LuckAce Privacy Policy

1. Introduction

LuckAce ("LuckAce," "we," "us," or "our") takes the privacy and security of your personal data seriously. This Privacy Policy describes how LuckAce collects, uses, stores, shares, and protects personal information obtained from players and visitors who access the LuckAce platform ("Platform").

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. LuckAce is committed to ensuring that all personal data in our possession is processed lawfully, fairly, and transparently, and that it is kept accurate, secure, and only for as long as necessary.

This Privacy Policy should be read alongside our Terms and Conditions, which govern your use of the LuckAce platform. Terms not defined in this Policy carry the meaning given to them in the Terms and Conditions.

2. Data Controller

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

LuckAce has appointed a Data Protection Officer (DPO) who is responsible for over seeing compliance with this Privacy Policy and applicable data protection legislation. Contact details for the DPO are provided in Section 14 of this Policy.

3. Personal Data We Collect

LuckAce collects the following categories of personal data from players and platform visitors:

LuckAce does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by applicable law or regulation (for example, where a player discloses a gambling-related health concern in the context of a responsible gaming request).

4. How We Collect Your Data

LuckAce 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 technical and usage data;
• Third-party sources: Data received from payment processors (such as GCash and PayMaya), identity verification service providers, fraud prevention agencies, and regulatory bodies where we are legally permitted to receive such data;
• Publicly available sources: In limited circumstances, data from publicly available sources such as government registries, where necessary for compliance purposes.

5. How We Use Your Personal Data

LuckAce uses the personal data we collect for the following purposes:

• To create and manage your LuckAce player account;
• To verify your identity and age in compliance with PAGCOR regulations and Philippine law (players must be 21 years of age or older);
• To process deposits and withdrawals through your chosen payment method;
• To provide, maintain, and improve the LuckAce platform and its features;
• To detect, investigate, and prevent fraudulent transactions, money laundering, and other illegal activities;
• To comply with our legal and regulatory obligations, including anti-money laundering (AML) and counter-terrorism financing (CTF) requirements;
• To send you transactional communications relating to your account, such as deposit confirmations, withdrawal notifications, and security alerts;
• To send you promotional communications and offers, where you have consented to receive such communications or where we have a legitimate interest in doing so;
• To monitor your gaming activity for responsible gaming purposes and to enforce any self-exclusion or limit settings you have applied to your account;
• To resolve disputes and respond to complaints or support requests;
• To conduct internal analytics and research to improve our products and services.

6. Legal Basis for Processing

LuckAce processes your personal data on the following legal bases as provided under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and provision of gaming services;
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC, AML, CTF, and PAGCOR regulatory requirements;
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly in relation to marketing communications and non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Data Sharing & Disclosure

LuckAce does not sell, rent, or trade your personal data to third parties. 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, BPI, BDO, Metrobank, and other approved payment service providers, for the purpose of processing your deposits and withdrawals;
• Identity verification providers: Third-party KYC and age verification service providers engaged to assist with regulatory compliance;
• Fraud prevention and security providers: Service providers that assist LuckAce in detecting and preventing fraudulent activity and maintaining platform security;
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other government bodies where disclosure is required by law or regulation;
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by LuckAce in connection with the operation of the business, subject to confidentiality obligations;
• Business successors: In the event of a merger, acquisition, or sale of all or part of LuckAce's business, your personal data may be transferred to the relevant successor entity, subject to equivalent data protection obligations.

8. Data Retention

LuckAce retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and regulatory record-keeping requirements;
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations;
• Communications data: Support and complaint records are retained for a minimum of three (3) years from the date of the communication;
• Technical and usage data: Retained for up to two (2) years from the date of collection, unless a longer period is required for security or fraud investigation purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with LuckAce's data disposal procedures. Where data is anonymised, it may be retained indefinitely for analytical purposes as it can no longer be linked to an identifiable individual.

9. Data Security

LuckAce implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the LuckAce platform;
• Encryption of sensitive data at rest, including financial information and government ID details;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning of platform infrastructure;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Staff training on data protection obligations and security best practices.

While LuckAce takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, LuckAce will notify the National Privacy Commission and, where required, affected players in accordance with the Data Privacy Act of 2012.

10. Cookies & Tracking Technologies

LuckAce uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the Platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled;
• Performance cookies: Used to collect anonymised information about how players use the Platform, such as which pages are visited most frequently, to help us improve performance and user experience;
• Functional cookies: Used to remember your preferences and settings, such as language preferences and display options, to provide a more personalised experience;
• Analytics cookies: Used to understand aggregate usage patterns and improve our platform features. Data collected through analytics cookies is anonymised and not linked to individual player accounts.

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 LuckAce platform. LuckAce does not use cookies to track your browsing activity on websites other than the LuckAce platform.

11. Your Data Subject Rights

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

• Right to be informed: The right to be informed about how your personal data is collected and processed, as set out in this Privacy Policy;
• Right of access: The right to request a copy of the personal data LuckAce holds about you and information about how it is processed;
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you;
• 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 our 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 our legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where processing is based on your consent or a contract;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe that LuckAce has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 14. LuckAce will respond to all valid requests within thirty (30) days of receipt. We may need to verify your identity before processing your request.

12. Minors & Age Restriction

The LuckAce platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. LuckAce does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the registration and KYC process for all new accounts.

If LuckAce becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the LuckAce platform, please contact our support team immediately.

13. Changes to This Privacy Policy

LuckAce reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. Where changes are material, LuckAce will notify registered players via the email address associated with their account prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how LuckAce protects your personal data. Your continued use of the LuckAce platform following any update constitutes your acknowledgement of the revised Policy.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by LuckAce, please contact our Data Protection Officer:

Data Protection Officer — LuckAce
Email: [email protected]
General Support: [email protected]

You may also reach our customer support team 24/7 via live chat on the LuckAce platform. Please include your registered account username and a clear description of your query to help us assist you efficiently.

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 of the Philippines.