Privacy Policy

This Privacy Policy ("Policy") describes how luckpot ("luckpot," "we," "us," "our") collects, uses, stores, shares, and protects the personal data of individuals ("you," "Player," "User") who access or use the luckpot online gaming platform available at luckpot.org and any associated mobile applications or services (collectively, the "Platform"). This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

By registering a luckpot account or using the Platform in any manner, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of the Platform immediately.

1Introduction

luckpot is committed to protecting the privacy and personal data of all players on its platform, particularly Filipino users who trust luckpot with their information when registering, depositing, playing, and withdrawing. This Policy applies to all personal data collected through the luckpot Platform, including data collected via the website, mobile applications, customer support interactions, and any other touchpoints between you and luckpot.

This Policy should be read alongside luckpot's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. In the event of any conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.

2Data Controller

luckpot acts as the data controller in respect of all personal data collected through the Platform. As data controller, luckpot determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law.

luckpot has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection legislation. You may contact the DPO using the contact details provided in Section 16 of this Policy.

3Personal Data We Collect

luckpot collects the following categories of personal data from players:

3.1 Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth
• Gender
• Nationality
• Government-issued identification number (e.g., PhilSys National ID, UMID, driver's license, or passport number)
• Photograph or selfie submitted for identity verification purposes

3.2 Contact Data

• Email address
• Philippine mobile number
• Residential address (including barangay, city/municipality, province, and postal code)

3.3 Financial Data

• GCash or PayMaya account number linked to your luckpot account
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where provided for withdrawal purposes
• Transaction history, including deposits, withdrawals, wagers, and bonus activity
• Source of funds documentation where required under AMLA obligations

3.4 Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session data, including login timestamps and session duration
• Cookies and similar tracking technologies (see Section 10)

3.5 Gaming Data

• Game history, including games played, bet amounts, and outcomes
• Responsible gaming tool usage, including deposit limits, loss limits, and self-exclusion requests
• Bonus and promotion participation history

3.6 Communications Data

• Records of your communications with luckpot's customer support team, including live chat transcripts and email correspondence
• Survey responses and feedback submitted through the Platform

4How We Collect Your Data

luckpot collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud detection data from security partners; payment data from GCash, PayMaya, and banking partners.
• Regulatory sources: Data received from PAGCOR or other regulatory authorities in connection with licensing, compliance, or investigation requirements.

5How We Use Your Personal Data

luckpot uses your personal data for the following purposes:

• Account management: To register, verify, and maintain your luckpot player account.
• KYC and age verification: To verify that you are at least 21 years of age and to confirm your identity in compliance with PAGCOR requirements and Philippine law.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Anti-money laundering compliance: To monitor transactions and report suspicious activity as required under the Anti-Money Laundering Act (AMLA) and PAGCOR regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, and unauthorized access to the Platform.
• Responsible gaming: To administer responsible gaming tools, monitor for signs of problem gambling, and enforce self-exclusion requests.
• Customer support: To respond to your inquiries, complaints, and support requests.
• Platform improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the luckpot Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent to receive such communications. You may opt out at any time.
• Legal compliance: To comply with applicable Philippine laws, PAGCOR regulations, court orders, and lawful requests from regulatory or law enforcement authorities.

6Legal Basis for Processing

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

• Consent: Where you have given explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary for the performance of the contract between you and luckpot, including account registration, payment processing, and game participation.
• Legal obligation: Where processing is required to comply with a legal obligation applicable to luckpot, including PAGCOR licensing requirements, AMLA obligations, and tax reporting requirements.
• Legitimate interests: Where processing is necessary for luckpot's legitimate interests, including fraud prevention, platform security, and responsible gaming enforcement, provided that such interests are not overridden by your fundamental rights and freedoms.

7Data Sharing & Disclosure

luckpot does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with PAGCOR requirements.
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers necessary to process your deposits and withdrawals.
• Fraud prevention and security partners: Service providers engaged to detect and prevent fraudulent activity on the Platform.
• Game content providers: Third-party game developers and live dealer studios whose games are available on the luckpot Platform, to the extent necessary for game operation and dispute resolution.
• 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 regulation.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by luckpot in connection with its business operations, subject to strict confidentiality obligations.

