and fraud prevention data.
• Identity Verification Services: Third-party KYC (Know Your Customer) and AML (Anti-Money Laundering) verification providers.
• Credit Reference Agencies: Financial background checks where required by law or regulation.
• Affiliate Partners: Referral source information, affiliate tracking codes.
• Social Media Platforms: Profile information if you choose to connect your social media accounts.

4. How We Use Your Personal Information

skylot processes your personal data for the following lawful purposes:

4.1 Contract Performance and Service Provision

• Create and manage your skylot account.
• Authenticate your identity and verify your age (21+ requirement).
• Process deposits, withdrawals, and financial transactions.
• Provide access to casino games, live dealer tables, and other gaming services.
• Award bonuses, promotions, and loyalty rewards.
• Respond to customer support inquiries and resolve disputes.
• Send transactional communications (account confirmations, withdrawal approvals, payment receipts).

4.2 Legal Compliance and Regulatory Obligations

• Comply with PAGCOR licensing requirements and gaming regulations.
• Conduct KYC (Know Your Customer) and customer due diligence procedures.
• Prevent and detect money laundering, terrorist financing, and financial crimes in accordance with the Anti-Money Laundering Act of 2001 (AMLA).
• Maintain records for tax reporting and financial auditing purposes.
• Cooperate with law enforcement investigations and court orders.
• Comply with data retention requirements under Philippine law.

4.3 Fraud Prevention and Security

• Detect and prevent fraudulent activity, bonus abuse, collusion, and cheating.
• Monitor for suspicious transactions and betting patterns.
• Verify the authenticity of payment methods and prevent payment fraud.
• Protect against unauthorized account access and cyber threats.
• Enforce our Terms and Conditions and other platform policies.

4.4 Marketing and Communication (with Consent)

• Send promotional offers, bonus announcements, and special event notifications via email and SMS.
• Provide personalized game recommendations based on your preferences.
• Conduct market research, surveys, and feedback collection.
• Display targeted advertising on the Platform and third-party websites.

Note: You may opt out of marketing communications at any time by clicking "unsubscribe" in promotional emails, adjusting your account communication preferences, or contacting customer support. Opting out of marketing does not affect transactional communications necessary for account management.

4.5 Platform Improvement and Analytics

• Analyze usage patterns to improve Platform functionality and user experience.
• Conduct A/B testing to optimize game offerings and features.
• Monitor Platform performance, troubleshoot technical issues, and ensure system stability.
• Develop new games, features, and services based on user behavior insights.

4.6 Responsible Gaming and Player Protection

• Administer deposit limits, loss limits, and self-exclusion requests.
• Identify problem gambling behaviors and provide responsible gaming resources.
• Enforce age verification to prevent underage gambling.
• Comply with PAGCOR responsible gaming requirements.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, skylot processes your personal information based on the following legal grounds:

• Consent: You have explicitly consented to the processing of your personal data for specific purposes (e.g., marketing communications, optional features).
• Contract: Processing is necessary to fulfill our contractual obligations to provide gaming services as outlined in our Terms and Conditions.
• Legal Obligation: Processing is required to comply with Philippine laws, PAGCOR regulations, anti-money laundering requirements, and court orders.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, platform improvement, and customer support, provided such interests do not override your fundamental rights and freedoms.

6. How We Share Your Personal Information

skylot does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with the following categories of recipients for legitimate business and legal purposes:

6.1 Service Providers and Business Partners

• Payment Processors: GCash, PayMaya, banks, and financial institutions that facilitate deposits and withdrawals.
• Game Providers: Pragmatic Play, Evolution Gaming, PG Soft, Microgaming, and other third-party game suppliers.
• Identity Verification Services: KYC and AML compliance vendors that verify your identity and screen for fraud.
• Cloud Hosting Providers: Servers and data storage infrastructure providers.
• Customer Support Tools: Live chat software, ticketing systems, and CRM platforms.
• Marketing Service Providers: Email service providers, SMS gateways, and advertising platforms (subject to your marketing consent).
• Analytics Providers: Google Analytics and similar tools that analyze Platform usage.

All third-party service providers are contractually bound to protect your personal information and use it only for the purposes specified by skylot. We conduct due diligence to ensure that service providers maintain appropriate data security measures.

6.2 Regulatory Authorities and Law Enforcement

skylot may disclose your personal information to government agencies, regulators, and law enforcement when:

• Required by Philippine law, regulation, or legal process (subpoena, court order).
• Necessary to comply with PAGCOR reporting obligations.
• Required under anti-money laundering laws to report suspicious transactions to the Anti-Money Laundering Council (AMLC).
• Necessary to cooperate with criminal investigations or legal proceedings.
• Required to protect the rights, property, or safety of skylot, our users, or the public.

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. We will notify you via email and prominent notice on the Platform before your data is transferred and becomes subject to a different privacy policy.

6.4 Affiliates and Group Companies

skylot may share personal information with affiliated companies within our corporate group for internal administration, IT support, data analytics, and fraud prevention purposes. All affiliates are required to comply with this Privacy Policy.

