lakiwon Privacy Policy

1.1 lakiwon is an online gaming platform serving Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond. We are committed to maintaining the trust of our members by handling all personal data with transparency, integrity, and the highest standards of security.

1.2 This Policy applies to all personal data collected through the lakiwon website at https://lakiwon.net, including data collected during account registration, identity verification, deposits and withdrawals, gameplay, customer support interactions, and marketing communications.

1.3 This Policy should be read in conjunction with our Terms and Conditions and our Responsible Gaming Policy, both of which are incorporated herein by reference.

2.1 lakiwon collects personal information that is necessary to deliver our services, comply with legal and regulatory requirements, and protect the integrity of the platform. We collect information in the following categories:

2.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (used to verify that you are 21 years of age or older, as required under PAGCOR-applicable rules);
• Username and password (password stored in encrypted form only);
• Nationality and country of residence.

2.2 Contact Information

• Email address (primary communication channel);
• Mobile phone number (used for two-factor authentication and account security);
• Residential address in the Philippines.

2.3 Identity Verification (KYC) Documents

• Copies of government-issued identification such as Philippine passport, SSS ID, UMID, PhilHealth ID, or driver's license;
• Proof of address documents such as a utility bill or bank statement;
• Selfie or biometric photograph where required for enhanced verification.

2.4 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references;
• GCash or Maya account details (reference numbers only — we do not store full wallet credentials);
• Bank account numbers for BPI, BDO, UnionBank, or Metrobank withdrawals;
• Cryptocurrency wallet addresses (for USDT TRC20 transactions).

2.5 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, pages visited, and features accessed;
• Game history, wager amounts, and gaming session data.

2.6 Communications Data

• Records of live chat, email, and support ticket correspondence with the lakiwon support team;
• Survey responses and feedback submitted voluntarily through the platform.

3.1 lakiwon uses personal data collected from members for the following specific and legitimate purposes:

3.2 lakiwon will not use your personal data for any purpose that is incompatible with the purposes stated in this Policy without first obtaining your explicit consent or as required by applicable law.

4.1 Under the Data Privacy Act of 2012, the processing of personal data must be founded on one or more lawful bases. lakiwon processes your personal data on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and lakiwon, including delivering gaming services, processing transactions, and managing your account;
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, KYC requirements, and data retention mandates;
• Legitimate Interests: Processing is necessary for the legitimate interests of lakiwon, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and interests;
• Consent: Where none of the above bases apply, we will seek your explicit, informed consent before processing your data — particularly for direct marketing communications.

5.1 lakiwon does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal information only in the following limited circumstances:

• Payment Processors: We share necessary transaction data with payment service providers (such as GCash, Maya, BPI, BDO, UnionBank, Metrobank, 7-Eleven Cliqq, Coins.ph) solely to process your deposits and withdrawals;
• Game Providers: Your account identifiers and gaming activity may be shared with third-party game providers to enable game delivery and maintain accurate records;
• Identity Verification Services: KYC document data may be processed by third-party identity verification providers engaged by lakiwon under strict data processing agreements;
• Regulatory & Law Enforcement Authorities: We may disclose your personal data to competent Philippine government authorities, including the Anti-Money Laundering Council (AMLC) and law enforcement agencies, where required by law or valid legal process;
• Professional Advisers: Your data may be accessed by our legal, compliance, and financial advisers under appropriate confidentiality obligations.

5.2 All third-party service providers engaged by lakiwon are required to maintain the confidentiality of your personal data and to process it only in accordance with our instructions and applicable data protection laws.

6.1 lakiwon retains personal data for as long as is necessary to fulfill the purposes outlined in this Policy, or as required by applicable Philippine laws and regulations. The following general retention periods apply:

• Account Data: Retained for the duration of your active membership and for a minimum of five (5) years after account closure, in compliance with AML record-keeping obligations;
• KYC Documentation: Retained for a minimum of five (5) years following the end of the business relationship, as required by the Anti-Money Laundering Act;
• Transaction Records: Retained for a minimum of five (5) years;
• Communications Data: Support records retained for a minimum of three (3) years;
• Marketing Preferences: Retained until you withdraw consent or request removal from our marketing list.

6.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized so that it can no longer be linked to an individual.

