Contents
- 1. Introduction
- 2. Data We Collect
- 3. How We Use Your Data
- 4. Legal Basis
- 5. Cookies & Tracking
- 6. Data Sharing
- 7. International Transfers
- 8. Data Retention
- 9. Your Privacy Rights
- 10. Children's Privacy
- 11. Security Measures
- 12. Third-Party Links
- 13. Marketing Communications
- 14. Policy Changes
- 15. Contact & DPO
1. Introduction
This Privacy Policy describes how LuxyPlay ("LuxyPlay," "we," "us," "our") collects, uses, discloses, stores, and protects personal information provided by users ("Player," "you," "your") of the LuxyPlay online betting and gaming platform at luxyplay.app.
LuxyPlay is committed to protecting the personal information of all Filipino players who use our platform. We comply with applicable data protection legislation, including the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its implementing rules and regulations issued by the National Privacy Commission (NPC).
By registering an account with LuxyPlay or by continuing to use the platform after this Policy has been updated, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal information as described herein. If you do not agree with any part of this Policy, please discontinue use of the LuxyPlay platform and contact us to close your account.
Plain language note: We know privacy policies can be heavy reading. The short version is this — LuxyPlay collects the personal data we need to run your account, process your payments, and keep the platform safe. We don't sell your data. We don't share it with advertisers. And you can ask us to update or delete it any time.
2. Personal Data We Collect
LuxyPlay collects personal data from you in two primary ways: information you provide directly during registration and account use, and information collected automatically when you access and interact with our platform.
2.1 Information You Provide Directly
- Registration data: Full legal name, date of birth, mobile number, email address, and preferred username.
- Identity verification (KYC) data: Government-issued ID (passport, National ID, driver's licence, SSS/UMID card), selfie or liveness check image, proof of address document (utility bill, bank statement, or government correspondence).
- Payment information: GCash account details, Maya account number, bank account details (BDO, BPI, UnionBank), Visa/Mastercard details, and transaction records. Note that LuxyPlay does not store full card numbers — these are handled by our certified payment processing partners.
- Communications: Content of any support messages, live chat transcripts, and email correspondence with LuxyPlay.
- Responsible gaming data: Deposit limits, loss limits, session reminders, and self-exclusion requests submitted through your account settings.
2.2 Information Collected Automatically
- Device and technical data: Device type, operating system, browser type and version, screen resolution, and device identifiers.
- Usage data: Pages visited on luxyplay.app, features accessed, betting and gaming activity logs, session duration, and clickstream data.
- Connection data: IP address, approximate geolocation derived from IP, ISP, and connection timestamps.
- Cookie and tracking data: Data from cookies and similar tracking technologies placed on your device when you access LuxyPlay. See Section 5 for full details.
| Data Category | Examples | Collection Method |
|---|---|---|
| Identity | Name, date of birth, National ID | Registration & KYC forms |
| Contact | Mobile number, email address | Registration form |
| Financial | GCash account, transaction history | Deposits & withdrawal requests |
| Technical | Device type, IP address, browser | Automatic — platform access |
| Behavioural | Betting history, game logs, session data | Automatic — platform usage |
| Communications | Support chats, email content | Direct player input |
3. How We Use Your Personal Data
LuxyPlay uses the personal data collected from Filipino players for the following specific purposes:
3.1 Account Management
To create and maintain your LuxyPlay account, verify your identity, authenticate logins, manage your account settings, and provide the core betting and gaming services that LuxyPlay offers. Without this data, we cannot operate your account.
3.2 Payment Processing
To process deposits and withdrawals through your chosen Philippine payment method — including GCash, Maya, bank transfers, and card payments. Financial data is shared with our certified payment processing partners solely for transaction execution. LuxyPlay retains transaction records for regulatory compliance and dispute resolution purposes.
