WinLucky Privacy Policy – How We Protect Your Personal Data

About This Privacy Policy

This Privacy Policy describes how WinLucky collects, uses, discloses, and protects personal information provided by members and visitors in connection with the WinLucky platform at winlucky.best. It applies to all WinLucky services, including sports betting, casino games, Tongits, Sabong, virtual sports, fishing games, and any related features, whether accessed through a web browser or mobile device.

WinLucky operates in accordance with the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. By registering for a WinLucky account or using any WinLucky service, you acknowledge that you have read and understood this policy and that you consent to the collection and processing of your personal data as described here.

Personal Data We Collect

WinLucky collects different categories of personal data depending on how you interact with the platform. The categories we may collect include:

• Identity data: Full legal name, date of birth, gender, and government-issued identification details collected during registration or verification.
• Contact data: Email address, mobile number, and mailing address.
• Financial data: Payment method details including GCash account number, Maya account, bank account details, or card numbers as required to process deposits and withdrawals in Philippine pesos.
• Account data: Username, encrypted password, account preferences, deposit and withdrawal history, betting records, game activity, and responsible gaming limit settings.
• Device and technical data: IP address, browser type and version, device identifier, operating system, time zone, and pages visited on WinLucky.
• Communications data: Messages sent to WinLucky support, survey responses, and feedback submitted through the platform.
• Verification data: Copies of government-issued ID, selfies, or other documents submitted during identity verification checks.

How We Collect Your Data

WinLucky collects personal data through the following means:

• Direct input: Information you provide when registering, completing your profile, making a deposit or withdrawal, contacting support, or responding to a survey.
• Automated technologies: Cookies, web beacons, server logs, and similar tools that record device and browsing data when you visit the WinLucky platform.
• Third-party sources: Identity verification providers, payment processors, and fraud prevention services that share data with WinLucky as part of their contractual services to us.
• Account activity: Betting history, game participation, login timestamps, and session data generated automatically when you use WinLucky services.

You may choose not to provide certain optional data, but some data is required to operate your WinLucky account and process transactions. Withholding required data may prevent WinLucky from providing the relevant service.

Legal Basis for Processing

WinLucky processes personal data on one or more of the following lawful bases, consistent with the Data Privacy Act of 2012:

• Contract performance: Processing your registration, account management, deposits, withdrawals, and bet settlement is necessary to fulfil our contract with you as a WinLucky member.
• Legal obligation: Certain data processing, including identity verification and transaction record keeping, is required to comply with anti-money laundering regulations and other applicable Philippine law.
• Legitimate interests: WinLucky processes some data for fraud prevention, platform security, responsible gaming monitoring, and improving our services, where these interests are not overridden by your rights.
• Consent: Where WinLucky relies on your consent, for example for certain marketing communications, you may withdraw that consent at any time by contacting support or updating your account preferences.

How WinLucky Uses Your Personal Data

WinLucky uses the personal data it collects for the following purposes:

• To create and manage your WinLucky account and verify your identity.
• To process deposits and withdrawals in Philippine pesos through your chosen payment channel.
• To settle bets and game outcomes, calculate balances, and maintain transaction records.
• To communicate account updates, transaction confirmations, and important platform notices.
• To detect and prevent fraud, money laundering, collusion, and other prohibited activities.
• To operate responsible gaming tools including deposit limits, session alerts, and self-exclusion requests.
• To respond to support enquiries, complaints, and data rights requests.
• To analyse platform usage and improve WinLucky features, game selection, and user experience.
• To comply with legal reporting, audit, and record-keeping obligations under Philippine law.
• To send marketing communications where you have given appropriate consent and not subsequently opted out.

Sharing Your Personal Data

WinLucky does not sell, rent, or trade your personal information to third parties for marketing purposes. We may share your data with the following categories of recipients only to the extent necessary:

• Payment processors: GCash, Maya, GrabPay, Coins.ph, InstaPay and PESONet providers, BDO, BPI, UnionBank, Visa, Mastercard, and related acquiring banks, to process your financial transactions.
• Identity verification providers: Third-party services that assist WinLucky in verifying the identity and age of members as required by applicable regulation.
• Fraud and security providers: Services that analyse behaviour patterns and technical data to help WinLucky detect and prevent prohibited activity.
• Game content providers: Where a game is delivered by a licensed third-party supplier, minimal technical data may be shared to deliver the game session.
• Legal authorities: Government bodies, law enforcement, or regulatory authorities where disclosure is required by Philippine law, court order, or legal process.
• Professional advisers: Lawyers, auditors, and consultants under strict confidentiality obligations where necessary to protect WinLucky's legal position or business operations.

