luckgame Privacy Policy

1 Data Controller Identity

The data controller responsible for your personal information collected through the luckgame platform (accessible at luckgame.app and associated sub-domains and mobile interfaces) is luckgame ("luckgame," "we," "us," or "our"). luckgame is the operator of the Platform and the entity with primary decision-making authority over the purposes and means of processing your personal data.

luckgame operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and processes personal data in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC").

luckgame has designated a Data Privacy Officer ("DPO") who is responsible for overseeing data protection compliance across the Platform. Contact details for the DPO are provided in Section 15 of this Policy.

2 Personal Data We Collect

luckgame collects personal data in the categories described below. The collection of data marked as "Required" is necessary for the provision of our services; failure to provide such data may prevent account creation or the processing of transactions.

3 How We Collect Your Data

luckgame collects personal data through the following means:

• Directly from you – when you register an account, complete the KYC verification process, make a deposit or withdrawal, contact our support team, or respond to a survey or promotion;
• Automatically – through cookies, log files, and similar tracking technologies when you access the Platform (see Section 8);
• From payment processors – GCash, Maya, BPI, BDO, and other payment partners may transmit transaction confirmation data and partial account identifiers to luckgame for the purpose of crediting deposits and processing withdrawals;
• From identity verification providers – third-party KYC service providers may process your identity documents on our behalf and return a verification result to luckgame;
• From PAGCOR and regulatory authorities – in limited circumstances, luckgame may receive player information from PAGCOR or other regulatory bodies as part of compliance obligations, including anti-money laundering (AML) reporting under the Anti-Money Laundering Act (AMLA);
• From publicly available sources – luckgame may cross-reference publicly available sanction lists, watchlists, and regulatory databases for AML and fraud screening purposes.

4 Legal Bases for Processing

luckgame processes your personal data on the following legal bases under Section 12 and Section 13 of the DPA:

1. Contract Performance. Processing is necessary for the execution of the Terms and Conditions between you and luckgame, including account creation, game provision, deposit processing, and withdrawal execution.
2. Legal Obligation. Processing is required to comply with luckgame's obligations under applicable Philippine law, including the DPA, AMLA, Republic Act No. 9160 as amended, PAGCOR licence conditions, and NPC regulations.
3. Consent. For marketing communications, optional data collection, and certain cookie categories, luckgame relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.
4. Legitimate Interests. luckgame may process certain technical and usage data on the basis of its legitimate interests in platform security, fraud prevention, responsible gaming monitoring, and service improvement, where such interests are not overridden by your privacy rights.

5 How We Use Your Personal Data

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

5.1 Platform Operations

• Creating, maintaining, and authenticating your luckgame account;
• Processing deposits, withdrawals, and related financial transactions in Philippine Peso;
• Providing access to games, promotions, and account features;
• Enabling your use of responsible gaming tools, including deposit limits, self-exclusion, and session time controls.

5.2 Compliance and Regulatory Obligations

• Verifying your age and identity in compliance with PAGCOR requirements and the DPA;
• Screening against AML watchlists and conducting suspicious transaction monitoring under the AMLA;
• Retaining gaming and transaction records in compliance with PAGCOR audit requirements;
• Responding to lawful requests from PAGCOR, the NPC, law enforcement agencies, and courts of competent jurisdiction.

5.3 Security and Fraud Prevention

• Detecting and preventing fraud, identity theft, and unauthorised access to accounts;
• Monitoring for multi-accounting, collusion, and other prohibited conduct under the luckgame Terms and Conditions;
• Investigating and resolving player disputes and complaints.

5.4 Service Improvement

• Analysing anonymised usage patterns to improve Platform functionality, game selection, and payment processing;
• Conducting internal research and analytics to understand player preferences at a general, non-individual level;
• Testing new features and platform updates in a controlled environment.

5.5 Communications

• Responding to your support queries, account issues, and dispute submissions;
• Sending transactional notifications, including deposit confirmations, withdrawal status updates, and KYC approval notices;
• Sending marketing communications where you have opted in (see Section 13).

6 Sharing and Disclosure of Your Data

luckgame does not sell, rent, or trade your personal data to third parties for their own commercial purposes. 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 agreements:

• Payment Processors. GCash, Maya, BPI, BDO, Metrobank, Coins.ph, and other payment partners, solely for the purpose of processing your deposits and withdrawals;
• KYC and Identity Verification Providers. Third-party identity verification service providers engaged to support luckgame's KYC obligations under PAGCOR regulations;
• Game Providers. Software providers whose games are available on the luckgame Platform may receive limited session and bet data necessary to operate their games;
• Cloud and Hosting Providers. Infrastructure and hosting service providers who store luckgame Platform data on servers subject to contractual data protection obligations;
• Regulatory Authorities. PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies as required by law;
• Law Enforcement. Philippine law enforcement agencies and courts, pursuant to lawful court orders, subpoenas, or regulatory directives;
• Professional Advisors. Legal counsel, auditors, and compliance consultants engaged by luckgame, subject to professional confidentiality obligations.