7. International Data Transfers

skylot primarily processes personal data within the Philippines. However, some of our service providers, data centers, and business partners may be located outside the Philippines, including in jurisdictions that may not provide the same level of data protection as Philippine law.

When we transfer personal data internationally, we implement appropriate safeguards including:

• Ensuring the recipient country provides adequate data protection as determined by the National Privacy Commission.
• Entering into standard contractual clauses or data processing agreements with service providers.
• Conducting data protection impact assessments for high-risk transfers.
• Obtaining your explicit consent where required by law.

8. Data Retention

skylot retains your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

Specific retention periods include:

• Account Information: Retained for the duration of your active account plus seven (7) years after account closure to comply with PAGCOR record-keeping requirements and tax laws.
• Transaction Records: Retained for seven (7) years after the transaction date in accordance with anti-money laundering regulations and tax compliance requirements.
• Identity Verification Documents: Retained for seven (7) years after account closure for AML compliance.
• Customer Support Communications: Retained for three (3) years for dispute resolution and quality assurance purposes.
• Marketing Consent Records: Retained for three (3) years after consent is withdrawn to demonstrate compliance with data protection laws.
• Technical Logs and Security Data: Retained for one (1) year for security monitoring and incident investigation.

After the applicable retention period expires, personal information is securely deleted or anonymized so that it can no longer identify you.

9. Data Security Measures

skylot implements industry-standard technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption. Sensitive data at rest is encrypted using AES-256 encryption.
• Access Controls: Personal information is accessible only to authorized employees and service providers who require access to perform their job functions. Access is granted based on role-based permissions and the principle of least privilege.
• Authentication: Strong password requirements, two-factor authentication (2FA) options, and session timeout mechanisms protect account access.
• Network Security: Firewalls, intrusion detection systems, and DDoS protection safeguard our infrastructure.
• Regular Security Audits: Independent security audits, vulnerability assessments, and penetration testing are conducted regularly.
• Data Backup and Recovery: Redundant backups and disaster recovery plans ensure data availability and business continuity.
• Employee Training: Staff members receive data protection training and are bound by confidentiality obligations.

Despite these measures, no method of electronic transmission or storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and promptly notifying us of any unauthorized access.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

10.1 Right to Access

You have the right to obtain confirmation of whether skylot processes your personal data and to request access to such data. Upon request, we will provide a copy of your personal information in our possession.

10.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You may update your account details directly through the Platform settings or contact customer support for assistance.

10.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal information under certain circumstances, such as when:

• The data is no longer necessary for the purposes for which it was collected.
• You withdraw consent and there is no other legal basis for processing.
• You object to processing and there are no overriding legitimate grounds.
• The data has been unlawfully processed.

However, we may retain certain information where required by law (e.g., record-keeping obligations, pending legal disputes).

10.4 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes or where processing is based on legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests.

10.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller where technically feasible.

10.6 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

10.7 Right to Lodge a Complaint

If you believe skylot has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission
• Website: https://www.privacy.gov.ph
• Email: [email protected]
• Hotline: (02) 8234-2228

10.8 Exercising Your Rights

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] or through customer support. We will respond to your request within fifteen (15) business days as required by the DPA. We may request additional information to verify your identity before processing certain requests.

11. Cookies and Tracking Technologies

skylot uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, analyze Platform usage, and deliver personalized content.

11.1 Types of Cookies We Use

• Essential Cookies: Necessary for Platform functionality, account authentication, and security. These cannot be disabled.
• Performance Cookies: Collect anonymous data about how you use the Platform to help us improve performance and troubleshoot issues.
• Functional Cookies: Remember your preferences, language settings, and previous actions to provide a personalized experience.
• Targeting/Advertising Cookies: Track your browsing activity to deliver relevant advertisements on skylot and third-party websites. These cookies require your consent.

11.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies. However, disabling essential cookies may impair Platform functionality. For more information, visit your browser's help section.

12. Children's Privacy

skylot does not knowingly collect personal information from individuals under twenty-one (21) years of age. Our Services are intended exclusively for adults who meet the legal gambling age requirement in the Philippines.

If we discover that we have inadvertently collected personal data from a minor, we will delete such information immediately and permanently ban the associated account. Parents or guardians who believe their child has provided personal information to skylot should contact us immediately at [email protected].

13. Third-Party Links and Services

The skylot Platform may contain links to third-party websites, applications, or services that are not operated or controlled by us. This Privacy Policy does not apply to such third-party services. We encourage you to review the privacy policies of any third-party sites you visit. skylot is not responsible for the privacy practices or content of third-party websites.

14. Updates to This Privacy Policy

skylot reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated via:

• Email notification to the address associated with your account.
• Prominent notice on the Platform homepage.
• In-app notifications when you log in.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Amendments become effective seven (7) days after notification unless otherwise specified. Your continued use of skylot after the effective date constitutes acceptance of the revised Privacy Policy.

We recommend reviewing this Privacy Policy periodically to stay informed about how we protect your personal information.

15. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact:

• Data Protection Officer: [email protected]
• General Privacy Inquiries: [email protected]
• Customer Support: [email protected]
• Live Chat: Available 24/7 through the Platform

skylot is committed to responding to all privacy-related inquiries within fifteen (15) business days.