Privacy Policy

This Privacy Policy ("Policy") describes how luckyplay ("luckyplay," "we," "us," or "our"), the operator of the online gaming platform at luckyplay.one (the "Platform"), collects, uses, stores, and protects the personal information of players and visitors ("you" or "your").

luckyplay is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as any other applicable data protection laws.

By registering an account on luckyplay, accessing the Platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions, which govern your use of the Platform as a whole.

luckyplay collects personal data that you provide directly, data generated through your use of the Platform, and data received from third-party service providers. The categories of personal data we collect include:

luckyplay does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required for responsible gaming assessments or as mandated by applicable law.

luckyplay uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your luckyplay player account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to the games, promotions, and features available on the Platform, and to process your deposits and withdrawals in Philippine Peso (PHP / ₱) via your chosen payment method.
• KYC and Fraud Prevention: To verify your identity and age (21+ requirement), detect and prevent fraudulent activity, money laundering, and other illegal conduct, and to comply with our anti-money laundering (AML) obligations under Philippine law.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance through our live chat and email support channels.
• Responsible Gaming: To monitor your gaming behaviour, identify potential signs of problem gambling, and administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion.
• Legal and Regulatory Compliance: To comply with applicable Philippine laws and regulations, including reporting obligations to PAGCOR and the Anti-Money Laundering Council (AMLC) where required.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the functionality, security, and user experience of the luckyplay Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and news about luckyplay — but only where you have given your consent or where we have a legitimate interest to do so. You may opt out at any time.

luckyplay processes your personal data on the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications or participating in optional surveys.
• Contractual Necessity: Where processing is necessary for the performance of our contract with you — specifically, the Terms & Conditions governing your use of the luckyplay Platform — including account creation, game access, and payment processing.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to luckyplay, including KYC verification, AML reporting, and regulatory compliance with PAGCOR requirements.
• Legitimate Interests: Where processing is necessary for the legitimate interests of luckyplay or a third party, provided that such interests are not overridden by your rights and interests. This includes fraud prevention, Platform security, and service improvement activities.

Where we rely on consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

luckyplay 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:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC and Identity Verification Providers: Third-party identity verification services that assist luckyplay in verifying your age and identity as required by law.
• Game Software Providers: Licensed game suppliers whose games are available on the luckyplay Platform may receive limited technical data necessary to deliver their games to you.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or court order.
• IT and Security Service Providers: Cloud hosting providers, cybersecurity firms, and technical support partners who assist in operating and securing the Platform, subject to strict confidentiality obligations.
• Professional Advisers: Lawyers, auditors, and accountants who provide professional services to luckyplay, subject to professional confidentiality obligations.

luckyplay uses cookies and similar tracking technologies to operate the Platform, enhance your experience, and gather analytical data. The types of cookies we use include:

• 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.
• Analytical Cookies: Help us understand how players use the Platform — which games are most popular, how long sessions last, and where technical issues occur — so we can improve the service.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and gaming activity. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For full details on the cookies we use, please refer to our Cookie Notice, which is accessible from the Platform footer.

luckyplay retains your personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable law. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a period of five (5) years following account closure, in accordance with Philippine AML record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 (Republic Act No. 9160, as amended).
• KYC and Identity Documents: Retained for the duration of your account and for five (5) years following account closure.
• Customer Support Communications: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Technical and Usage Data: Retained for up to two (2) years from collection, after which it is anonymised or deleted.
• Marketing Preferences: Retained until you withdraw your consent or close your account, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with you.

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

• Transport Layer Security (TLS): All data transmitted between your device and the luckyplay Platform is encrypted using TLS 1.2 or higher.
• Data Encryption at Rest: Sensitive personal data stored on our servers is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorised luckyplay personnel and third-party processors on a strict need-to-know basis. All access is logged and audited.
• Two-Factor Authentication: luckyplay supports two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorised access.
• Regular Security Audits: The Platform undergoes regular penetration testing and security audits conducted by independent cybersecurity professionals.
• Incident Response: luckyplay maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) and affected players in accordance with applicable law.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by luckyplay. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13.

luckyplay will respond to all verified data subject requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified accordingly.

The luckyplay Platform is strictly intended for individuals who are 21 years of age or older, consistent with the minimum age requirement for casino-style gambling under Philippine law and PAGCOR-regulated platforms.

luckyplay does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and permanently close the associated account. Any deposits made by underage users will be returned to the original payment method where technically feasible; any winnings generated will be forfeited in full.

If you are a parent or guardian and believe that a minor in your care has registered an account on luckyplay, please contact our support team immediately via live chat or by email at the address provided in Section 13.

luckyplay primarily processes and stores personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers, game software suppliers, and cybersecurity partners — may process data in other jurisdictions.

Where personal data is transferred outside the Philippines, luckyplay ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Philippine law. These safeguards may include:

• Contractual clauses that require the recipient to protect personal data to the same standard as required under the Philippine Data Privacy Act.
• Transfers to countries or organisations that have been assessed as providing an adequate level of data protection.
• Binding corporate rules where data is transferred within a corporate group.

You may request further information about the safeguards applicable to international transfers of your personal data by contacting our Data Protection Officer.

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

The "Effective Date" at the top of this Policy indicates when the current version was last updated. We encourage you to review this Policy periodically to stay informed about how luckyplay protects your personal data.

Your continued use of the Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Policy, you must stop using the Platform and may request account closure in accordance with our Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by luckyplay, please contact us through any of the following channels:

• Live Chat: Available 24/7 directly within the luckyplay Platform — the fastest way to reach us.
• Email (General Support): [email protected]
• Email (Data Protection Officer): [email protected]

Our Data Protection Officer (DPO) is responsible for overseeing luckyplay's compliance with the Philippine Data Privacy Act and this Policy. The DPO can be contacted directly at the privacy email address above for matters specifically relating to your data rights or to report a potential data breach.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.