luckmax Privacy Policy

1. Introduction

1.1 luckmax operates an online casino and sports betting platform accessible at luckmax.org, serving Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond. As a platform that handles financial transactions and identity verification, we take our data protection obligations seriously.

1.2 This Privacy Policy applies to all personal data collected through the luckmax website, mobile platform, customer support channels, and any other touchpoint through which you interact with luckmax. It applies to registered players, prospective players, and visitors to the luckmax website.

1.3 luckmax acts as the data controller for personal data collected through the Platform. Our designated Data Protection Officer (DPO) can be contacted at the details provided in Section 13 of this Policy.

2. Personal Data We Collect

2.1 luckmax collects the following categories of personal data:

2.2 luckmax does not collect sensitive personal information (as defined under the Philippine Data Privacy Act) unless strictly required for regulatory compliance, such as government-issued ID numbers for KYC purposes.

3. How We Collect Your Data

3.1 Directly from you when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions.

3.2 Automatically through cookies, web beacons, and similar tracking technologies when you visit or use the luckmax Platform. See Section 8 for full details on our cookie practices.

3.3 From third parties including identity verification service providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), fraud prevention services, and regulatory bodies where required by law.

4. How We Use Your Personal Data

4.1 luckmax uses your personal data for the following purposes:

• Account Management: Creating and maintaining your luckmax account, verifying your identity, and managing your login credentials.
• Transaction Processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods in Philippine Peso.
• Regulatory Compliance: Meeting our obligations under PAGCOR regulations, the Philippine Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Responsible Gaming: Monitoring gaming activity to identify signs of problem gambling and applying responsible gaming tools where appropriate.
• Customer Support: Responding to your enquiries, resolving disputes, and improving our support services.
• Security & Fraud Prevention: Detecting and preventing fraudulent activity, unauthorised account access, and abuse of our platform.
• Platform Improvement: Analysing usage patterns to improve the luckmax platform, game offerings, and user experience.
• Marketing Communications: Sending you promotional offers and updates about luckmax, where you have provided consent to receive such communications. You may opt out at any time.

5. Legal Basis for Processing

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

• Contractual Necessity: Processing required to fulfil our obligations under the luckmax Terms & Conditions, including account management and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR regulations, AMLA requirements, and other applicable Philippine laws.
• Legitimate Interests: Processing for fraud prevention, platform security, 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. You may withdraw consent at any time by contacting luckmax support or adjusting your browser cookie settings.

6. Data Sharing & Disclosure

6.1 luckmax does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your data only in the following circumstances:

• Payment Processors: We share necessary financial data with GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners solely to process your transactions.
• Identity Verification Providers: We share identity documents with licensed KYC service providers to fulfil our age and identity verification obligations.
• Regulatory Authorities: We may disclose your data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine authorities when required by law or court order.
• Fraud Prevention Services: We share technical and usage data with fraud detection partners to protect the integrity of the luckmax platform and all its players.
• Service Providers: We engage trusted third-party service providers (such as cloud hosting and customer support software providers) who process data on our behalf under strict data processing agreements.

6.2 All third parties with whom luckmax shares personal data are contractually required to handle that data in accordance with the Philippine Data Privacy Act and to implement appropriate security measures.

7. Data Retention

7.1 luckmax retains your personal data for as long as your account is active and for a period thereafter as required by applicable law. The following retention periods apply:

• Account and Identity Data: Retained for a minimum of five (5) years after account closure, as required by PAGCOR and AMLA regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Support Communications: Retained for three (3) years from the date of the communication.
• Technical and Usage Data: Retained for up to two (2) years from collection, unless required longer for security or legal purposes.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year thereafter as evidence of consent.

7.2 Upon expiry of the applicable retention period, luckmax will securely delete or anonymise your personal data in accordance with our data disposal procedures.

8. Cookies & Tracking Technologies

8.1 luckmax uses cookies and similar technologies (including web beacons and local storage) to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in to your luckmax account. These cannot be disabled.
• Performance Cookies: Collect anonymised data about how players use the Platform, such as which pages are visited most frequently. This helps us improve Platform performance.
• Functionality Cookies: Remember your preferences, such as language settings and display options, to personalise your luckmax experience.
• Analytics Cookies: Used to understand aggregate player behaviour and improve our game offerings and promotional strategies.

8.2 You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the luckmax Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate.

9. Data Security

9.1 luckmax implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• AES-256 encryption for data stored on our servers;
• TLS/SSL encryption for all data transmitted between your device and the luckmax Platform;
• Multi-factor authentication options for player accounts;
• Regular security audits and penetration testing by independent security professionals;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• 24/7 monitoring of our systems for suspicious activity and potential security incidents.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, luckmax will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Philippine Data Privacy Act.

9.3 While luckmax takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your luckmax login credentials and for notifying us immediately if you suspect unauthorised access to your account.

10. Your Data Subject Rights

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

• Right to be Informed: The right to know what personal data luckmax collects about you and how it is used – which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data luckmax holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations under PAGCOR and AMLA regulations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another data controller.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

10.2 To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 13. luckmax will respond to all data subject rights requests within thirty (30) days of receipt, as required by the Data Privacy Act.

10.3 luckmax may need to verify your identity before processing a data subject rights request to ensure that personal data is not disclosed to an unauthorised person.

11. Children's Privacy

11.1 The luckmax platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations applicable to online gaming in the Philippines. luckmax does not knowingly collect personal data from individuals under the age of 21.

11.2 If luckmax becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, all data will be deleted, and any funds will be returned to the payment source. If you believe a minor has registered on luckmax, please contact our support team immediately.

12. Changes to This Privacy Policy

12.1 luckmax reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or platform features. When material changes are made, we will notify registered players via email and post a prominent notice on the luckmax Platform.

12.2 The "Last Updated" date at the top of this Policy indicates when the most recent changes were made. Your continued use of the luckmax Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms.

12.3 We encourage you to review this Privacy Policy periodically to stay informed about how luckmax protects your personal data.

13. Contact Us & Data Protection Officer

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

• Email: [email protected]
• Live Chat: Available 24/7 via the luckmax Platform
• Address: Manila, Philippines

13.2 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 (NPC).