luckgame Privacy Policy

1. Introduction

luckgame ("luckgame", "we", "our", "the Platform") operates the online gaming platform accessible at luckgame.win. This Privacy Policy ("Policy") describes how luckgame collects, processes, stores, shares, and protects personal data relating to individuals ("you", "the Data Subject") who access, register on, or otherwise interact with the luckgame platform, including through its website, any associated mobile interface, customer support channels, and marketing communications.

luckgame is committed to protecting your privacy and handling your personal data responsibly, transparently, and in compliance with Republic Act No. 10173 (the Data Privacy Act of 2012 or "DPA"), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission ("NPC") of the Philippines. Where luckgame processes data in connection with its PAGCOR-licensed operations, additional regulatory data handling obligations also apply.

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

2. Data Controller

luckgame acts as the personal information controller ("PIC") in respect of personal data collected through the luckgame platform. As PIC, luckgame determines the purposes and means by which your personal data is processed. luckgame is registered with the National Privacy Commission of the Philippines and operates under a valid PAGCOR license.

For all privacy-related inquiries, data subject requests, and concerns, you may contact our designated Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

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

3.1 Identity & Contact Data

• Full legal name as appearing on government-issued identification
• Date of birth (for age verification purposes)
• Gender
• Philippine mobile telephone number
• Email address
• Residential address, including city, province, and postal code

3.2 Identity Verification (KYC) Data

• Copies or photographs of government-issued identification documents (e.g., PhilSys National ID, UMID, passport, driver's licence, SSS/GSIS ID)
• Selfie or facial image submitted for liveness verification
• Source of funds declarations where required by AML regulations

3.3 Financial Data

• GCash account number or Maya account details linked to your luckgame wallet
• Bank account details where bank transfers are used (BPI, BDO, Metrobank, UnionBank, etc.)
• Deposit and withdrawal transaction history
• Account balance information

3.4 Gaming & Behavioural Data

• Game session history, bet amounts, game outcomes, and win/loss records
• Bonus and promotional offer uptake and wagering progress
• Platform navigation patterns and feature usage
• Responsible gaming tool usage (deposit limits, session timers, self-exclusion elections)

3.5 Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Session timestamps and duration
• Cookies and similar tracking technology data (see Section 7)

3.6 Communications Data

• Records of customer support interactions via live chat, email, or ticketing system
• Feedback, complaints, and dispute records
• Marketing communication preferences and opt-in/opt-out records

4. How We Collect Your Data

luckgame collects personal data through the following means:

• Account Registration: Data provided directly by you when creating a luckgame account, including name, mobile number, email, and date of birth
• KYC Submission: Identity documents and facial images submitted voluntarily during the mandatory verification process
• Payment Transactions: Financial data provided when linking a GCash, Maya, or bank account and when processing deposits and withdrawals
• Platform Usage: Data generated automatically as you navigate and interact with luckgame, including gaming activity and session data
• Cookies & Analytics: Technical data collected via cookies, local storage, and analytics tools embedded in the platform
• Customer Support: Information shared during communications with the luckgame support team
• Third-Party Verification Providers: Identity verification data returned from KYC service providers used to confirm document authenticity

5. Purpose & Legal Basis for Processing

luckgame processes personal data on the following legal bases as recognised under the Data Privacy Act of 2012:

Purpose	Legal Basis
Account creation and management	Performance of contract (Terms & Conditions)
Age and identity verification (KYC)	Legal obligation (PAGCOR, AML laws)
Processing deposits and withdrawals	Performance of contract; legal obligation
Anti-money laundering monitoring	Legal obligation (RA 9160 as amended)
Responsible gaming monitoring and intervention	Legal obligation; legitimate interest
Fraud prevention and platform security	Legitimate interest
Customer support and dispute resolution	Performance of contract; legitimate interest
Marketing and promotional communications	Consent (opt-in)
Platform analytics and improvement	Legitimate interest
Regulatory reporting to PAGCOR and AMLC	Legal obligation

6. How We Use Your Data

luckgame uses your personal data for the purposes described in Section 5 and more specifically for the following activities:

• Registering and maintaining your luckgame player account
• Verifying your identity and age to comply with PAGCOR requirements and prevent underage gambling
• Processing your deposits from GCash, Maya, BPI, BDO, and other accepted payment methods
• Processing your withdrawal requests back to your GCash or Maya account (targeting 1-2 hour processing)
• Monitoring for and investigating suspicious transactions, multi-accounting, fraud, and collusion
• Administering bonuses, promotions, and loyalty programme benefits
• Providing 24/7 customer support and resolving disputes
• Sending account notifications, security alerts, and transaction confirmations
• Sending promotional offers and luckgame news where you have opted in to receive such communications
• Complying with reporting obligations to PAGCOR and the Anti-Money Laundering Council (AMLC)
• Improving the luckgame platform based on usage analytics and player feedback
• Monitoring responsible gaming indicators and applying intervention tools where required

7. Cookies & Tracking Technologies

luckgame uses cookies, web beacons, pixel tags, and similar tracking technologies on its platform to facilitate core functionality and improve the user experience. Cookies are small data files stored on your device when you visit luckgame.win.