3.3 Identity Verification and KYC Compliance
To verify your age (you must be 21 or older), confirm your identity, and comply with anti-money laundering (AML) obligations. KYC data is processed by LuxyPlay's licensed verification partners and is not used for any purpose beyond identity confirmation and regulatory compliance. KYC documents are stored securely and access is restricted to authorised personnel.
3.4 Fraud Prevention and Platform Security
To detect and prevent fraudulent activity, unauthorised account access, duplicate accounts, bonus abuse, and other activities that violate LuxyPlay's Terms and Conditions or applicable law. Behavioural and technical data is analysed by LuxyPlay's risk and security systems for this purpose.
3.5 Customer Support
To respond to your queries, complaints, and support requests submitted via live chat, email, or other LuxyPlay communication channels. Communication data is retained to maintain an accurate history of your interactions with our support team.
3.6 Regulatory Compliance
To comply with LuxyPlay's licensing obligations, reporting requirements to regulatory authorities, anti-money laundering obligations, and any other legal requirements applicable to LuxyPlay's operations in the Philippines and its licensing jurisdiction.
3.7 Platform Improvement
To analyse aggregated, anonymised usage data to understand how Filipino players use the LuxyPlay platform and to improve the product, fix technical issues, and develop new features. This analysis does not identify individual players.
3.8 Marketing Communications
To send you promotional offers, bonus notifications, and updates about new features on LuxyPlay — but only if you have consented to receive marketing communications. See Section 13 for full details and how to opt out.
4. Legal Basis for Processing
Under the Philippine Data Privacy Act of 2012, LuxyPlay processes your personal data on the following legal bases:
- Contractual necessity: Processing required to perform the contract between you and LuxyPlay — account management, betting, payments, and withdrawals.
- Legal obligation: Processing required to comply with LuxyPlay's regulatory and legal obligations — KYC, AML reporting, age verification, and licensing requirements.
- Legitimate interests: Processing for fraud prevention, platform security, and aggregated analytics — where these interests are not overridden by your privacy rights.
- Consent: Processing for marketing communications — only where you have explicitly opted in to receive them. Consent can be withdrawn at any time.
5. Cookies and Tracking Technologies
LuxyPlay uses cookies and similar tracking technologies when you access luxyplay.app. Cookies are small text files stored on your device that help us recognise you, maintain your session, and improve your experience on the platform.
5.1 Types of Cookies LuxyPlay Uses
- Strictly necessary cookies: Essential for the LuxyPlay platform to function — session management, login authentication, and security tokens. These cannot be disabled.
- Functional cookies: Remember your preferences such as language settings and responsible gaming limits you have set. Can be disabled but may affect platform functionality.
- Analytics cookies: Collect anonymised data about how you use luxyplay.app to help us understand usage patterns and improve the platform. Can be disabled without affecting core functionality.
LuxyPlay does not use third-party advertising cookies or share cookie data with ad networks. You can manage cookie preferences through your browser settings at any time. Note that disabling strictly necessary cookies will prevent you from logging into your LuxyPlay account.
No advertising cookies: LuxyPlay does not use tracking cookies to build advertising profiles or share your data with advertising networks. The cookies we use are limited to what's needed to run your account and improve the platform itself.
6. How We Share Your Personal Data
LuxyPlay does not sell personal data. We do not share your information with advertisers, data brokers, or marketing partners. Data sharing is limited to the following categories of recipients, each engaged under strict contractual data protection obligations:
6.1 Payment Processing Partners
GCash, Maya, BDO, BPI, UnionBank, and card payment processors receive the minimum data required to execute your transactions — typically your account identifier and transaction amount. These partners operate under their own privacy policies and applicable Philippine financial regulations.
6.2 Identity Verification (KYC) Providers
LuxyPlay works with licensed KYC and identity verification service providers to verify player ages and identities. Your submitted documents are processed by these partners and the results communicated to LuxyPlay. KYC providers are contractually prohibited from using your data for any purpose other than identity verification for LuxyPlay's account.
