luckypot Privacy Policy

1.Introduction

luckypot ("we," "us," "our") is committed to protecting the privacy and personal data of every Player who uses our PAGCOR-regulated online casino and sports betting platform at luckypot.win. This Privacy Policy describes the personal data we collect, the purposes for which we use it, how we protect it, and the rights available to you under Philippine law.

This policy is prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the National Privacy Commission's issuances. It is also informed by luckypot's obligations as a PAGCOR-regulated operator, including the Anti-Money Laundering Act of 2001 as amended.

By registering for a luckypot Account, depositing funds, or otherwise using the Platform, you confirm that you have read, understood, and accepted this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of the luckypot Platform.

2.Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, luckypot is the data controller responsible for the personal data of Players collected through the luckypot.win Platform.

luckypot operates under PAGCOR regulation. Our Data Protection Officer (DPO) can be contacted through our 24/7 live chat support or by email at [email protected] — clearly marked as a DPO inquiry.

3.Personal Data We Collect

luckypot collects the following categories of personal data:

3.1 Registration Data

• Full legal name
• Date of birth (to verify 21+ age requirement)
• Philippine mobile number
• Email address
• Username and encrypted password
• Residential address (province, city — e.g., Makati, Cebu City, Davao City)

3.2 Identity Verification (KYC) Data

• Government-issued Philippine ID (PhilSys National ID, passport, driver's license, or similar)
• Proof of address documents
• Selfie or facial image for identity matching
• Proof of payment method ownership where required

3.3 Financial Data

• GCash registered mobile number and account reference
• Maya / BPI / BDO / Metrobank account references (masked)
• Transaction history: deposits, withdrawals, and bet amounts in PHP

3.4 Gameplay & Activity Data

• Game history, bet records, and session duration
• Bonus usage and wagering activity
• Responsible gaming tool settings (deposit limits, self-exclusion status)

3.5 Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser
• Session logs and access timestamps
• Cookie identifiers (see Section 11)

3.6 Communications Data

• Live chat transcripts and support ticket content
• Email correspondence with luckypot
• Responses to surveys or promotions where participated voluntarily

4.How We Collect Your Data

luckypot collects personal data through the following methods:

• Directly from you: through registration forms, identity verification submissions, customer support interactions, and voluntary participation in promotions;
• Automatically: through cookies, server logs, and device fingerprinting when you access the luckypot Platform;
• From third parties: KYC verification providers, payment processors (GCash, Maya, BPI, etc.), and fraud prevention services where required for regulatory compliance.

5.Legal Basis for Processing

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

• Contractual necessity: Processing required to perform the agreement between you and luckypot (account management, game provision, payment processing);
• Legal obligation: Processing required to comply with PAGCOR regulatory requirements, the Anti-Money Laundering Act, and other applicable Philippine law;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement — where these interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent.

6.How We Use Your Personal Data

luckypot uses your personal data for the following purposes:

• To create and manage your luckypot Account, including identity verification;
• To process deposits and withdrawals in PHP and communicate transaction status;
• To provide access to games, live dealer tables, sportsbook markets, and all Platform features;
• To enforce the 21+ age restriction and detect underage access attempts;
• To comply with PAGCOR regulatory requirements, including player activity reporting;
• To comply with the Anti-Money Laundering Act and related regulations, including transaction monitoring and AMLC reporting where required;
• To detect and prevent fraud, collusion, bonus abuse, and other prohibited conduct;
• To administer responsible gaming tools including deposit limits, self-exclusion, and cooling-off periods;
• To send account-related transactional communications (e.g., deposit confirmation, withdrawal processed, OTP codes);
• To send promotional communications where you have opted in;
• To analyse Platform usage and improve luckypot's services;
• To respond to customer support inquiries and resolve disputes.

7.Data Sharing & Disclosure

7.1 luckypot does not sell, rent, or trade your personal data to any third party for commercial purposes.

7.2 luckypot may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• PAGCOR and Philippine regulatory authorities: as required under luckypot's operating license and applicable Philippine law;
• Anti-Money Laundering Council (AMLC): for mandatory suspicious transaction reports and covered transaction reports under the Anti-Money Laundering Act;
• Payment processors: GCash, Maya, BPI, BDO, Metrobank, and other payment providers, to the extent necessary to process transactions;
• KYC and identity verification providers: for identity matching and age verification;
• Fraud prevention and security providers: for the detection of suspicious activity and protection of the Platform;
• Game content providers: strictly limited technical identifiers to enable game session management;
• Law enforcement or courts: where required by a valid legal order issued under Philippine law.

7.3 All third parties with whom luckypot shares personal data are contractually required to process that data only for the specified purpose and to maintain appropriate security standards.

8.International Data Transfers

8.1 Some of luckypot's service providers operate outside the Philippines. Where personal data is transferred internationally, luckypot ensures that such transfers are subject to adequate safeguards consistent with the requirements of the Philippine Data Privacy Act and the National Privacy Commission's rules on cross-border data transfers.