All third parties receiving your data are required to handle it securely and only for the stated purpose. WinLucky does not permit service providers to use your data for their own purposes beyond the contracted service.

Cookies and Tracking Technologies

WinLucky uses cookies and similar tracking technologies to operate the platform effectively, keep you logged in securely, and understand how the platform is used. The main types of cookies WinLucky uses include:

• Essential cookies: Required for platform functionality such as session management, login state, and payment page security. These cannot be disabled without affecting platform access.
• Analytics cookies: Used to understand how members navigate WinLucky so we can improve the experience. Data collected is aggregated and not used to identify individuals directly.
• Preference cookies: Used to remember settings you apply on the WinLucky platform, such as display preferences.

You can control non-essential cookies through your browser settings. Disabling certain cookies may limit the functionality of some WinLucky features. WinLucky does not use third-party advertising cookies to track your browsing across external websites.

Data Security

WinLucky implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, loss, or destruction. These include encrypted transmission of sensitive data, access controls limiting which staff can view personal information, and regular review of our security practices.

No internet transmission or electronic storage method is completely secure. While WinLucky works to protect your data, we cannot guarantee absolute security. If a data breach occurs that is likely to result in a risk to your rights, WinLucky will notify affected members and the relevant authority as required by applicable law.

Data Retention

WinLucky retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. Specific retention periods include:

• Account and transaction records are typically retained for a minimum of five years following account closure to comply with anti-money laundering and financial record-keeping obligations.
• Identity verification documents are retained for the period required by applicable regulation from the date of verification or account closure.
• Support communications and complaint records are retained for the period required to resolve the matter and any subsequent legal or regulatory review.
• Anonymised or aggregated analytical data that cannot identify any individual may be retained indefinitely for platform improvement purposes.

When personal data is no longer required, WinLucky securely deletes or anonymises it in line with our internal data disposal procedures.

Your Privacy Rights

As a Philippine resident, you have rights under the Data Privacy Act of 2012 regarding your personal information held by WinLucky. These rights include:

• Right to be informed: The right to know what personal data WinLucky collects and how it is processed, which is the purpose of this policy.
• Right of access: The right to request a copy of the personal data WinLucky holds about you.
• Right to correction: The right to have inaccurate or incomplete personal data corrected. You can update basic account information directly in your WinLucky account settings.
• Right to erasure: The right to request deletion of personal data where it is no longer necessary for the purpose collected and no legal obligation requires retention.
• Right to object: The right to object to certain processing activities, including direct marketing where applicable.
• Right to data portability: The right to receive certain personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe WinLucky has handled your data improperly.

To exercise any of these rights, contact WinLucky at support@winlucky.best with your name, registered email address, and a clear description of your request. WinLucky will respond within a reasonable period and may need to verify your identity before fulfilling certain requests.

Minors and Age Restriction

WinLucky does not knowingly collect personal data from individuals below the age of 21. Our platform is strictly for eligible adults. If WinLucky becomes aware that personal data has been collected from a person under 21 without appropriate verification, we will take immediate steps to close the account and delete the associated data. Parents or guardians who believe a minor has registered a WinLucky account should contact support@winlucky.best immediately.

Changes to This Privacy Policy

WinLucky may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or the services we offer. When material changes are made, we will update the effective date at the top of this page and notify active members through the platform or by email where practicable. Continued use of WinLucky after the updated policy takes effect constitutes acceptance of the revised terms. We recommend reviewing this page periodically.

How to Contact WinLucky About Privacy

If you have any questions about this Privacy Policy, how WinLucky handles your personal data, or how to exercise your rights, please contact us:

• Email: support@winlucky.best
• Via the Help section in your WinLucky account area.
• For further information on data rights in the Philippines, the National Privacy Commission website provides guidance for data subjects.

WinLucky aims to respond to all valid privacy enquiries within fifteen business days of receipt. For complex requests, we will acknowledge receipt promptly and provide a full response as soon as reasonably practicable.