luckgame Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") is published by luckgame.asia ("luckgame", "we", "us", or "our") in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as applicable directives from the Philippine Amusement and Gaming Corporation (PAGCOR).

This Policy applies to all personal information collected by luckgame from players, prospective players, and visitors to luckgame.asia, whether collected through the website, mobile interfaces, customer support interactions, or any other channel operated by luckgame.

By registering an account with luckgame or otherwise using our Platform, you acknowledge that you have read, understood, and agree to the collection and use of your personal data as described in this Policy. If you do not agree, please do not use luckgame's services.

2. Data Controller

The data controller responsible for your personal information is luckgame.asia, the operator of the online gaming platform accessible at https://luckgame.asia. luckgame operates under a valid PAGCOR license and is subject to Philippine law, including RA 10173 and its implementing regulations.

For all data privacy enquiries, requests, and concerns, please contact our Data Protection Officer (DPO) using the contact information provided in Section 15 of this Policy.

3. Personal Data We Collect

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

luckgame does not intentionally collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. We do not collect biometric data for identification purposes beyond what you voluntarily provide via device-level biometric authentication.

4. How We Collect Your Data

luckgame collects personal data through the following means:

• Direct provision: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, or contacting customer support;
• Automated technical collection: Data collected automatically when you access luckgame.asia, including IP address, device identifiers, session data, and browsing behaviour via cookies and similar technologies (see Section 8);
• Third-party payment processors: Transaction data received from GCash, Maya, BPI, BDO, and other payment providers when you conduct financial transactions on the Platform;
• Identity verification providers: Verification data from third-party KYC service providers engaged by luckgame to assist with PAGCOR-mandated identity checks;
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with licensing, compliance, or investigation requirements.

5. Legal Basis for Processing

luckgame processes your personal data on the following legal bases under RA 10173:

• Contractual necessity: Processing required to establish, manage, and fulfil our contract with you as a registered luckgame player (account creation, deposits, withdrawals, gameplay);
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AML obligations under RA 9160 (as amended), and other applicable Philippine laws;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your data protection rights;
• Consent: Processing for optional communications such as promotional emails and SMS notifications, where you have given explicit consent during registration or through your Account settings. You may withdraw such consent at any time.

6. How We Use Your Personal Data

luckgame uses your personal data for the following purposes:

• Registering and managing your luckgame Account, including identity verification and age verification (21+ requirement per PAGCOR);
• Processing deposits, withdrawals, and all financial transactions on the Platform;
• Providing customer support through live chat, email, and other support channels;
• Sending transactional communications including deposit confirmations, withdrawal status updates, and security alerts via SMS or email to your registered Philippine mobile number or email address;
• Sending promotional communications, bonus offers, and marketing materials — but only where you have given explicit consent or where permitted by applicable law;
• Monitoring and enforcing responsible gaming measures including deposit limits, session time reminders, and self-exclusion;
• Conducting AML monitoring, fraud detection, and abuse prevention in compliance with PAGCOR requirements and Philippine law;
• Generating internal analytics to improve platform performance, game selection, and user experience;
• Complying with regulatory reporting obligations to PAGCOR, the NPC, or other competent Philippine authorities;
• Resolving disputes, investigating complaints, and enforcing luckgame's Terms and Conditions.

7. Disclosure to Third Parties

luckgame may share your personal data with the following categories of third parties, strictly for the purposes described in this Policy:

• Payment processors: GCash (Mynt), Maya, BPI, BDO, UnionBank, and other licensed Philippine payment service providers, solely for the purpose of processing your financial transactions;
• KYC / identity verification providers: Third-party identity verification service providers engaged by luckgame to fulfil PAGCOR's KYC requirements;
• Game providers: Licensed third-party game providers (such as JILI, PG Soft, Evolution Gaming) may receive anonymised or limited player session data necessary to deliver their games within the luckgame Platform;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government bodies as required by law;
• IT and security service providers: Trusted technology partners providing hosting, cybersecurity, and platform infrastructure services, subject to appropriate data processing agreements;
• Professional advisors: Legal, accounting, and compliance advisors, subject to confidentiality obligations.

luckgame does not sell, rent, or trade your personal data to third parties for commercial advertising or marketing purposes. Where data is shared with third-party processors, luckgame ensures that adequate contractual safeguards are in place consistent with RA 10173.

