Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how luxebet ("we," "us," or "our") collects, uses, stores, and discloses personal data in connection with the operation of the luxebet online gaming platform, accessible at https://luxebet.app (the "Platform").

This Policy applies to all individuals who access or use the luxebet Platform, including registered account holders, visitors who browse the Platform without registering, and individuals who contact our customer support team. By using the luxebet Platform, you acknowledge that you have read and understood this Privacy Policy.

luxebet is committed to protecting the privacy and personal data of all users in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. We take our obligations under this law seriously and have implemented appropriate technical and organizational measures to safeguard your information.

2. Data Controller Information

luxebet acts as the data controller for personal data collected through the Platform. As data controller, luxebet determines the purposes and means of processing your personal data. If you have any questions about how your data is handled, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

luxebet collects personal data in the following categories, depending on how you interact with the Platform:

We do not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive data is collected (such as government ID documents), it is handled with heightened security measures.

4. How We Use Your Personal Data

luxebet uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your luxebet account, including verifying your identity and age (21+ requirement) during registration.
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver the core functionality of the luxebet Platform.
• Regulatory Compliance: To fulfill our obligations under Philippine gaming regulations, anti-money laundering (AML) laws, and the Data Privacy Act of 2012, including Know Your Customer (KYC) verification.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other illegal or prohibited activities.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 Filipino support team.
• Responsible Gaming: To monitor gaming patterns and identify players who may be at risk of problem gambling, in alignment with PAGCOR's responsible gaming framework.
• Platform Improvement: To analyze usage patterns and technical data to improve the performance, features, and user experience of the luxebet Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where we have a legitimate interest in doing so. You may opt out at any time.

5. Legal Basis for Processing

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

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration, including account management and payment processing.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML obligations, KYC requirements, and gaming regulatory requirements.
• Legitimate Interests: Processing necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your explicit consent, such as for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing of Personal Data

luxebet does not sell, rent, or trade 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 agreements:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• Game Providers: Licensed third-party game suppliers whose games are hosted on the luxebet Platform, to the extent necessary for game operation and fairness auditing.
• Identity Verification Services: Third-party KYC and identity verification providers used to confirm your identity and age during the registration process.
• Regulatory Authorities: PAGCOR and other relevant Philippine government agencies, where disclosure is required by law or regulatory obligation.
• Law Enforcement: Philippine law enforcement agencies or courts, where disclosure is required by a valid legal order, warrant, or subpoena.
• IT and Infrastructure Providers: Cloud hosting, cybersecurity, and technical service providers who support the operation of the luxebet Platform, subject to strict data processing agreements.

All third parties with whom we share personal data are required to handle it in accordance with applicable data protection laws and our contractual requirements. We do not permit third parties to use your data for their own independent purposes.

7. Data Retention

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

As a general guideline:

• Account data and transaction records are retained for a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements.
• KYC and identity verification documents are retained for the duration of the account relationship and for five (5) years thereafter.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Technical and usage data collected via cookies and analytics tools is retained for up to twenty-four (24) months.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

8. Cookies and Tracking Technologies

luxebet uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the Platform, analyze usage patterns, and support our security and fraud prevention measures.

We use the following categories of cookies:

• Essential Cookies: Required for the Platform to function correctly. These cannot be disabled without affecting core functionality, such as maintaining your login session and processing transactions.
• Analytics Cookies: Used to collect aggregated, anonymized data about how users interact with the Platform, helping us identify areas for improvement.
• Preference Cookies: Used to remember your settings and preferences, such as language and display options, to personalize your experience.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the luxebet Platform.

9. Data Security

luxebet implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting access to personal data to authorized personnel only.
• Regular security assessments, penetration testing, and vulnerability scanning of our systems.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Staff training on data protection obligations and security best practices.

While we take all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, luxebet will notify you and the National Privacy Commission (NPC) in accordance with the requirements of the Data Privacy Act of 2012.

10. Your Rights as a Data Subject

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

• Right to be Informed: The right to know what personal data we collect, how we use it, and with whom we share it – as described in this Policy.
• Right of Access: The right to request a copy of the personal data we hold about you.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or updated.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• 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, machine-readable format and to transmit it to another data controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. We will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

11. Children's Privacy

The luxebet Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact our support team immediately.

12. Cross-Border Data Transfers

Some of luxebet's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, luxebet ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses consistent with the requirements of the Data Privacy Act of 2012 and NPC guidelines on cross-border data transfers.

13. Changes to This Privacy Policy

luxebet reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The date of the most recent revision is displayed at the top of this page. Where changes are material, we will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect. Your continued use of the luxebet Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

14. Contact and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact the luxebet Data Protection Officer:

Email: [email protected]

For the fastest response, registered users may also use the live chat feature within their luxebet account. Our Filipino support team is available 24/7.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which oversees enforcement of the Data Privacy Act of 2012.