luckph Privacy Policy

i Introduction

luckph ("luckph", "we", "us", "the Platform") is committed to protecting the privacy and personal data of every individual who interacts with our platform. This Privacy Policy ("Policy") describes how luckph collects, uses, stores, shares, and protects personal data in connection with the operation of the luckph online gaming platform at luckph.cam.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. Filipino players interacting with luckph — whether based in Metro Manila, Cebu, Davao, or elsewhere in the Philippines — are entitled to the rights and protections set out in this Policy and under the DPA.

1 Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information from which you can be directly or indirectly identified, including your name, email address, date of birth, mobile number, GCash wallet number, and IP address.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, and deletion.
• "Data Controller" means luckph, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party engaged by luckph to process Personal Data on luckph's behalf, subject to luckph's instructions.
• "Data Subject" means the individual whose Personal Data is being processed — in most contexts, you as a luckph player.
• "NPC" means the National Privacy Commission of the Philippines, the government body responsible for enforcing the DPA 2012.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.
• "DPA" means Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations.

2 Personal Data We Collect

luckph collects the following categories of Personal Data in connection with providing its services:

2.1 Registration & Identity Data

• Full legal name;
• Date of birth (required to verify the 21+ age requirement);
• Government-issued identification details (e.g., PhilSys ID, driver's license, passport) when KYC verification is required;
• Email address and Philippine mobile number;
• luckph username and encrypted password.

2.2 Financial & Transaction Data

• GCash wallet number and PayMaya account identifier;
• Bank account details (BPI, BDO, Metrobank) where provided for withdrawals;
• Deposit and withdrawal transaction records including amounts, timestamps, and processing status;
• Bonus and promotion redemption history.

2.3 Gaming Activity Data

• Game session records including games played, wager amounts, outcomes, and session duration;
• Account balance history;
• Responsible gaming limit settings and self-exclusion status.

2.4 Technical & Device Data

• IP address and approximate geographic location;
• Device type, operating system, and browser information;
• Session cookies and login timestamps;
• Platform interaction logs including pages visited and features accessed.

2.5 Communications Data

• Content of support chat interactions and emails submitted to luckph's support team;
• Responses to surveys or feedback requests, where voluntarily provided.

3 How We Collect Personal Data

luckph collects Personal Data through the following means:

• Directly from you — when you register a luckph account, complete identity verification, make deposits or withdrawal requests, contact our support team, or participate in promotions;
• Automatically through the platform — via session cookies, server logs, and analytics tools that record your technical and interaction data as you use luckph;
• From payment service providers — GCash, PayMaya, and our banking partners share transactional confirmation data with luckph to record and reconcile deposits and withdrawals;
• From identity verification providers — third-party KYC service providers may share verification outcomes and document authentication results with luckph where identity verification is required;
• From fraud detection services — automated systems may provide risk scoring or flagging data associated with your account activity.

4 Purpose of Processing & Legal Basis

The table below sets out the purposes for which luckph processes Personal Data and the corresponding legal basis under the DPA 2012:

5 Data Sharing & Third Parties

5.1 Service Providers

luckph shares Personal Data with trusted third-party service providers strictly to the extent necessary to deliver luckph's services. These providers are contractually bound to process data only on luckph's instructions and in accordance with standards consistent with the DPA 2012. Service provider categories include:

• Payment processing partners (GCash / G-Xchange, Inc.; PayMaya / Maya Philippines, Inc.; BPI; BDO; Metrobank);
• Identity verification and KYC service providers;
• Fraud prevention and cybersecurity vendors;
• Game content providers (e.g., Evolution Gaming, Pragmatic Play) — limited to session-level data required to deliver and certify game outcomes;
• Cloud hosting and IT infrastructure providers operating under data processing agreements.

5.2 Legal and Regulatory Disclosure

luckph may disclose Personal Data to Philippine government agencies and regulatory bodies — including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement authorities — where required by law, court order, or in response to a lawful government request.