The categories of cookies used by luckgame include:

• Strictly Necessary Cookies: Required for the platform to function, including session management, login state, and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language, game lobby layout, and notification settings.
• Analytics Cookies: Collect aggregated, anonymised data about platform usage to help luckgame understand how players interact with features and identify areas for improvement.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of marketing campaigns. Applied only where you have provided consent.

You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair the functionality of the luckgame platform, including your ability to log in or complete transactions.

8. Sharing Your Personal Data

luckgame does not sell, rent, or trade your personal data to third parties for commercial purposes. luckgame may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Processors: GCash, Maya, GrabPay, BPI, BDO, Metrobank, InstaPay, and PesoNet, solely for processing your financial transactions
• KYC & Identity Verification Providers: Third-party services used to verify the authenticity of identity documents and facial images submitted during account verification
• Game Providers: Game studios and platform providers (e.g., Pragmatic Play, Evolution Gaming, PG Soft) may receive limited session data to facilitate gameplay
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies in the Philippines, where disclosure is required by law or regulatory directive
• IT & Security Service Providers: Cloud infrastructure, cybersecurity, and platform monitoring vendors operating under binding data processing agreements
• Professional Advisors: Legal, audit, and compliance advisors engaged by luckgame, subject to professional confidentiality obligations

All third parties with whom luckgame shares personal data are required to maintain appropriate security standards and to process such data only for the specified purpose. luckgame does not authorise third parties to use your data for their own independent purposes.

9. Data Retention

luckgame retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by AML regulations
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction
• Customer support communications: Retained for three (3) years from the date of the interaction
• Marketing preference records: Retained until you withdraw consent or for three (3) years from the last meaningful interaction, whichever is earlier
• Analytics data: Retained in anonymised or aggregated form for up to seven (7) years

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

10. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and luckgame's servers
• Encryption at rest for sensitive personal and financial data stored in luckgame's databases
• Multi-factor authentication (OTP via SMS) for account login on unrecognised devices
• Role-based access controls limiting staff access to personal data on a strictly need-to-know basis
• Regular penetration testing and vulnerability assessments conducted by qualified security professionals
• Continuous monitoring of platform infrastructure for anomalies and intrusion attempts
• Mandatory security training for all luckgame employees who handle personal data

In the event of a personal data breach that is likely to result in harm to data subjects, luckgame will notify the NPC within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with the DPA and NPC guidelines.

11. Your Rights as a Data Subject

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

• Right to be Informed: The right to know that your personal data is being or has been collected and processed, and the details of such processing
• Right of Access: The right to obtain confirmation of whether luckgame holds personal data about you and to receive a copy of that data
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or updated
• Right to Erasure or Blocking: The right to request deletion or blocking of personal data where the processing was unlawful, the data is no longer necessary, or consent has been withdrawn, subject to applicable retention obligations
• Right to Object: The right to object to the processing of your personal data where luckgame relies on legitimate interest as the legal basis, or for direct marketing purposes
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission if you believe luckgame has violated your data privacy rights

To exercise any of the above rights, please contact luckgame's Data Protection Officer using the details in Section 15. luckgame will respond to all verified data subject requests within thirty (30) days. In some cases, luckgame may be required to retain certain data notwithstanding an erasure request, where retention is mandated by law (e.g., AML record-keeping requirements).

12. Children & Minors

luckgame is strictly a 21+ platform. luckgame does not knowingly collect personal data from persons under the age of 21. If luckgame becomes aware that personal data has been collected from an underage individual, the account will be immediately suspended, all associated data will be deleted from active systems (subject to any mandatory legal retention obligations), and any funds will be returned to the deposit source. If you are a parent or guardian and believe that a minor has registered on luckgame, please contact our DPO immediately using the details in Section 15.

13. Cross-Border Data Transfers

luckgame's primary data processing infrastructure is located in the Philippines. In certain circumstances, personal data may be transferred to and processed by service providers located outside the Philippines, including cloud infrastructure providers and certain game platform operators. luckgame ensures that any cross-border transfer of personal data is subject to appropriate safeguards, including contractual data processing agreements that impose data protection obligations equivalent to those required under Philippine law. luckgame will not transfer your personal data to a foreign country or international organisation unless such transfer is permitted under the DPA and its implementing rules.

14. Changes to This Privacy Policy

luckgame reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, legal or regulatory requirements, or platform functionality. Material changes to this Policy will be communicated to registered players via email or an in-platform notification at least seven (7) days before the changes take effect. The updated Policy will be published at luckgame.win/privacy-policy with a revised "Last Updated" date. Your continued use of the luckgame platform after the effective date of any revision constitutes your acceptance of the updated Policy.

15. Contact Us & Data Protection Officer

For all privacy-related inquiries, data subject requests, or concerns regarding luckgame's data processing practices, please contact our Data Protection Officer:

Data Protection Officer – luckgame
Email: [email protected]
Platform: Live Chat available to registered luckgame players
Response Time: All privacy requests acknowledged within 48 hours; full response within 30 days

If you are not satisfied with luckgame's response to a privacy complaint, you have the right to escalate your concern to the National Privacy Commission of the Philippines.