All third-party service providers engaged by luckpot are required to process personal data only in accordance with luckpot's instructions and applicable data protection law, and are prohibited from using your data for their own independent purposes.

8International Data Transfers

Some of luckpot's third-party service providers may be located outside the Philippines. Where personal data is transferred to recipients in other countries, luckpot ensures that appropriate safeguards are in place to protect your data in accordance with the Philippine Data Privacy Act, including the use of standard contractual clauses or other approved transfer mechanisms.

luckpot will not transfer your personal data to any country that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

9Data Retention

luckpot retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. 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, in compliance with PAGCOR and AMLA record-keeping requirements.
• Transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required under Philippine anti-money laundering regulations.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer support records: Retained for a minimum of two (2) years from the date of the interaction.
• Marketing consent records: Retained until you withdraw your consent or for a maximum of three (3) years from the date of consent, whichever is earlier.

Upon expiry of the applicable retention period, luckpot will securely delete or anonymize your personal data in accordance with its data disposal procedures.

10Cookies & Tracking Technologies

luckpot uses cookies and similar tracking technologies on the Platform to enhance your user experience, analyze platform performance, and deliver relevant content. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management and security features. These cannot be disabled.
• Performance cookies: Used to collect anonymized data about how players use the Platform, helping luckpot identify areas for improvement.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies: Used to understand aggregate usage patterns and improve the overall Platform experience.

You can 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 luckpot Platform. luckpot does not use cookies to serve third-party advertising.

11Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by luckpot:

• 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 luckpot holds about you.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held by luckpot.
• 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 luckpot's 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 luckpot's 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 (NPC) if you believe that luckpot has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact luckpot's Data Protection Officer using the contact details provided in Section 16. luckpot will respond to all data subject requests within fifteen (15) calendar days of receipt, in accordance with the requirements of the Philippine Data Privacy Act. In complex cases, this period may be extended by a further fifteen (15) days, in which case luckpot will notify you of the extension and the reasons for it.

Please note that certain rights are subject to limitations under applicable law. For example, luckpot may be unable to delete personal data that it is required to retain under PAGCOR regulations or AMLA obligations, even where a deletion request is received.

12Children's Privacy

The luckpot Platform is strictly intended for individuals aged 21 years and above, as required under Philippine law governing online gaming and casino-style gambling. luckpot does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the luckpot registration process, and luckpot employs technical and manual measures to prevent underage access to the Platform.

If luckpot becomes aware that personal data has been collected from an individual under the age of 21, it will immediately suspend the relevant account, delete the associated personal data, and report the matter to PAGCOR where required. If you believe that a minor has registered a luckpot account, please contact our support team immediately using the details in Section 16.

13Data Security

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

• SSL/TLS encryption: All data transmitted between your device and the luckpot Platform is encrypted using industry-standard SSL/TLS protocols.
• Two-factor authentication (2FA): Available to all players to add an additional layer of security to their luckpot accounts.
• Access controls: Strict role-based access controls ensure that luckpot staff can only access personal data on a need-to-know basis.
• Data minimization: luckpot collects only the personal data that is strictly necessary for the purposes described in this Policy.
• Regular security audits: The Platform undergoes regular security assessments and penetration testing to identify and remediate vulnerabilities.
• Incident response: luckpot maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, luckpot will notify the National Privacy Commission and affected players in accordance with the requirements of the Philippine Data Privacy Act.

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

14Third-Party Links

The luckpot Platform may contain links to third-party websites or services, including payment provider portals and regulatory authority websites. This Policy applies solely to personal data collected by luckpot through the Platform. luckpot is not responsible for the privacy practices of any third-party websites or services, and we encourage you to review the privacy policies of any third-party sites you visit.

15Updates to This Policy

luckpot reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. The date of the most recent revision is indicated at the top of this page. Where changes are material, luckpot will notify registered players via email or an in-platform notification prior to the changes taking effect.

Your continued use of the luckpot Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the updated Policy, you must cease using the Platform and may request account closure by contacting our support team.

16Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or luckpot's handling of your personal data, please contact our Data Protection Officer through the following channels:

• Live Chat: Available 24/7 directly within the luckpot Platform.
• Email: [email protected]
• Support Hours: 24 hours a day, 7 days a week, Philippine Standard Time (PST).

If you are not satisfied with luckpot's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC and its complaint procedures is available through official Philippine government channels.