luckycola Privacy Policy

1. Introduction

luckycola ("luckycola," "we," "us," or "our") operates the online gaming platform accessible at luckycola.one ("Platform"). We are committed to protecting the privacy and personal data of all players, visitors, and users of the luckycola Platform ("you" or "your").

This Privacy Policy ("Policy") describes how luckycola collects, uses, stores, shares, and protects your personal data in connection with your use of the Platform. It also describes the rights available to you under applicable Philippine data protection law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

This Policy applies to all personal data collected through the luckycola website, mobile application, customer support channels, and any other luckycola service. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read alongside luckycola's Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your relationship with luckycola.

2. Data Controller

luckycola is the data controller responsible for the personal data collected through the Platform. As data controller, luckycola determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data protection law.

luckycola has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection legislation. You may contact the DPO using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

3.1 Registration & Identity Data

When you create a luckycola account, we collect the following information:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Residential address in the Philippines (including city, province, and postal code)
• Email address
• Philippine mobile number
• Username and encrypted password
• Gender (optional)

3.2 Identity Verification (KYC) Data

To comply with Philippine anti-money laundering regulations and PAGCOR requirements, we may collect:

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, UMID, driver's licence, PhilSys National ID)
• Proof of residential address documents (e.g., utility bill, bank statement, barangay certificate)
• Proof of payment method ownership
• Selfie or live photo for identity verification purposes

3.3 Financial Data

When you make deposits or request withdrawals, we collect:

• GCash or PayMaya account details (mobile number associated with the account)
• Bank account details (account name, account number, bank name) for bank transfer transactions
• Debit card details (card number, expiry date — stored in tokenised form only)
• Transaction history, including deposit amounts, withdrawal amounts, and timestamps

3.4 Gaming & Activity Data

As part of normal Platform operation, we collect:

• Game play history, including games played, bet amounts, wins, and losses
• Session duration and frequency of play
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status)

3.5 Technical & Device Data

When you access the Platform, we automatically collect:

• IP address and approximate geographic location
• Device type, operating system, and browser type and version
• Unique device identifiers
• Pages visited, links clicked, and time spent on each page
• Referring URL

3.6 Communications Data

When you contact luckycola's customer support team or communicate with us through any channel, we collect:

• The content of your messages, emails, and live chat transcripts
• Records of telephone calls (where applicable)
• Your communication preferences

4. How We Collect Your Data

luckycola collects your personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or update your account settings.
• Automatically: Through cookies, web beacons, and similar tracking technologies when you access and use the Platform. See Section 10 for more information on our use of cookies.
• From third parties: From identity verification service providers, payment processors (such as GCash and PayMaya), fraud prevention services, and regulatory authorities where required by law.
• From publicly available sources: Where necessary for compliance purposes, from publicly available government databases or regulatory watchlists.

5. How We Use Your Personal Data

luckycola uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your luckycola account, including verifying your identity and age (21+), processing your login, and managing your account settings.
• Service delivery: To provide you with access to luckycola's games, promotions, bonuses, and all other Platform features.
• Payment processing: To process your deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card, and to maintain accurate financial records.
• Legal and regulatory compliance: To comply with our obligations under Philippine law, including the Anti-Money Laundering Act (AMLA), PAGCOR regulations, and the Data Privacy Act of 2012. This includes conducting KYC verification, filing suspicious transaction reports with the AMLC where required, and responding to lawful requests from regulatory authorities.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeover, and other illegal or prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming activity for signs of problem gambling, to enforce responsible gaming tools you have set, and to comply with PAGCOR's responsible gaming requirements.
• Customer support: To respond to your enquiries, resolve complaints, and provide technical assistance.
• Marketing and promotions: To send you information about luckycola promotions, bonuses, and new games where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyse usage patterns, conduct research, and improve the luckycola Platform, games, and user experience.

6. Legal Basis for Processing

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

• Contractual necessity: Processing necessary to perform our contract with you (the Terms & Conditions), including account management, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine law, including AMLA, PAGCOR regulations, and tax obligations.
• Legitimate interests: Processing necessary for luckycola's legitimate business interests, including fraud prevention, security, and Platform improvement, where these interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

luckycola does not sell your personal data to third parties. 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, and banking partners, to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers who assist luckycola in verifying player identities.
• Game providers: Software providers whose games are available on the luckycola Platform, to the extent necessary to deliver the gaming service.
• Fraud prevention services: Third-party providers who assist luckycola in detecting and preventing fraud and money laundering.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or regulation.
• Professional advisers: Lawyers, accountants, auditors, and other professional advisers, subject to confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of luckycola's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

8. Data Retention

luckycola retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account data: Retained for the duration of your luckycola account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLA requirements.
• KYC and identity documents: Retained for a minimum of five (5) years following the end of the business relationship, as required by the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years following the date of the transaction.
• Customer support communications: Retained for two (2) years following the resolution of the relevant enquiry or complaint.
• Marketing data: Retained until you withdraw your consent to receive marketing communications.

When personal data is no longer required, luckycola will securely delete or anonymise it in accordance with our data retention and disposal procedures.

9. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the luckycola Platform
• Encryption of sensitive data at rest, including financial data and identity documents
• Strict access controls limiting employee access to personal data on a need-to-know basis
• Regular security audits and penetration testing
• Two-factor authentication options for player accounts
• Continuous monitoring for suspicious activity and potential data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, luckycola will notify the National Privacy Commission (N PC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay where required by law.

While luckycola takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are also responsible for keeping your luckycola login credentials confidential and for notifying us immediately if you suspect any unauthorised access to your account.

10. Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit the luckycola Platform. They allow the Platform to recognise your device, remember your preferences, and provide a personalised experience. luckycola also uses similar tracking technologies such as web beacons and pixel tags.

10.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function correctly, including maintaining your login session and enabling secure transactions. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics cookies: Help luckycola understand how players use the Platform, which pages are most visited, and where improvements can be made. Data collected is aggregated and anonymised.
• Marketing cookies: Used to deliver relevant luckycola promotions and content based on your interests and activity on the Platform. Only used where you have provided consent.

10.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the luckycola Platform and your ability to access certain features. For more information on managing cookies, refer to your browser's help documentation.

11. Your Data Privacy Rights

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

• Right to be informed: You have the right to be informed about how luckycola collects and processes your personal data, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data luckycola holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request that inaccurate or incomplete personal data held by luckycola be corrected or updated. You may update most account information directly through your luckycola account settings.
• Right to erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to luckycola's legal and regulatory retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to luckycola's overriding legitimate grounds.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe luckycola has processed your personal data in violation of the Data Privacy Act of 2012.

12. Minors and Age Restriction

The luckycola Platform is strictly restricted to individuals who are at least twenty-one (21) years of age, in accordance with Philippine gaming regulations. luckycola does not knowingly collect personal data from persons under the age of 21.

If luckycola becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered a luckycola account, please contact our support team immediately using the details in Section 14.

luckycola employs age verification procedures during the registration process and KYC review to prevent underage access to the Platform. These measures are part of luckycola's broader commitment to responsible gaming and player protection.

13. Changes to This Privacy Policy

luckycola 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, luckycola will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is indicated at the top of this page. We encourage you to review this Policy periodically to stay informed about how luckycola protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

14. Contact Us & Data Protection Officer

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

• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the luckycola Platform — the fastest way to reach our team.

If you are not satisfied with luckycola's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) through its official channels.