LuckyNova Privacy Policy

1. Introduction

LuckyNova ("LuckyNova," "we," "us," or "our") operates the online gaming platform accessible at luckynova.asia (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, including registered players, visitors, and prospective users.

This Privacy Policy ("Policy") describes how LuckyNova collects, uses, stores, shares, and protects personal data in connection with your use of the Platform. It also explains the rights you have under applicable data protection law and how you can exercise those rights.

This Policy should be read alongside LuckyNova's Terms & Conditions, which are available at luckynova.asia/terms-conditions. By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

If you do not agree with this Policy, you must not use the LuckyNova Platform. If you have questions about how we handle your data, please contact our Data Protection Officer using the details in Section 14.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, LuckyNova is the personal information controller responsible for the personal data collected through the Platform.

LuckyNova operates under applicable Philippine gaming regulations and is committed to full compliance with the National Privacy Commission's (NPC) guidelines on data privacy and protection.

All data processing activities carried out by LuckyNova are conducted in accordance with the principles of transparency, legitimate purpose, and proportionality as required under RA 10173.

3. Personal Data We Collect

LuckyNova collects the following categories of personal data from players and users of the Platform:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (used to verify the 21+ age requirement);
• Gender;
• Nationality and country of residence;
• Government-issued identification number (e.g., passport number, driver's license number, PhilSys ID number, UMID number).

3.2 Contact Data

• Email address;
• Mobile phone number;
• Residential address (including barangay, city/municipality, province, and postal code).

3.3 Financial & Payment Data

• GCash or PayMaya account details (mobile number associated with the wallet);
• Bank account details for BPI, BDO, or Metrobank transfers (account name and number);
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used;
• Account balance information.

3.4 Gaming & Activity Data

• Game history, including games played, bet amounts, outcomes, and session duration;
• Bonus and promotion usage history;
• Responsible gaming tool settings (e.g., deposit limits, self-exclusion status);
• Customer support interaction records.

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type;
• Session logs, including login timestamps and session duration;
• Cookie identifiers and similar tracking data (see Section 9).

4. How We Collect Your Data

LuckyNova collects 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 participate in promotions;
• Automatically: When you use the Platform, we automatically collect technical and device data through cookies, log files, and similar technologies (see Section 9);
• From third parties: We may receive data from identity verification providers, payment processors (such as GCash and PayMaya), fraud prevention services, and regulatory authorities where required by law;
• From publicly available sources: In limited circumstances, we may verify information against publicly available records for fraud prevention or regulatory compliance purposes.

5. Purpose & Legal Basis for Processing

LuckyNova processes your personal data for the following purposes, each supported by a lawful basis under RA 10173:

Where LuckyNova relies on your consent as the legal basis for processing (e.g., 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. To withdraw consent, contact us at [email protected] or update your communication preferences in your account settings.

6. Sharing Your Personal Data

LuckyNova does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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, and Metrobank, for the purpose of processing deposits and withdrawals;
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory requirements;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent authorities, where required by law or court order;
• IT and platform service providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements;
• Fraud prevention services: Third-party providers used to detect and prevent fraudulent activity on the Platform;
• Professional advisers: Legal, accounting, and auditing firms, subject to professional confidentiality obligations.

All third parties with whom LuckyNova shares personal data are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with LuckyNova's instructions and applicable law.

7. Data Retention

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

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR and AMLA requirements;
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act;
• Gaming activity data: Retained for three (3) years from the date of the activity, or longer if required for dispute resolution or regulatory purposes;
• Customer support records: Retained for two (2) years from the date of the interaction;
• Marketing data: Retained until you withdraw consent or request deletion, whichever is earlier;
• Technical and device data: Retained for up to twelve (12) months from collection.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with LuckyNova's data disposal procedures. Where data cannot be immediately deleted due to technical constraints, it will be isolated and protected from further processing until deletion is possible.

8. Data Security

LuckyNova implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and the LuckyNova Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest is encrypted using AES-256 encryption;
• Access controls: Access to personal data is restricted to authorized LuckyNova personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations;
• Two-factor authentication: LuckyNova supports two-factor authentication (2FA) for player accounts to provide an additional layer of security;
• Regular security audits: LuckyNova conducts regular security assessments, penetration testing, and vulnerability scans of its Platform and infrastructure;
• Incident response: LuckyNova maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected individuals in accordance with RA 10173.

While LuckyNova takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

9. Cookies & Tracking Technologies

LuckyNova uses cookies and similar tracking technologies to operate and improve the Platform, personalize your experience, and analyze usage patterns. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that prevent fraudulent use. These cannot be disabled;
• Functional cookies: Remember your preferences (e.g., language settings, game preferences) to provide a more personalized experience;
• Analytics cookies: Collect anonymized data about how users interact with the Platform to help us improve performance and user experience;
• Marketing cookies: Used to deliver relevant promotional content based on your interests and gaming activity. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on how to manage cookies, refer to your browser's help documentation.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by LuckyNova:

To exercise any of these rights, please submit a written request to LuckyNova's Data Protection Officer at [email protected]. LuckyNova will respond to all data privacy requests within fifteen (15) business days of receipt. We may require you to verify your identity before processing your request.

If you believe that LuckyNova has not adequately addressed your data privacy concerns, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Minors & Age Restriction

The LuckyNova Platform is strictly intended for individuals who are 21 years of age or older. LuckyNova does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not use the Platform or provide any personal data to LuckyNova.

If LuckyNova becomes aware that personal data has been collected from an individual 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 Platform, please notify us immediately at [email protected].

LuckyNova uses date-of-birth verification during registration and may request additional proof of age documents as part of the KYC process to enforce this restriction.

12. International Data Transfers

LuckyNova primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, such as cloud infrastructure providers or international fraud prevention services.

Where personal data is transferred outside the Philippines, LuckyNova ensures that appropriate safeguards are in place to protect your data, including:

• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the National Privacy Commission;
• Implementing contractual clauses that require recipients to protect personal data to the same standard required under RA 10173;
• Conducting due diligence on all international data processors to verify their security and compliance standards.

13. Changes to This Privacy Policy

LuckyNova 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, LuckyNova will notify registered players via email or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the LuckyNova Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

14. Contact Us & Data Protection Officer

LuckyNova has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection law. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact our DPO through the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 through the LuckyNova Platform
• Service Coverage: Serving players across Manila, Cebu, Davao, Quezon City, Makati, and all of the Philippines

LuckyNova aims to respond to all data privacy inquiries within fifteen (15) business days. For urgent security concerns, please use the live chat function for the fastest response.