7 Data Retention

luckgame retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to longer retention periods required by applicable law. The following general retention guidelines apply:

• Account data – retained for the duration of your account and for a period of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements;
• KYC documents – retained for a minimum of five (5) years following account closure, or longer if required by the AMLA or PAGCOR;
• Transaction records – retained for five (5) years from the date of the transaction, as required under Philippine tax and financial reporting regulations;
• Gaming activity logs – retained for three (3) years from the date of the recorded activity, subject to PAGCOR audit requirements;
• Support communications – retained for two (2) years from the date of resolution of the relevant query or dispute;
• Marketing consent records – retained for the duration of your marketing opt-in status and for two (2) years following any opt-out, as evidence of the consent history.

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

8 Cookies & Tracking Technologies

luckgame uses cookies and similar tracking technologies (collectively, "Cookies") to operate and improve the Platform. Cookies are small text files stored on your device when you access the Platform. The following categories of Cookies are used:

• Strictly Necessary Cookies. Essential to the functioning of the Platform. These Cookies enable session management, authentication, and security features. They cannot be disabled without affecting Platform functionality. No consent is required for these Cookies.
• Functional Cookies. Remember your preferences such as language settings, game lobby filters, and responsible gaming tool configurations to personalise your experience.
• Analytics Cookies. Collect anonymised data about how visitors use the Platform, including pages visited and navigation paths. This data is used to improve Platform performance and content.
• Security Cookies. Support fraud detection and account security features, including device fingerprinting for multi-account detection.

You may manage non-essential Cookie preferences through your browser settings. Note that disabling certain Cookies may affect Platform functionality. For detailed Cookie information, please refer to the Cookie notice displayed on your first visit to the Platform.

9 Data Security Measures

luckgame implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS Encryption. All data transmitted between your device and the luckgame Platform is encrypted using Transport Layer Security (TLS). The Platform operates exclusively over HTTPS.
• Encryption at Rest. Sensitive personal data, including KYC documents and financial records, is encrypted at rest in luckgame's storage infrastructure.
• Access Controls. Access to personal data is restricted to luckgame personnel and authorised third parties who require it to perform their duties, subject to role-based access controls and a need-to-know principle.
• Two-Factor Authentication. luckgame offers two-factor authentication (2FA) for player accounts and enforces 2FA for staff accessing internal systems containing personal data.
• Security Monitoring. luckgame employs continuous security monitoring, intrusion detection systems, and regular penetration testing to identify and address vulnerabilities.
• Incident Response. luckgame maintains a data breach incident response procedure. In the event of a personal data breach that poses a risk to affected individuals, luckgame will notify the NPC and affected data subjects within seventy-two (72) hours of discovery, as required under the DPA.

10 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by luckgame. These rights are subject to applicable exceptions under the DPA and its IRR.

To exercise any of the above rights, submit a written request to luckgame's Data Privacy Officer at the contact details provided in Section 15. luckgame will respond to rights requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. We may require identity verification before processing your request to protect against unauthorised access to account data.

11 Children and Minors

The luckgame Platform is strictly for use by adults aged twenty-one (21) years and above, as required by PAGCOR regulations governing online gaming in the Philippines. luckgame does not knowingly collect personal data from persons under the age of 21.

If luckgame discovers or has reasonable grounds to believe that a person under 21 years of age has registered an account or submitted personal data, luckgame will immediately suspend the account, securely delete the associated data to the extent permitted by law, and report the incident in accordance with its PAGCOR compliance obligations.

If you believe that a minor has created an account on the luckgame Platform, please contact luckgame support immediately via the official support channel.

12 Cross-Border Data Transfers

Some of luckgame's service providers, including cloud infrastructure providers, game software providers, and KYC verification services, operate servers or processing facilities outside the Republic of the Philippines. Where personal data is transferred to recipients in other jurisdictions, luckgame ensures that appropriate safeguards are in place to protect your data, including:

• Data processing agreements that incorporate standard contractual clauses consistent with NPC guidance;
• Transferring data only to countries, organisations, or service providers that provide an adequate level of protection for personal data in the NPC's assessment, or where equivalent contractual protections are contractually imposed;
• Restricting the scope of data transferred to the minimum necessary for the specific purpose of the transfer.

Details of the specific safeguards applicable to any cross-border transfer are available from luckgame's DPO upon written request.

13 Marketing Communications

luckgame will send you promotional communications about bonuses, new games, and special offers only if you have explicitly opted in to receive such communications during registration or at any subsequent point through your account settings.

Marketing messages may be delivered via SMS to your registered Philippine mobile number, email (if provided), or in-platform notifications. Each marketing communication will include clear opt-out instructions.

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

• Updating your communication preferences in your luckgame account settings;
• Replying "STOP" to any SMS marketing message;
• Contacting luckgame support via the official support channel.

Withdrawing consent to marketing communications will not affect the delivery of transactional messages, including deposit confirmations, withdrawal notifications, and security alerts, which are necessary for the operation of your account.

14 Updates to This Privacy Policy

luckgame reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, luckgame will notify registered players via SMS to their registered Philippine mobile number, or via in-platform notification, at least seven (7) days before the updated Policy takes effect.

The date at the top of this Privacy Policy reflects the most recent revision. Continued use of the luckgame Platform after the effective date of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with the updated Policy, you should cease using the Platform and request account closure.

Prior versions of this Privacy Policy are available upon written request to the Data Privacy Officer.

15 Contact & Data Privacy Officer

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