8.2 luckypot will not transfer your personal data to countries or organizations that do not provide an adequate level of data protection without implementing appropriate contractual and security safeguards.

9.Data Retention

9.1 luckypot retains your personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, including:

• Account data: retained for the duration of your Account and for a minimum of 5 years following Account closure, as required by PAGCOR and AML regulations;
• KYC documentation: retained for a minimum of 5 years from the date of the last transaction, as required by Philippine AML law;
• Transaction records: retained for a minimum of 5 years in accordance with PAGCOR requirements;
• Communication logs: retained for 2 years for dispute resolution and regulatory purposes;
• Technical/session logs: retained for up to 12 months.

9.2 Following the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

10.Your Privacy Rights

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

• Right to be informed: the right to know how your data is collected and used — the purpose of this Privacy Policy;
• Right of access: the right to obtain a copy of the personal data we hold about you;
• Right to rectification: the right to correct inaccurate or incomplete personal data;
• Right to erasure: the right to request deletion of personal data that is no longer necessary, subject to legal retention obligations;
• Right to object: the right to object to processing based on legitimate interests, including direct marketing;
• Right to data portability: the right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint: the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your privacy rights have been violated.

To exercise any of these rights, contact luckypot's Data Protection Officer via live chat support or at [email protected]. We will respond within 15 business days of receiving a verified request. Note that some rights are subject to legal exceptions, particularly where retention is required for PAGCOR compliance or AML obligations.

11.Cookies & Tracking Technologies

11.1 luckypot uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Essential cookies: required for Platform functionality, including session management and security. These cannot be disabled.
• Functional cookies: used to remember your preferences (e.g., language, last-played games) to improve your luckypot experience.
• Analytics cookies: used to understand aggregate Platform usage patterns and improve our services. These do not identify you personally.
• Marketing cookies: used to deliver relevant promotional content where you have consented to receive marketing communications from luckypot.

11.2 You can manage non-essential cookies through your browser settings. Disabling certain cookies may affect Platform functionality. For guidance on managing cookies in popular Philippine mobile browsers (Chrome for Android, Safari for iOS), please consult your browser's help documentation.

12.Children & Minors

12.1 luckypot does not knowingly collect personal data from individuals under 21 years of age. The Platform is strictly for adults aged 21 and above as required by PAGCOR and Philippine law.

12.2 If luckypot becomes aware that personal data has been collected from an individual under 21, we will immediately suspend the associated Account, delete the data, and report the incident as required by our PAGCOR obligations.

12.3 If you believe that an underage individual has registered on luckypot, please contact our support team immediately via live chat so we can investigate and take appropriate action.

13.Security Measures

13.1 luckypot implements comprehensive technical and organisational security measures to protect your personal data, including:

• 256-bit SSL/TLS encryption on all data transmissions;
• Encrypted storage of passwords using industry-standard hashing algorithms;
• OTP-based two-factor authentication for Account access;
• Role-based access controls limiting internal data access to personnel with a legitimate operational need;
• Regular security audits and penetration testing of the luckypot Platform;
• Incident response procedures compliant with NPC breach notification requirements.

13.2 In the event of a personal data breach that is likely to pose a risk to your rights and freedoms, luckypot will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected Players without undue delay, as required by the Philippine Data Privacy Act.

14.Third-Party Links & Services

14.1 The luckypot Platform may contain references to third-party services (e.g., payment gateways). This Privacy Policy does not apply to third-party websites or services. luckypot is not responsible for the privacy practices of third-party operators, and Players should review the privacy policies of any third-party services they interact with separately.

14.2 luckypot's game content providers may process limited technical session data to deliver game content. Such providers are contractually required to comply with applicable data protection standards.

15.Changes to This Privacy Policy

15.1 luckypot reserves the right to update this Privacy Policy at any time. The current version will always be published at luckypot.win/privacy-policy with a "Last Updated" date.

15.2 For material changes affecting how your personal data is processed, luckypot will notify you via the Platform or your registered email address at least 15 days before the changes take effect.

15.3 Continued use of the luckypot Platform after the effective date of any updated Privacy Policy constitutes acceptance of the revised terms.

16.Contact & Complaints

16.1 For questions, data access requests, or privacy complaints relating to luckypot, please contact our Data Protection Officer through the following channels:

• Live Chat: Available 24/7 within the luckypot Platform — fastest response, operating on Philippine Standard Time.
• Email: [email protected] — mark your message "DPO / Privacy Inquiry" for routing to our data protection team.

16.2 If you are not satisfied with luckypot's response to your privacy concern, you have the right to file a formal complaint with the National Privacy Commission (NPC) of the Philippines through its official channels at privacy.gov.ph.

16.3 luckypot will acknowledge privacy complaints within 5 business days (Philippine Standard Time) and will endeavour to resolve all complaints within 30 calendar days.