luckyph Privacy Policy

1.1 luckyph is committed to protecting the privacy and security of your personal information. This Policy applies to all personal data collected through the luckyph website, mobile interface, customer support channels, and any other services operated by luckyph.

1.2 By registering an Account on luckyph or by continuing to use the Platform after this Policy has been made available to you, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

1.3 If you do not agree with any part of this Policy, you should discontinue use of the luckyph Platform and contact us to request closure of your Account.

1.4 This Policy should be read together with the luckyph Terms & Conditions, which are incorporated herein by reference.

2.1 For the purposes of the Data Privacy Act of 2012 and this Policy, luckyph is the personal information controller responsible for the personal data collected through the luckyph Platform.

2.2 luckyph has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO at any time using the contact details provided in Section 15 of this Policy.

2.3 Where luckyph engages third-party service providers to process personal data on its behalf, such providers act as personal information processors and are bound by contractual obligations to process data only in accordance with luckyph's instructions and applicable law.

3.1 luckyph collects the following categories of personal data:

3.2 luckyph does not intentionally collect sensitive personal information (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless specifically required for responsible gaming compliance or as mandated by applicable law.

4.1 luckyph collects personal data through the following means:

• Direct Interactions: Data you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Technologies: Data collected automatically when you access the Platform, including cookies, web beacons, server logs, and similar tracking technologies that record your IP address, device identifiers, and browsing behavior on the Platform.
• Third-Party Sources: Data received from identity verification providers, payment processors (such as GCash and PayMaya), fraud prevention services, and regulatory authorities where permitted by law.
• KYC Providers: Data obtained during the Know Your Customer verification process, including document scans and biometric verification results provided by our accredited verification partners.

5.1 luckyph uses your personal data for the following purposes:

• To create, manage, and maintain your luckyph Account;
• To verify your identity and age (21+ requirement) in compliance with applicable Philippine regulations;
• To process deposits and withdrawals via GCash, PayMaya, bank transfer, and other approved payment methods;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To provide customer support and resolve disputes;
• To send you transactional communications, including deposit confirmations, withdrawal notifications, and security alerts;
• To send you promotional communications and personalized offers, where you have opted in to receive such communications;
• To monitor your gaming activity for responsible gaming purposes and to enforce deposit limits, cooling-off periods, and self-exclusion requests;
• To improve the luckyph Platform through analytics and user behavior research;
• To comply with legal and regulatory obligations, including reporting requirements under Philippine anti-money laundering laws.

5.2 luckyph will 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 permitted by applicable law.

6.1 luckyph processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform our contract with you, including operating your Account, processing transactions, and providing gaming services;
• Legal Obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and tax obligations;
• Legitimate Interests: Processing necessary for luckyph's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7.1 luckyph 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 only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions;
• Identity Verification Providers: Accredited KYC and age verification service providers to confirm your identity and eligibility;
• Fraud Prevention Services: Third-party fraud detection and anti-money laundering screening providers;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where disclosure is required by law;
• IT & Platform Service Providers: Cloud hosting, data analytics, and cybersecurity providers who process data on our behalf under strict data processing agreements;
• Legal & Professional Advisors: Lawyers, auditors, and compliance consultants bound by professional confidentiality obligations.

7.2 All third-party processors engaged by luckyph are contractually required to implement appropriate technical and organizational security measures and to process personal data only in accordance with luckyph's documented instructions.

7.3 luckyph does not transfer your personal data outside the Philippines except where required by law or where adequate data protection safeguards are in place as required by the National Privacy Commission.

8.1 luckyph uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

8.2 We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled as they are required for security, session management, and core functionality.
• Performance & Analytics Cookies: Help us understand how Players interact with the Platform so we can improve it. Data collected is aggregated and anonymized.
• Functional Cookies: Remember your preferences (such as language settings) to provide a more personalized experience.
• Marketing Cookies: Used to deliver relevant promotional content. These are only activated with your explicit consent.

8.3 You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the luckyph Platform.

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the luckyph Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for Account access and administrative systems;
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC requirements.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, luckyph will notify the National Privacy Commission and affected individuals within the timeframes prescribed by the Data Privacy Act and its Implementing Rules.

9.3 While luckyph takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your Account credentials and for notifying us immediately if you suspect unauthorized access to your Account.

10.1 luckyph retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law, whichever is longer.

10.2 The following general retention periods apply:

• Account Data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, as required by anti-money laundering regulations;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction;
• KYC Documents: Retained for a minimum of five (5) years following Account closure or the completion of the relevant transaction;
• Support Communications: Retained for three (3) years from the date of the last interaction;
• Marketing Preferences: Retained until you withdraw consent or request deletion, subject to legal retention requirements.

10.3 Upon expiry of the applicable retention period, personal data will be securely deleted, destroyed, or anonymized in accordance with luckyph's data disposal procedures.

11.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by luckyph:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy;
• Right of Access: The right to request a copy of the personal data luckyph holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• 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 lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

11.2 To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Rights Request." We will respond within fifteen (15) business days of receiving your request. We may require you to verify your identity before processing your request.

11.3 Please note that certain rights are subject to limitations under applicable law. For example, we may be required to retain certain data for anti-money laundering compliance purposes even if you request deletion.

12.1 The luckyph Platform is strictly intended for individuals who are at least twenty-one (21) years of age. luckyph does not knowingly collect personal data from persons under the age of 21.

12.2 If luckyph becomes aware that personal data has been collected from a person under the age of 21, it will take immediate steps to delete such data and close the associated Account. Any funds held in such an Account will be dealt with in accordance with applicable Philippine law.

12.3 If you are a parent or guardian and believe that your child has provided personal data to luckyph, please contact us immediately at [email protected] so that we can take appropriate action.

13.1 The luckyph Platform may contain links to third-party websites or services for informational purposes. luckyph is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

13.2 The inclusion of any link on the luckyph Platform does not imply endorsement of the linked site or service by luckyph.

14.1 luckyph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify you by email or through a prominent notice on the Platform.

14.2 Your continued use of the luckyph Platform following the posting of any amendments constitutes your acceptance of the revised Privacy Policy. We recommend reviewing this Policy periodically to stay informed of how we protect your data.

14.3 If you do not agree with any changes to this Policy, you should discontinue use of the Platform and contact us to request Account closure.

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

• Data Protection Officer Email: [email protected]
• Subject Line: Privacy Policy Inquiry / Data Rights Request
• Response Time: Within 15 business days of receipt
• Live Chat: Available 24/7 on the luckyph Platform for urgent privacy concerns

15.2 You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data rights have been violated. Information on how to file a complaint is available on the NPC's official website.