6.3 Regulatory Authorities
LuxyPlay may be required to disclose certain player data to regulatory authorities, law enforcement agencies, or the National Privacy Commission in response to a lawful request, court order, or as required under LuxyPlay's licensing obligations. We will notify affected players of such disclosures where legally permitted to do so.
6.4 Platform Technology Providers
Hosting, cloud infrastructure, and cybersecurity providers who support the technical operation of LuxyPlay may have access to data stored on our systems as part of their service delivery. All such providers are engaged under data processing agreements that restrict their use of your data to the specified service purpose only.
6.5 Game Providers
Third-party game developers and live casino studio providers — including JILI Games and live casino partners — receive session tokens and anonymised player identifiers required to run games and resolve dispute reviews. Full personal identity data is not shared with game providers.
7. International Data Transfers
Some of LuxyPlay's technology and service partners operate outside the Philippines. Where personal data is transferred to recipients in other countries, LuxyPlay ensures that appropriate safeguards are in place — including contractual data transfer clauses requiring the recipient to maintain standards of protection consistent with the Philippine Data Privacy Act.
LuxyPlay does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without ensuring equivalent contractual protections are in place. If you have questions about international transfers of your data, you can contact LuxyPlay's Data Protection Officer at the address provided in Section 15.
8. Data Retention
LuxyPlay retains your personal data for as long as your account is active and for a period following account closure as required by our legal and regulatory obligations. Specific retention periods are as follows:
| Data Type | Retention Period | Reason |
|---|---|---|
| Account registration data | Duration of account + 5 years post-closure | Regulatory & AML compliance |
| KYC documents | Duration of account + 5 years post-closure | AML and licensing obligations |
| Transaction records | Duration of account + 5 years post-closure | Financial regulation & dispute resolution |
| Betting and game logs | Duration of account + 3 years post-closure | Dispute resolution & regulatory audit |
| Support communications | 3 years from last interaction | Dispute resolution & quality review |
| Marketing consent records | Until consent withdrawn + 1 year | Consent management compliance |
| Analytics data (anonymised) | Indefinite (anonymised — no personal data) | Platform improvement |
After the applicable retention period, personal data is securely deleted or anonymised in accordance with LuxyPlay's data destruction procedures. Where data is anonymised rather than deleted, the anonymised data cannot be re-linked to you and is no longer considered personal data under applicable law.
9. Your Privacy Rights
Under the Philippine Data Privacy Act of 2012, Filipino players have the following rights with respect to their personal data held by LuxyPlay. You can exercise any of these rights by contacting us at support@luxyplay.app.
Right to Access
Request a copy of the personal data LuxyPlay holds about you, including what categories of data we have, how we use it, and who we've shared it with.
Right to Correction
Request correction of inaccurate or incomplete personal data in your LuxyPlay account. Some corrections may require supporting documentation.
Right to Erasure
Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected — subject to LuxyPlay's legal and regulatory retention obligations.
Right to Object
Object to processing of your personal data for direct marketing at any time. You can also object to processing based on LuxyPlay's legitimate interests in specific circumstances.
Right to Data Portability
Request a copy of personal data you have provided to LuxyPlay in a structured, machine-readable format, where technically feasible.
Right to Restrict Processing
Request restriction of processing in certain circumstances — for example, while a dispute about data accuracy is under review.
LuxyPlay will respond to privacy rights requests within 30 calendar days. In complex cases, this may be extended by a further 30 days with notification to you of the reason for extension. There is no charge for submitting a privacy rights request. LuxyPlay may need to verify your identity before processing your request.
If you believe LuxyPlay has not handled your personal data appropriately, you have the right to lodge a complaint with the Philippine National Privacy Commission at privacy.gov.ph.
10. Children's Privacy
LuxyPlay is strictly restricted to persons aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. Age verification is conducted during registration and prior to withdrawal processing as part of LuxyPlay's standard KYC procedures.
