luckygames Privacy Policy

Section 01 Introduction

This Privacy Policy ("Policy") describes how luckygames ("luckygames," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "your," or "Player") who access or use the luckygames online gaming platform available at luckygames.today and all associated subdomains, mobile interfaces, and applications (collectively, the "Platform").

luckygames operates in the Philippines and is committed to complying with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). We take our obligations as a personal information controller seriously and have implemented appropriate technical and organizational measures to protect your data.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated herein by reference. If you have any questions about how luckygames handles your personal data, please refer to Section 15 (Contact Us) of this Policy.

Section 02 Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, luckygames acts as the Personal Information Controller in respect of the personal data collected through the Platform. This means luckygames determines the purposes for which, and the manner in which, your personal data is processed.

Where luckygames engages third-party service providers to process personal data on our behalf — such as payment processors, KYC verification providers, and analytics platforms — those parties act as Personal Information Processors and are contractually bound to process your data only in accordance with luckygames's instructions and this Policy.

Section 03 Personal Data We Collect

luckygames collects the following categories of personal data from players and platform users. The specific data collected depends on how you interact with the Platform:

3.1 Identity and Contact Data

• Full legal name (first name, middle name, last name)
• Date of birth and age verification information
• Residential address (including barangay, city/municipality, province, and ZIP code)
• Email address and mobile phone number
• Government-issued identification documents (e.g., Philippine passport, SSS ID, UMID, driver's license, PhilSys national ID)
• Selfie or live photo for identity verification purposes

3.2 Financial Data

• GCash account number or registered mobile number
• PayMaya account details
• Bank account details (BPI, BDO, Metrobank, or other accepted banks) for withdrawal processing
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used
• Account balance information

3.3 Gaming and Behavioral Data

• Game history, including games played, bet amounts, win/loss records, and session durations
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status)
• Customer support interaction records, including chat logs and email correspondence

3.4 Technical and Device Data

• IP address and approximate geolocation data
• Device type, operating system, and browser type and version
• Unique device identifiers
• Login timestamps and session activity logs
• Cookie identifiers and similar tracking technology data (see Section 10)

Section 04 How We Collect Your Data

luckygames collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and device data collected automatically when you access or use the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from security partners; payment confirmation data from GCash, PayMaya, and banking partners.
• Publicly available sources: In limited circumstances, luckygames may verify information against publicly available records for compliance and fraud prevention purposes.

Section 05 How We Use Your Personal Data

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

luckygames does not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

Section 06 Legal Basis for Processing

Under the Data Privacy Act of 2012, luckygames processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the luckygames Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR reporting requirements, and tax regulations.
• Legitimate interests: Processing necessary for luckygames's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Section 07 Data Sharing and Disclosure

luckygames does not sell, rent, or trade your personal data to third parties for their own marketing 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 safeguards:

7.1 Service Providers and Processors

Third-party companies that provide services on our behalf, including KYC and identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), cloud hosting providers, customer support platforms, and analytics services. All processors are bound by data processing agreements that restrict their use of your data to the specific services they provide to luckygames.

7.2 Regulatory and Law Enforcement Authorities

luckygames may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other government authorities where required by law, court order, or regulatory directive. Such disclosures are made only to the extent required and in accordance with applicable legal procedures.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of luckygames's business, your personal data may be transferred to the acquiring entity as part of that transaction. luckygames will notify affected players of any such transfer and ensure that the receiving entity is bound by privacy obligations no less protective than those set out in this Policy.

7.4 With Your Consent

luckygames may share your personal data with other third parties where you have given your explicit prior consent to such sharing.

Section 08 Data Retention

luckygames retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and PAGCOR record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act and related regulations.
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained until consent is withdrawn and for one (1) year thereafter as evidence of consent.
• Technical and device logs: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, luckygames will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

Section 09 Data Security

luckygames implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the luckygames Platform.
• Encryption at rest for sensitive personal and financial data stored on luckygames servers.
• Multi-factor authentication (MFA) options for player account access.
• Role-based access controls limiting internal access to personal data to authorized personnel only, on a strict need-to-know basis.
• Regular security audits and penetration testing conducted by qualified third-party security professionals.
• Intrusion detection and prevention systems monitoring the Platform for suspicious activity in real time.
• Staff training on data privacy and security obligations under the Data Privacy Act of 2012.

Section 10 Cookies and Tracking Technologies

luckygames uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security and fraud prevention functions. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences and settings (such as language and display preferences) to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how players use the Platform, helping luckygames improve performance and user experience. Data collected is aggregated and does not identify individual users.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the luckygames Platform. luckygames does not use third-party advertising cookies or share cookie data with advertising networks.

Section 11 Your Data Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by luckygames:

To exercise any of these rights, please submit a written request to our Data Protection Officer at [email protected]. luckygames will respond to all verified requests within thirty (30) days of receipt, in accordance with the Data Privacy Act of 2012. We may request proof of identity before processing your request.

If you believe luckygames has not adequately addressed your data privacy concerns, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through their official channels.

Section 12 Minors and Age Restriction

The luckygames Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. luckygames does not knowingly collect personal data from individuals under the age of 21.

If luckygames becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and — where applicable — return any deposited funds. If you believe a minor has registered on the luckygames Platform, please notify us immediately at [email protected].

Section 13 International Data Transfers

luckygames primarily stores and processes personal data within the Philippines. However, certain third-party service providers engaged by luckygames — including cloud infrastructure providers and KYC verification platforms — may process data in other jurisdictions.

Where personal data is transferred outside the Philippines, luckygames ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. Such safeguards may include standard contractual clauses, data processing agreements, or transfers to jurisdictions recognized as providing adequate data protection.

By using the luckygames Platform, you acknowledge and consent to the transfer of your personal data to third-party processors in other jurisdictions where necessary for the provision of luckygames services, subject to the safeguards described above.

Section 14 Changes to This Privacy Policy

luckygames reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, luckygames will notify registered players via email or through a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is always displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how luckygames protects your personal data. Your continued use of the Platform following the posting of any changes constitutes your acceptance of the revised Policy.

Section 15 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way luckygames handles your personal data, please contact our Data Protection Officer:

For unresolved complaints, you may also contact the National Privacy Commission (NPC) of the Philippines through their official website and complaint channels.