8. Cookies & Tracking Technologies

luckgame.asia uses cookies and similar technologies (including web beacons, pixel tags, and local storage) to enhance your experience, maintain your session, and improve Platform performance. The main types of cookies used by luckgame are:

• Strictly necessary cookies: Required for core Platform functions such as session management and luckgame Login authentication. These cannot be disabled without affecting Platform functionality;
• Performance cookies: Collect anonymised data on how players navigate luckgame.asia to help us identify and fix performance issues;
• Functional cookies: Remember your preferences such as language settings and notification preferences;
• Analytics cookies: Help luckgame understand aggregate usage patterns to improve game selection and platform design. Data collected is anonymised and not linked to individual player identities.

You can manage your cookie preferences through your browser settings. Blocking strictly necessary cookies may impair your ability to access certain features of luckgame.asia, including the luckgame Login page.

9. Data Retention

luckgame retains your personal data for the following periods:

• Active Account data: Retained for the duration of your Account plus a minimum of five (5) years following account closure, as required by PAGCOR and AML regulations;
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship or the date of the last transaction, consistent with RA 9160 AML requirements;
• Transaction records: Retained for five (5) years from the date of the transaction;
• Customer support communications: Retained for three (3) years from the date of the last interaction;
• Technical / log data: Retained for up to twelve (12) months for security and fraud investigation purposes.

After the applicable retention period expires, personal data will be securely deleted or anonymised such that it can no longer be linked to an individual player.

10. Security Measures

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

• 256-bit Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and luckgame.asia;
• Encryption of sensitive stored data including passwords (bcrypt hashing) and payment method details;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Multi-factor authentication required for administrative access to systems containing personal player data;
• Regular vulnerability assessments and penetration testing of luckgame's platform infrastructure;
• Incident response procedures including breach detection, containment, and notification protocols consistent with RA 10173.

While luckgame implements industry-standard security measures, no online system is entirely immune from risk. You play an important role in protecting your account by maintaining a strong, unique luckgame password and enabling two-factor authentication.

11. Your Privacy Rights

As a data subject under RA 10173 and its Implementing Rules, you have the following rights with respect to personal data held by luckgame:

• Right to be informed: The right to be told what personal data luckgame collects about you and how it is used — which this Policy addresses;
• Right of access: The right to request a copy of the personal data luckgame holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data in your luckgame Account;
• Right to erasure: The right to request deletion of personal data where it is no longer necessary for the purposes for which it was collected, subject to luckgame's legal retention obligations under PAGCOR and AML regulations;
• Right to object: The right to object to processing of your personal data for direct marketing purposes. You may withdraw marketing consent at any time through your Account notification settings;
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used format where technically feasible;
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe luckgame has violated your privacy rights.

To exercise any of the above rights, please contact luckgame's Data Protection Officer using the details in Section 15. We will respond to verified requests within thirty (30) days, or within the timeframe specified by RA 10173 where applicable.

12. Children & Minors

luckgame's Platform is strictly intended for adults aged 21 years or older, as required by PAGCOR. We do not knowingly collect personal data from persons under the age of 21.

If luckgame becomes aware that personal data has been collected from a person under 21, that Account will be immediately suspended, all associated data will be reviewed, and appropriate action will be taken consistent with PAGCOR's requirements and RA 10173. If you believe a minor has registered an Account on luckgame.asia, please notify us immediately at the contact details in Section 15.

13. International Data Transfers

luckgame's primary operations and data storage infrastructure are based in the Philippines. In limited circumstances — for example, where luckgame engages internationally-based game providers, technology vendors, or KYC service providers — your personal data may be transferred to, stored, or processed outside the Philippines.

Where such transfers occur, luckgame ensures that appropriate safeguards are in place consistent with RA 10173's requirements for cross-border data transfers, including contractual data processing agreements with recipient organisations that impose equivalent data protection standards.

14. Changes to This Privacy Policy

luckgame reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR requirements. The date of the most recent revision is indicated at the top of this Policy.

Material changes to this Policy will be communicated to registered luckgame players via email or in-platform notification at least seven (7) days before the amended Policy takes effect. Your continued use of luckgame.asia after the effective date of any amendment constitutes your acknowledgment of the revised Policy.

15. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data held by luckgame, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Privacy / Data Subject Request
• Live Chat: Available 24/7 through the luckgame Platform
• Response Time: luckgame aims to acknowledge all privacy requests within 48 hours and resolve them within 30 days

Complaints may also be submitted to the National Privacy Commission (NPC) of the Philippines through the NPC's official channels.