If LuxyPlay becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, all betting activity voided, and the data deleted in accordance with applicable law. Any deposited funds belonging to an underage account will be returned to the originating payment method following identity verification of the payment account holder.
Parents and guardians: If you believe a minor has registered or is using a LuxyPlay account, please contact us immediately at support@luxyplay.app. We take underage gambling seriously and will act on all credible reports promptly.
11. Security Measures
LuxyPlay implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure:
- 256-bit SSL/TLS encryption for all data in transit between your device and LuxyPlay's servers.
- Encryption at rest for sensitive personal data including KYC documents and financial information stored in LuxyPlay's systems.
- Access controls: Personal data is accessible only to LuxyPlay personnel with a specific operational need. Access is logged and audited.
- Multi-factor authentication on internal systems that contain player personal data.
- Regular penetration testing and security audits by qualified independent security professionals.
- Incident response procedures: LuxyPlay maintains documented procedures for identifying, containing, and reporting data security incidents, including notification to affected players and the National Privacy Commission within required timeframes in the event of a notifiable data breach.
While LuxyPlay takes all reasonable steps to protect your data, no system is completely impenetrable. You also play a role in keeping your account secure — use a strong, unique password for your LuxyPlay account and do not share it with anyone. Contact support immediately if you suspect unauthorised access to your account.
12. Third-Party Links
LuxyPlay's platform may from time to time include links to third-party websites or services — for example, links to game providers' information pages or payment processors' help sections. These third-party sites operate independently of LuxyPlay and have their own privacy policies. LuxyPlay has no control over and accepts no responsibility for the content or privacy practices of any third-party site.
We recommend reviewing the privacy policy of any third-party site before submitting personal information on that site. LuxyPlay's Privacy Policy applies only to data collected on the luxyplay.app platform itself.
13. Marketing Communications
LuxyPlay may send promotional emails, SMS messages, or in-app notifications about bonuses, new features, and special events on LuxyPlay — but only to players who have opted in to receive marketing communications during registration or through their account settings.
You can withdraw your marketing consent and unsubscribe from LuxyPlay communications at any time by:
- Clicking the unsubscribe link included in any LuxyPlay marketing email;
- Updating your communication preferences in your LuxyPlay account settings; or
- Contacting LuxyPlay support at support@luxyplay.app to request removal from all marketing lists.
Withdrawing marketing consent does not affect the sending of transactional communications — you will still receive account-related notifications such as deposit confirmations, withdrawal updates, and security alerts, as these are essential to managing your LuxyPlay account.
14. Changes to This Privacy Policy
LuxyPlay reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, new regulatory requirements, or platform developments. When we make material changes, we will notify registered players by email or through a prominent notice on the LuxyPlay platform at least seven days before the changes take effect.
The most current version of this Privacy Policy is always available at luxyplay.app/privacy-policy with the effective date clearly displayed at the top of the page. Continued use of LuxyPlay after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, please contact us to close your account before the revised policy takes effect.
15. Contact Us and Data Protection Officer
For any question, request, or concern related to this Privacy Policy or the handling of your personal data by LuxyPlay, please contact us through the following channels:
- Email: support@luxyplay.app
- Live Chat: Available 24/7 from your logged-in LuxyPlay account
- Language: Filipino (Tagalog) and English both welcome
LuxyPlay has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection law. Privacy-specific inquiries, rights requests, and data breach reports can be directed to the DPO via the email address above with the subject line "Privacy Request – [Your Name]".
If you are not satisfied with LuxyPlay's response to a privacy concern, you have the right to escalate your complaint to the Philippine National Privacy Commission at privacy.gov.ph.
Thank you for trusting LuxyPlay with your personal information. We take our responsibility to protect it seriously. If anything in this policy is unclear or you'd like it explained in plain Tagalog or English, our support team is always happy to help.