lucky.ph Privacy Policy

1.1 lucky.ph ("we," "us," "our," "the Company") operates the online gaming platform accessible at luckyph.vip, including all associated games, promotions, and account services (collectively, the "Platform"). lucky.ph is the data controller responsible for the personal information collected through the Platform.

1.2 lucky.ph operates within the regulatory framework established by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the data protection requirements of Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

1.3 This Privacy Policy applies to all personal data collected from players, prospective players, and visitors to the lucky.ph Platform, regardless of whether they are located in Metro Manila, Cebu, Davao, or any other part of the Philippines.

2.1 lucky.ph collects personal information in the following categories:

A. Information You Provide Directly

• Registration data: Full legal name, date of birth, residential address, email address, Philippine mobile number, and chosen username;
• Identity verification (KYC) documents: Government-issued ID (passport, driver's license, SSS ID, PhilHealth card, UMID card), proof of address, and proof of payment method;
• Payment information: GCash account number, Maya account details, bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), or debit card details — sufficient to process deposits and withdrawals;
• Communications: Messages sent to customer support, feedback submitted through the Platform, and responses to surveys or promotions.

B. Information Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers;
• Usage data: Pages visited, games played, session duration, betting history, deposit and withdrawal history, bonus usage, and navigation patterns within the Platform;
• Location data: General geographic location derived from your IP address, used to verify that you are accessing the Platform from within the Philippines;
• Cookies and similar technologies: As described in Section 6 of this Policy.

C. Information from Third Parties

• Payment providers: Transaction verification data from GCash, Maya, and partner banks to confirm deposit and withdrawal status;
• Identity verification services: Confirmation results from third-party KYC providers used to verify government-issued IDs;
• Fraud prevention services: Risk scores and flagging data from anti-fraud and anti-money laundering screening services.

3.1 lucky.ph uses your personal information for the following purposes:

3.2 Marketing opt-out. If you no longer wish to receive marketing communications from lucky.ph, you may opt out at any time by updating your communication preferences in your account settings or by contacting customer support. Opting out of marketing will not affect transactional communications related to your account.

4.1 Under the Data Privacy Act of 2012 (RA 10173), lucky.ph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your lucky.ph account, process transactions, and provide gaming services;
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself;
• Legitimate interests: Processing necessary for lucky.ph's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5.1 lucky.ph does not sell, rent, or trade your personal information. We share your data only in the following limited circumstances:

• Payment processors: GCash, Maya, and partner Philippine banks receive the payment details necessary to process your deposits and withdrawals;
• KYC and identity verification providers: Third-party services that assist in verifying government-issued IDs and confirming player eligibility;
• Fraud and AML screening services: Providers that help lucky.ph detect suspicious transactions and comply with the Anti-Money Laundering Act;
• Game software providers: Licensed game developers whose titles are available on the Platform may receive anonymised or pseudonymised gameplay data for technical and audit purposes;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law or court order;
• Professional advisers: Lawyers, auditors, and accountants bound by professional confidentiality obligations, where necessary for lucky.ph's legal and compliance functions.

5.2 All third-party service providers who process personal data on behalf of lucky.ph are required to implement appropriate technical and organisational security measures and to process data only in accordance with lucky.ph's instructions and applicable Philippine law.

6.1 lucky.ph uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse usage patterns. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and display options to personalise your experience.
• Analytics cookies: Collect anonymised data about how players use the Platform — which pages are visited most, where players encounter errors, and how navigation flows work — to help us improve the Platform.
• Marketing cookies: Used only with your consent to deliver relevant promotional content and measure the effectiveness of lucky.ph's marketing campaigns.

6.2 You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent the Platform from functioning correctly. For detailed information on managing cookies in your browser, refer to your browser's help documentation.

7.1 lucky.ph retains your personal data for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by Philippine law.

7.2 The following general retention periods apply:

• Active account data: Retained for the duration of your account's active status plus five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act;
• KYC documents: Retained for five (5) years following account closure or the completion of the business relationship;
• Customer support communications: Retained for two (2) years from the date of the communication;
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter as evidence of the consent.

7.3 When personal data is no longer required, lucky.ph will securely delete or anonymise it in accordance with industry best practices.

8.1 lucky.ph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest, including payment details and identity documents, is encrypted using AES-256;
• Access controls: Personal data is accessible only to authorised lucky.ph personnel with a documented business need. Role-based access controls and multi-factor authentication are enforced for all staff with data access;
• Firewalls and intrusion detection: The Platform is protected by enterprise-grade firewalls and continuous intrusion detection and prevention systems;
• Regular security audits: lucky.ph conducts regular penetration testing and security audits to identify and remediate vulnerabilities;
• Incident response: lucky.ph maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights, we will notify the National Privacy Commission (NPC) and affected players in accordance with the Data Privacy Act.

8.2 While lucky.ph takes all reasonable steps to protect your personal data, no internet transmission or electronic storage system is 100% secure. You are responsible for maintaining the security of your account credentials and for notifying lucky.ph immediately if you suspect unauthorised access to your account.

9.1 As a data subject under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by lucky.ph:

9.2 To exercise any of the above rights, please contact lucky.ph's customer support team via live chat on the Platform. We will respond to all data subject requests within fifteen (15) business days, in accordance with the Data Privacy Act.

10.1 lucky.ph is strictly an adult platform. The Platform is not directed at, and is not intended for use by, persons under the age of twenty-one (21). lucky.ph does not knowingly collect personal data from individuals under 21 years of age.

10.2 If lucky.ph becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended and the personal data will be deleted as soon as practicable, subject to any legal obligations to retain records of the underage access attempt.

10.3 If you are a parent or guardian and believe that your child has registered an account on lucky.ph, please contact our customer support team immediately so that we can take appropriate action.

11.1 lucky.ph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. The "Last Updated" date at the top of this page will be revised accordingly.

11.2 Where changes are material — meaning they significantly affect your rights or how we use your personal data — lucky.ph will notify registered players via email or in-platform notification at least fourteen (14) days before the changes take effect.

11.3 Your continued use of the lucky.ph Platform following notification of changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you should close your account before the revised Policy takes effect.

12.1 If you have any questions, concerns, or requests relating to this Privacy Policy or lucky.ph's handling of your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the lucky.ph Platform — the fastest way to reach our support team;
• Email: [email protected] — for formal data subject requests and privacy-related inquiries.

12.2 For complaints that cannot be resolved directly with lucky.ph, you may contact the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC), Philippines
• Website: privacy.gov.ph
• Address: 5th Floor, Delegation Building, PICC Complex, Pasay City, Metro Manila