philuck Privacy Policy

1. Introduction & Scope

philuck ("we," "us," or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the philuck online casino, sports betting, and gaming platform (the "philuck Platform"). This Privacy Policy ("Policy") describes the types of personal information we collect, the lawful bases on which we process it, how we use and share it, and the rights available to you as a data subject under Philippine law.

This Policy applies to all users of the philuck Platform, including registered account holders, visitors to our website, and any person who communicates with us via email, live chat, or any other channel. It covers personal data collected through our website, mobile interface, promotional materials, and customer support interactions.

By using the philuck Platform, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read alongside the philuck Terms & Conditions, which govern your use of the Platform more broadly.

philuck processes personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC) of the Philippines.

2. Personal Data We Collect

We collect personal data through several channels depending on how you interact with the philuck Platform. The categories of personal information we may collect include:

2.1 Information You Provide Directly

• Registration data: Full legal name, date of birth, residential address (including city such as Manila, Cebu, Davao, or Quezon City), email address, and mobile number.
• Identity verification (KYC) documents: Government-issued ID (e.g., Philippine National ID, passport, driver's license, SSS/GSIS card), proof of address, and selfie photographs as required to verify your identity and age.
• Financial information: GCash mobile number, Maya account details, bank account information (BPI, BDO, UnionBank, Metrobank), Coins.ph wallet ID, or cryptocurrency wallet addresses for deposit and withdrawal processing. Note: philuck does not store full card numbers or CVV codes.
• Communications: Content of messages sent to philuck support via live chat, email, or any other channel, including complaint records and support ticket history.

2.2 Information Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage and behavioral data: Pages visited, games played, bets placed, session duration, click patterns, and feature interactions within the philuck Platform.
• Transaction data: Deposit and withdrawal history, bet records, game round IDs, bonus usage, and account balance history.
• Location data: General geographic location inferred from your IP address for compliance and fraud prevention purposes. philuck does not collect precise GPS location data.
• Cookies and similar technologies: As described in Section 5 of this Policy.

2.3 Information from Third Parties

• Identity verification results from our KYC and AML compliance partners.
• Fraud risk signals from payment processors (e.g., GCash, Maya) to help prevent unauthorized transactions.
• Self-exclusion status data from PAGCOR or other applicable gaming regulatory databases.

3. How We Use Your Personal Data

philuck processes your personal data only where we have a lawful basis to do so. The table below summarizes the primary purposes for which we use your data and the corresponding legal basis under RA 10173:

Where philuck relies on your consent as the lawful basis for processing (such as for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. You can manage your communication preferences through your account settings.

4. Data Sharing & Disclosure

philuck does not sell, rent, or trade your personal data to any third party for their own commercial or marketing purposes. We may share your personal information with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors and e-wallet providers: GCash (Mynt), Maya (Voyager), BPI, BDO, UnionBank, Coins.ph, and other financial service providers, solely to facilitate your deposits and withdrawals.
• KYC and identity verification partners: Third-party verification services engaged to confirm your identity, age, and address as required under PAGCOR licensing conditions and Philippine AML laws.
• Game content providers: JILI and other game studios that supply the casino content on the philuck Platform may process limited technical data (such as game session tokens) as part of their services, subject to their own data protection commitments.
• Regulatory and law enforcement authorities: The Anti-Money Laundering Council (AMLC), PAGCOR, the National Privacy Commission (NPC), and any other competent Philippine authority where disclosure is required by law, court order, or regulatory direction.
• Professional advisers: Legal counsel, auditors, and compliance consultants engaged by philuck, under strict confidentiality obligations.
• IT infrastructure and cloud service providers: Hosting, database, and cybersecurity service providers that support the operation of the philuck Platform, engaged under data processing agreements that require them to protect your information.

Any third party that receives personal data from philuck is contractually required to process it only for the purposes specified, to maintain adequate security standards, and to comply with applicable Philippine data protection law.

5. Cookies & Tracking Technologies

The philuck Platform uses cookies and similar tracking technologies (such as web beacons and local storage) to deliver a functional, personalized, and secure experience. The types of cookies we use are:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without preventing you from using the Platform.
• Functional cookies: Remember your preferences such as language settings, currency display, and game history to personalize your experience on return visits.
• Analytics cookies: Help philuck understand how players navigate the Platform, which features are most used, and where improvements should be made. Data collected through analytics cookies is aggregated and does not identify you individually.
• Security cookies: Used to detect fraud, identify unusual login patterns, and protect the integrity of your philuck account.