7.1 The lakiwon platform uses cookies and similar tracking technologies to enhance your user experience, maintain session continuity, and collect anonymized analytics data. A cookie is a small text file placed on your device when you visit the platform.

7.2 The following types of cookies are used on the lakiwon platform:

• Strictly Necessary Cookies: These are essential for the platform to function correctly. They enable you to navigate the site and use core features such as secure login and session management. These cookies cannot be disabled;
• Analytical / Performance Cookies: These cookies collect anonymized information about how visitors use the platform — such as which pages are visited most frequently and how users navigate between pages. This data helps us improve platform performance;
• Functional Cookies: These cookies allow the platform to remember choices you make (such as your preferred language or display settings) and provide enhanced, personalized features.

7.3 lakiwon does not use third-party advertising cookies or behavioral profiling cookies for cross-site advertising purposes.

7.4 You may control cookie settings through your browser's privacy settings. Please note that disabling strictly necessary cookies may affect the functionality of the platform.

8.1 lakiwon implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• SSL/TLS encryption for all data transmitted between your device and the lakiwon platform;
• Encryption of sensitive stored data, including passwords and payment references;
• Two-factor authentication (2FA) options for member accounts;
• Regular security audits and vulnerability assessments;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Staff training on data protection and security best practices.

8.2 While lakiwon takes every reasonable precaution to protect your personal data, no method of electronic transmission or storage is 100% secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant authorities in accordance with applicable legal requirements.

9.1 The lakiwon platform is strictly intended for persons who are 21 years of age or older, consistent with the minimum age for participation in online gambling under PAGCOR-applicable regulations in the Philippines. We do not knowingly collect personal data from any person under the age of 21.

9.2 If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe that a minor has provided personal data to lakiwon, please contact us immediately using the contact details in Section 13 of this Policy.

9.3 We recommend that parents and guardians use parental control software to restrict minors' access to online gambling platforms, including lakiwon.

10.1 In the course of delivering our services — particularly through third-party game providers and technical infrastructure partners — your personal data may be transferred to and processed in jurisdictions outside the Philippines. When such transfers occur, lakiwon ensures that adequate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012.

10.2 Safeguards for cross-border transfers may include contractual clauses that impose data protection obligations on the recipient, or reliance on the recipient jurisdiction's data protection adequacy determination where applicable.

10.3 By using the lakiwon platform and consenting to this Privacy Policy, you acknowledge and agree to the potential transfer of your personal data as described in this section.

11.1 As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by lakiwon:

• Right to Be Informed — to be notified of the nature and purpose of data collection;
• Right to Access — to obtain a copy of the personal data we hold about you;
• Right to Rectification — to have inaccurate or incomplete data corrected;
• Right to Erasure or Blocking — to request deletion of data that is no longer necessary or was unlawfully processed, subject to legal retention requirements;
• Right to Object — to object to processing based on legitimate interests or for direct marketing;
• Right to Data Portability — to receive your data in a structured, commonly used format where technically feasible;
• Right to Damages — to be indemnified for damages sustained due to inaccurate, incomplete, or unlawfully obtained or used personal data;
• Right to File a Complaint — to lodge a complaint with the National Privacy Commission of the Philippines.

11.2 To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 13. We will respond to your request within 15 business days of receipt. In complex cases, this period may be extended by a further 15 business days, and you will be notified accordingly.

11.3 We may request proof of identity before processing any data rights request to ensure that we do not disclose or alter data in response to a fraudulent request.

12.1 lakiwon reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will notify registered members via the email address on file or through a prominent notice on the platform, at least seven (7) days before the changes take effect.

12.2 The updated Policy will be published on this page with a revised effective date. We encourage you to review this Policy periodically to stay informed of how we are protecting your information. Your continued use of the platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

13.1 lakiwon has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Policy or the handling of your personal data, please contact our DPO.

13.2 Our support and DPO contact details are displayed in the footer of this page. All data-related inquiries submitted via our support channels are routed directly to the DPO for handling. Please include "Data Privacy Request" in the subject line of your communication for faster processing.

13.3 If you are dissatisfied with our response to any privacy concern or data rights request, you have the right to escalate your complaint directly to the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC can be found on the NPC's official website.