Privacy Policy – luckgame

1. Introduction

luckgame ("we," "us," or "our") operates the online casino and sports betting platform accessible at luckgame.one. As a platform serving Filipino players, luckgame takes its obligations under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations seriously. This Privacy Policy describes how luckgame collects, uses, stores, shares, and protects the personal information of users who register for and use the luckgame platform.

This Privacy Policy applies to all personal data processed by luckgame in connection with your use of the luckgame website, mobile-optimised platform, customer support services, and any promotional or loyalty programmes operated by luckgame. It should be read in conjunction with luckgame's Terms & Conditions, which are available at luckgame.one/terms-conditions.

By registering an account with luckgame, making a deposit, or otherwise using the luckgame platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, you should not use the luckgame platform.

2. Data We Collect

luckgame collects the following categories of personal data from players and platform users:

luckgame does not collect sensitive personal information beyond what is strictly necessary for identity verification, regulatory compliance, and responsible gaming purposes. We do not collect information about your religious beliefs, political opinions, or health status unless directly relevant to a responsible gaming assessment.

3. How We Collect Your Data

luckgame collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and use the luckgame platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from third-party KYC (Know Your Customer) service providers; fraud detection data from security service providers; payment data from payment processors including GCash and Philippine banking partners.
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with compliance obligations, including self-exclusion registers.

4. How We Use Your Data

luckgame uses the personal data it collects for the following purposes:

• To create and manage your luckgame account, including verifying your identity and eligibility to use the platform.
• To process deposits, withdrawals, and other financial transactions through GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other supported payment methods.
• To provide customer support and respond to your enquiries, complaints, and feedback.
• To comply with our legal and regulatory obligations, including anti-money laundering (AML) requirements, PAGCOR reporting obligations, and responsible gaming mandates.
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited activities on the luckgame platform.
• To personalise your luckgame experience, including recommending games and promotions that may be of interest to you based on your usage patterns.
• To send you promotional communications about luckgame offers, bonuses, and new games, where you have consented to receive such communications.
• To monitor and improve the performance, security, and functionality of the luckgame platform.
• To enforce luckgame's Terms & Conditions and other applicable policies.
• To implement responsible gaming measures, including monitoring for signs of problem gambling and applying deposit or session limits where appropriate.

5. Legal Basis for Processing

luckgame 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 from luckgame.
• Contractual necessity: Where processing is necessary to perform the contract between you and luckgame, including account management, payment processing, and game provision.
• Legal obligation: Where processing is required to comply with applicable laws and regulations, including PAGCOR requirements, AML obligations, and tax reporting requirements.
• Legitimate interests: Where processing is necessary for luckgame's legitimate business interests, such as fraud prevention, platform security, and improving the luckgame service, provided these interests are not overridden by your rights and interests.

Where luckgame relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

6. Data Sharing & Disclosure

luckgame does not sell, rent, or trade your personal data to third parties for their own marketing purposes. luckgame may share your personal data with the following categories of recipients in the circumstances described below:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers engaged by luckgame to verify your identity and age in accordance with regulatory requirements.
• Fraud prevention services: Third-party security and fraud detection providers engaged to protect the luckgame platform and its players from fraudulent activity, money laundering, and other prohibited conduct.
• Regulatory authorities: PAGCOR and other Philippine government agencies or law enforcement bodies, where disclosure is required by law, court order, or regulatory directive.
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers who process data on luckgame's behalf under strict data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants, where necessary for luckgame to obtain professional advice or to defend legal claims.

All third parties with whom luckgame shares personal data are required to handle that data in accordance with applicable data privacy laws and luckgame's data protection standards. luckgame does not permit third-party service providers to use your personal data for their own purposes beyond the specific services they provide to luckgame.

7. Cookies & Tracking Technologies

luckgame uses cookies and similar tracking technologies to enhance your experience on the platform, to analyse platform usage, and to support security and fraud prevention measures. The following types of cookies are used on the luckgame platform:

• Essential cookies: Required for the luckgame platform to function correctly, including maintaining your login session, remembering your preferences, and enabling secure transactions. These cookies cannot be disabled without affecting platform functionality.
• Analytics cookies: Used to collect anonymised data about how players use the luckgame platform, including which pages are visited most frequently and how players navigate between sections. This data helps luckgame improve the platform experience.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats on the luckgame platform.
• Preference cookies: Used to remember your settings and preferences on the luckgame platform, such as your preferred language or display settings.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the luckgame platform. For detailed instructions on managing cookies in your browser, refer to your browser's help documentation.

8. Data Retention

luckgame retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account data: Retained for the duration of your luckgame account and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and applicable AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• Identity verification documents: Retained for the duration of your account and for five (5) years following account closure.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Technical and usage data: Retained for up to two (2) years from the date of collection, unless a longer retention period is required for security or legal purposes.

Where personal data is no longer required for any lawful purpose, luckgame will securely delete or anonymise it in accordance with its data disposal procedures.

9. Data Security

luckgame implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the luckgame platform.
• Encrypted storage of sensitive personal and financial data on secure servers.
• Access controls limiting internal access to personal data to authorised personnel on a need-to-know basis.
• Regular security audits and vulnerability assessments of the luckgame platform and infrastructure.
• Multi-factor authentication requirements for administrative access to luckgame systems.
• Staff training on data privacy obligations and secure data handling practices.

While luckgame 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, luckgame will notify you and the National Privacy Commission (NPC) in accordance with the requirements of the Philippine Data Privacy Act.

10. Your Rights

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

• Right to be informed: You have the right to be informed about how luckgame collects and uses your personal data, as set out in this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data luckgame holds about you.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data luckgame 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 luckgame's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on luckgame's legitimate interests.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe luckgame has not handled your personal data in accordance with applicable law.

To exercise any of these rights, please contact luckgame's Data Privacy Officer at [email protected]. luckgame will respond to all data rights requests within thirty (30) days of receipt, in accordance with the requirements of the Philippine Data Privacy Act.

11. Children's Privacy

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

If you are a parent or guardian and believe that your child has registered on the luckgame platform or provided personal data to luckgame, please contact us immediately at [email protected] so that we can take appropriate action.

12. International Data Transfers

luckgame primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines – for example, in connection with cloud hosting or international payment processing – luckgame will ensure that appropriate safeguards are in place to protect your personal data in accordance with the Philippine Data Privacy Act.

Such safeguards may include contractual data protection clauses, adequacy assessments of the recipient country's data protection framework, or other mechanisms recognised under Philippine data privacy law. luckgame will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate protective measures.

13. Updates to This Privacy Policy

luckgame reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, luckgame will notify registered players by posting a notice on the luckgame platform or by sending an email to your registered address.

The date at the top of this Privacy Policy indicates when it was last updated. We encourage you to review this Privacy Policy periodically to stay informed about how luckgame protects your personal data. Your continued use of the luckgame platform following the posting of any updated Privacy Policy constitutes your acceptance of the changes.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or luckgame's handling of your personal data, please contact our Data Privacy Officer:

Email: [email protected]

luckgame aims to acknowledge all privacy-related enquiries within 48 hours and to provide a full response within 30 days. For complaints that cannot be resolved directly with luckgame, you may escalate your concern to the National Privacy Commission of the Philippines.

For questions about responsible gaming tools and self-exclusion options, please visit the Responsible Gaming page. For general platform terms, please refer to the Terms & Conditions.