You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to log in and use the philuck Platform. Our Platform does not currently respond to "Do Not Track" browser signals, as no uniform standard for such signals exists.

6. Data Retention

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

Key retention periods that apply to philuck player data include:

• Account and KYC records: Retained for a minimum of five (5) years from the date your account is closed, in accordance with the Anti-Money Laundering Act (AMLA) and PAGCOR regulatory requirements.
• Transaction and betting records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw your consent, plus a reasonable period thereafter to demonstrate compliance.
• Cookie and analytics data: Typically retained for thirteen (13) months from collection.

When personal data is no longer required, philuck will securely delete or anonymize it in a manner that ensures it cannot be reconstructed or re-identified.

7. Security Measures

philuck takes the security of your personal data seriously and has implemented a range of technical and organizational measures to protect it against unauthorized access, loss, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the philuck Platform.
• Encryption of sensitive personal data (including KYC documents and financial details) stored in our databases.
• Role-based access controls that restrict employee access to personal data strictly to those who need it to perform their job functions.
• Regular security assessments, vulnerability scanning, and penetration testing of the philuck Platform.
• Two-factor authentication (2FA) options for player accounts to reduce the risk of unauthorized login.
• Incident response procedures to detect, contain, and notify affected parties of data breaches in accordance with NPC reporting requirements.

8. Your Rights Under RA 10173

As a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by philuck:

• Right to be informed: You have the right to know what personal data we collect about you, how it is used, and with whom it is shared — this Privacy Policy fulfils that obligation.
• Right of access: You may request a copy of the personal data philuck holds about you, including the purposes for which it is processed.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You can update most account details directly through your philuck account settings.
• Right to erasure: Subject to our legal and regulatory obligations (including AML record-keeping requirements), you may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected.
• Right to data portability: You may request a copy of the personal data you have provided to philuck in a structured, commonly used, and machine-readable format.
• Right to object: You may object to the processing of your personal data where it is based on legitimate interests, or at any time where it is used for direct marketing purposes.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to file a complaint: If you believe philuck has mishandled your personal data, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please submit a written request to our Data Privacy Officer using the contact details provided in Section 11. philuck will respond to all verifiable data subject requests within thirty (30) days of receipt, or within any shorter period required by applicable law.

9. Minors & Age Policy

The philuck Platform is strictly intended for individuals aged 21 years and older, consistent with Philippine gaming regulations. philuck does not knowingly collect personal data from persons under the age of 21.

If you are under 21 years of age, you are not permitted to register an account or use the philuck Platform in any capacity. If philuck discovers or has reason to believe 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 are a parent or guardian and believe that a minor has provided personal information to philuck or accessed our Platform, please contact us immediately at the details provided in Section 11 so that we can investigate and take appropriate action.

10. Changes to This Privacy Policy

philuck reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, philuck will:

• Update the "Last Updated" date at the top of this page;
• Display a prominent notice on the philuck Platform informing registered players of the update; and
• Where required by law or where the changes materially affect your rights, notify you by email to your registered address prior to the changes taking effect.

Your continued use of the philuck Platform after any changes to this Privacy Policy take effect constitutes your acknowledgement of the updated Policy. We encourage you to review this page periodically to stay informed about how philuck protects your personal data.

11. Contact & Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or philuck's personal data processing practices, you are welcome to contact our designated Data Privacy Officer (DPO). philuck is committed to addressing all privacy-related inquiries promptly and transparently.

You may reach the philuck Data Privacy Officer at:

• Email: [email protected] — please include "Privacy Request" in the subject line of your message.
• Platform: Via the live chat support function available within your philuck account.

When submitting a data subject request, please provide your registered username, a clear description of your request or concern, and any supporting information that may help us locate and verify your data. philuck will verify your identity before fulfilling any access, correction, or deletion request, to ensure your data is protected against unauthorized third-party requests.

If you are unsatisfied with philuck's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines, which can be reached through its official government website.