5.3 No Sale of Data

6 Data Retention

luckph retains Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law. The following general retention principles apply:

• Account and identity data: Retained for the duration of your luckph account and for a minimum of five (5) years following account closure, in compliance with Anti-Money Laundering Council requirements under RA 9160;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with financial record-keeping obligations;
• Gaming activity logs: Retained for three (3) years from the relevant session, or longer where required for dispute resolution or regulatory purposes;
• Support communications: Retained for two (2) years from the date of last interaction, unless a longer period is required in connection with an unresolved dispute;
• Marketing consent records: Retained for the period during which consent remains active, plus three (3) years following withdrawal, to demonstrate compliance.

Upon expiry of the applicable retention period, luckph will securely delete or anonymise Personal Data in accordance with its data disposal procedures.

7 Security Measures

luckph implements technical and organizational security measures designed to protect Personal Data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Transport Layer Security (TLS/SSL): All data transmitted between player devices and luckph's servers is encrypted using 256-bit SSL, consistent with the standard applied by Philippine financial institutions;
• Password hashing: Account passwords are stored using industry-standard one-way hashing algorithms. luckph staff cannot access your plain-text password;
• Access controls: Internal access to Personal Data is restricted on a need-to-know basis, with role-based access controls and audit logging;
• Trusted device recognition: Login activity from unrecognized devices triggers additional verification before account access is granted;
• Real-time monitoring: Automated systems monitor for anomalous access patterns, potential data breaches, and fraudulent activity on a continuous basis;
• Regular security assessments: luckph conducts periodic vulnerability assessments and internal security reviews of its platform and infrastructure.

8 Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device by the luckph platform when you access it through a browser. They allow luckph to recognize your device on subsequent visits and to maintain session continuity, security, and platform preferences.

8.2 Types of Cookies Used by luckph

• Essential cookies: Required for luckph to function correctly. They maintain your login session, implement security features, and enable core platform functionality. These cannot be disabled without disrupting your use of luckph;
• Analytics cookies: Used to collect aggregated, anonymized data about how players navigate and use luckph, enabling platform improvements;
• Preference cookies: Store your display and language preferences to personalize your luckph experience across sessions.

8.3 Managing Cookies

You may manage or disable non-essential cookies through your browser settings at any time. Note that disabling cookies may affect the functionality and user experience of the luckph platform. Essential cookies cannot be disabled without opting out of luckph altogether.

9 Your Rights Under the DPA 2012

As a Data Subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your Personal Data processed by luckph:

10 Minors & the 21+ Requirement

luckph does not knowingly collect Personal Data from individuals under 21 years of age. Access to luckph is strictly limited to players who are at least 21 years old at the time of registration, in compliance with PAGCOR regulations governing online gaming in the Philippines.

All luckph accounts undergo age verification as part of the registration process. Where luckph becomes aware — through account review, identity verification, or third-party reporting — that a minor has accessed the platform, the account will be immediately suspended, all associated Personal Data will be flagged for review, and any balance will be handled in accordance with luckph's legal obligations.

11 Changes to This Privacy Policy

luckph reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. All updates will be published on this page with a revised effective date.

Where changes are material — meaning they significantly affect your rights or how luckph processes your data — luckph will notify registered players via email or a prominent in-platform notification at least fourteen (14) days before the changes take effect.

Continued use of luckph after the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy. If you do not agree with the updated terms, you should close your luckph account before the changes take effect.

12 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or luckph's data processing practices, you may contact luckph's Data Protection Officer through the following channels:

• Email: [email protected] (plain text only — not a clickable link)
• Subject line for data requests: "DPA Data Rights Request – [Your Full Name]"
• Live Chat: Available 24/7 through the luckph platform — average response under 5 minutes
• Languages: English and Filipino (Tagalog)

luckph's support team is available around the clock to assist players across the Philippines — whether you're in Makati, Cebu City, Davao, Cagayan de Oro, or anywhere in between. All data rights requests are handled in confidence and responded to within thirty (30) days.