Laki Win Privacy Policy

This Privacy Policy ("Policy") describes how Laki Win ("we," "us," or "the Platform"), accessible at https://laki-win.app, collects, uses, stores, and protects the personal data of users ("you," "Player," or "User") who access or use the Laki Win online gaming platform.

Laki Win is committed to protecting the privacy and personal data of all Filipino players in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations as administered by the National Privacy Commission (NPC).

This Policy applies to all personal data collected through the Laki Win website, mobile application, customer support channels, and any other interaction you have with the Laki Win platform. It should be read together with our Terms & Conditions, which govern your use of the platform.

Laki Win collects the following categories of personal data from players. We only collect data that is necessary and proportionate to the purposes described in this Policy.

Laki Win collects personal data through the following means:

• Direct Collection: Data you provide when registering an account, completing identity verification, making a deposit or withdrawal, contacting support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the Laki Win platform, including through cookies, log files, and similar tracking technologies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment data from GCash, PayMaya, BPI, BDO, and Metrobank when you initiate a transaction.
• Publicly Available Sources: In limited circumstances, we may verify information against publicly available records or databases as required by Philippine AML regulations.

Laki Win uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your Laki Win player account, including processing your registration and verifying your identity.
• Service Delivery: To provide access to all games and features on the Laki Win platform, including slots, fishing games, virtual sports, poker, and card games.
• Financial Transactions: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and to maintain accurate transaction records in Philippine Peso (₱).
• Legal & Regulatory Compliance: To comply with applicable Philippine laws, including the Data Privacy Act, Anti-Money Laundering Act, and PAGCOR regulatory requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the platform.
• Responsible Gaming: To monitor gaming activity and identify players who may be at risk, and to enforce self-exclusion and deposit limit requests.
• Customer Support: To respond to your inquiries, resolve disputes, and improve the quality of our support services.
• Marketing Communications: To send you promotional offers and updates about Laki Win, where you have provided consent to receive such communications. You may opt out at any time.
• Platform Improvement: To analyse usage patterns and improve the performance, features, and user experience of the Laki Win platform.

Under the Data Privacy Act of 2012, Laki Win processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to upon registration, including account management and transaction processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including AML reporting obligations and PAGCOR licensing requirements.
• Legitimate Interests: Processing necessary for Laki Win's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent, including for marketing communications and the processing of sensitive personal information. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Laki Win does not sell your personal data. We may share your 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, to facilitate deposits and withdrawals. These providers process your financial data under their own privacy policies and applicable Philippine financial regulations.
• Identity Verification Providers: Third-party KYC service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud Prevention Partners: Anti-fraud and risk management service providers who assist Laki Win in detecting and preventing fraudulent activity on the platform.
• IT & Hosting Providers: Cloud hosting and infrastructure providers who store and process data on Laki Win's behalf under strict data processing agreements.
• Regulatory Authorities: The National Privacy Commission, PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or court order.
• Professional Advisers: Legal, accounting, and auditing firms engaged by Laki Win, subject to professional confidentiality obligations.

Laki Win uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit the Laki Win website. We use the following types of cookies:

• Essential Cookies: Required for the platform to function correctly, including maintaining your login session and remembering your preferences. These cannot be disabled without affecting platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Laki Win platform, helping us identify areas for improvement.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.
• Preference Cookies: Used to remember your language, display, and notification preferences across sessions.

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

Laki Win retains your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by Philippine AML regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with the Anti-Money Laundering Act of 2001 and its amendments.
• Identity Verification Documents: Retained for the duration of your account and for five (5) years following account closure.
• Support Communications: Retained for three (3) years from the date of the last communication, for dispute resolution and service improvement purposes.
• Technical & Usage Data: Retained for up to two (2) years from collection, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, your personal data will be securely deleted or irreversibly anonymised. Where data is anonymised, it may be retained indefinitely for statistical and analytical purposes without identifying you personally.

Laki Win implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• TLS (Transport Layer Security) encryption for all data transmitted between your device and the Laki Win platform.
• AES-256 encryption for sensitive data stored in our databases.
• Multi-factor authentication options for player accounts.
• Regular security audits and penetration testing of the Laki Win platform.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While Laki Win takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying Laki Win immediately if you suspect any unauthorised access to your account.

As a data subject under the Data Privacy Act of 2012, Filipino players have the following rights with respect to their personal data held by Laki Win:

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data Laki Win holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by Laki Win.
• 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 Laki Win's legal retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• 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 Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• 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.

To exercise any of the above rights, please contact the Laki Win support team using the contact details provided in Section 14 of this Policy. We will respond to all data rights requests within fifteen (15) business days, in accordance with NPC guidelines. We may need to verify your identity before processing your request.

Laki Win does not knowingly collect, process, or store personal data from individuals under the age of 21. Age verification is a mandatory step in the Laki Win registration process, and we reserve the right to request supporting documentation to confirm a player's age at any time.

If Laki Win 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 Laki Win platform, please contact our support team immediately.

Laki Win primarily processes and stores personal data within the Philippines. In limited circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international KYC partners.

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

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law.
• Transfers only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission.
• Your explicit consent, where required by applicable law.

Laki Win reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform features. When material changes are made, we will notify registered players via email or through a prominent notice on the Laki Win platform.

The date of the most recent revision is displayed at the top of this page. Your continued use of the Laki Win platform following the publication of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by Laki Win, please contact our Data Privacy team. We are available 24/7 to assist Filipino players across Metro Manila, Cebu, Davao, Iloilo, Quezon City, Makati, and the rest of the Philippines.

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated. Information about the NPC and how to file a complaint is available through official Philippine government channels.