Summary: Luck Cola collects only the personal data we genuinely need to operate your account, process payments, and comply with Philippine regulations. We do not sell your personal information to third parties. You have the right to access, correct, or request deletion of your data at any time by contacting support@luckcola.app.
1. Introduction
Welcome to the Luck Cola Privacy Policy. Luck Cola ("we," "us," "our") operates the online gaming platform accessible at luckcola.app. We take the privacy of every Filipino player seriously, and this document is our commitment to being transparent about how we handle your personal information.
This Privacy Policy applies to all personal data collected through the luckcola.app website, any mobile-optimised version of the platform, and any communications between you and Luck Cola — including live chat, email, and promotional messages. It should be read alongside our Terms and Conditions.
By registering a Luck Cola account, you confirm that you have read and understood this policy. If you do not agree with how we handle personal data, please do not create an account or use the platform.
2. What Personal Data We Collect
Luck Cola collects different types of personal data depending on how you interact with the platform. Here is a breakdown of what we may hold about you:
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality | Registration and KYC verification |
| Contact Data | Email address, mobile number, residential address | Registration and account updates |
| Financial Data | GCash number, Maya account, bank account details, card last 4 digits | Deposit and withdrawal processing |
| Verification Documents | Government-issued ID (passport, driver's licence, UMID), selfie photos | KYC verification process |
| Gaming Activity Data | Game history, bet amounts, session duration, win/loss records | Automatically during platform use |
| Technical Data | IP address, device type, browser, operating system, login timestamps | Automatically during platform use |
| Communications Data | Live chat logs, support emails, survey responses | When you contact Luck Cola |
| Marketing Preferences | Opt-in/opt-out status, preferred communication channel | Registration and account settings |
We do not collect sensitive personal data such as racial or ethnic origin, religious beliefs, political opinions, or health information, except where required for responsible gaming assessments under applicable regulations.
3. How We Collect Your Data
3.1 Directly from You
The majority of personal data Luck Cola holds is provided directly by you when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a survey or promotion. We only ask for information that is necessary for the purpose at hand.
3.2 Automatically
When you access luckcola.app or use the platform on a mobile device, we automatically collect certain technical data — including your IP address, device identifiers, browser type, and session information. This data helps us keep the platform secure, diagnose technical problems, and understand how players use different features.
3.3 From Third Parties
Luck Cola may receive data about you from third-party sources including:
- Payment providers (GCash, Maya, banks) — transaction confirmation and account verification data
- Identity verification services — document validation responses during KYC
- Fraud prevention partners — risk signals and flagged account patterns
- Regulatory bodies — information required for licensing compliance
4. Why We Use Your Personal Data
Luck Cola processes your personal data only for legitimate, clearly defined purposes. The main reasons we use your information are:
- Account management — Creating, maintaining, and securing your Luck Cola account, including authentication and password recovery
- Identity and age verification — Confirming you are at least 21 years old and are who you say you are, as required by Philippine gaming regulations
- Payment processing — Facilitating deposits and withdrawals via your chosen Philippine payment method
- Platform operation — Delivering games, calculating results, recording bets, and maintaining game history
- Regulatory compliance — Meeting our obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012 (Republic Act 10173)
- Fraud prevention and security — Detecting and preventing unauthorised access, multi-accounting, and financial crime
- Responsible gaming — Monitoring gaming patterns to identify potential problem gambling behaviour and applying any limits or restrictions you have set
- Customer support — Responding to your enquiries, resolving disputes, and improving our service
- Marketing communications — Sending you information about promotions and new features, but only if you have opted in to receive these
- Platform improvement — Analysing aggregated, anonymised usage data to improve the Luck Cola experience for all players
5. Who We Share Your Data With
Luck Cola does not sell, rent, or trade your personal information to third parties for their own commercial purposes. We share data only when necessary, and only with the following categories of recipients:
5.1 Payment Processors
When you make a deposit or request a withdrawal, we share the minimum necessary data with your chosen payment provider (GCash, Maya, GrabPay, Coins.ph, your bank, or card network) to process the transaction. These providers operate under their own privacy policies and are bound by Philippine financial regulations.
5.2 Game Providers
Luck Cola sources games from licensed third-party providers. These providers may receive your account identifier and session data to deliver and record game results. They do not receive your contact details, financial data, or identity documents.
5.3 Identity Verification Partners
To complete KYC verification, your identity documents and biometric data (selfie photos) may be processed by a third-party verification service. These partners are required to handle your data securely and to use it solely for the purpose of verifying your identity for Luck Cola.
5.4 Regulatory and Legal Authorities
We are legally required to share certain data with Philippine regulatory bodies — including PAGCOR and the Anti-Money Laundering Council (AMLC) — and may be required to disclose information in response to valid court orders, subpoenas, or other legal processes. We will always seek to limit such disclosures to the minimum required by law.
5.5 Fraud Prevention and Security
Luck Cola may share data with fraud prevention and cybersecurity partners to protect the platform and all its members from unauthorised access and financial crime. These partners process data only on Luck Cola's instruction and are bound by strict confidentiality agreements.
6. How Long We Keep Your Data
Luck Cola retains personal data for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. In practice, this means:
- Account data and KYC documents — Retained for the lifetime of your account and for a minimum of 5 years after account closure, in accordance with AMLA record-keeping requirements.
- Financial and transaction records — Retained for a minimum of 5 years as required under Philippine anti-money laundering regulations.
- Gaming activity records — Retained for a minimum of 2 years for dispute resolution and responsible gaming monitoring purposes.
- Support communications — Retained for 2 years after the conversation is closed.
- Marketing data — Retained until you withdraw your marketing consent, after which your preferences will be updated but basic account data will be retained per the schedules above.
When data is no longer required and retention obligations have been met, it is securely deleted or anonymised.
7. How We Protect Your Data
Luck Cola implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, and disclosure. These include:
- SSL/TLS encryption for all data transmitted between your device and luckcola.app
- Encryption of sensitive data fields (including financial data and identity documents) at rest
- Role-based access controls ensuring that only authorised staff can access personal data, and only to the extent necessary for their role
- Regular security audits and penetration testing of the platform
- Multi-factor authentication options for player accounts
- Continuous monitoring for suspicious access patterns and potential breaches
In the event of a data breach that is likely to result in a risk to your rights and freedoms, Luck Cola will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will inform affected players as soon as reasonably practicable.
8. Cookies and Tracking Technologies
Luck Cola uses cookies and similar tracking technologies on luckcola.app to make the platform work properly and to understand how it is being used. A cookie is a small text file placed on your device when you visit a website.
8.1 Strictly Necessary Cookies
These cookies are required for the platform to function. They keep you logged in during your session, maintain your game state, and ensure transactions process correctly. You cannot opt out of strictly necessary cookies without stopping using the platform.
8.2 Performance and Analytics Cookies
These cookies collect anonymised information about how players use Luck Cola — which pages are visited most often, where errors occur, and how long sessions typically last. This data helps us improve the platform. You can opt out of these cookies through your browser settings.
8.3 Functional Cookies
Functional cookies remember your preferences — such as your chosen language or notification settings — so you don't have to set them every time you visit.
You can manage or delete cookies through your browser settings at any time. Note that disabling certain cookies may affect the functionality of the Luck Cola platform.
9. Your Data Rights Under Philippine Law
Under the Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by Luck Cola: