locky88 Privacy Policy

This Privacy Policy ("Policy") is issued by locky88 ("locky88," "we," "us," or "our") and applies to all personal data collected through the locky88 website at locky88.org, its subdomains, mobile applications, and any related services (collectively, the "Platform"). This Policy forms part of the locky88 Terms & Conditions and should be read alongside them.

locky88 is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. We process personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

By registering an account on the locky88 Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the Platform.

locky88 collects the following categories of personal data from players:

locky88 does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by law (for example, information about a gambling addiction disclosed in the context of a self-exclusion request, which is treated with the highest level of confidentiality).

locky88 collects personal data through the following means:

• Direct Interactions: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting our support team, or participating in a promotion.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. Please see Section 7 for more information on our use of cookies.
• Third-Party Sources: Identity and fraud-check data received from our KYC verification partners, payment processors (such as GCash and PayMaya), and fraud prevention service providers. locky88 only receives data from third parties where it has a lawful basis to do so.

locky88 uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your locky88 account, including verifying your identity and age.
• Service Delivery: To process your deposits and withdrawals, provide access to games, and deliver the full range of locky88 Platform services.
• Legal and Regulatory Compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) requirements, KYC obligations, and any directives from relevant regulatory authorities.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, unauthorised account access, and other illegal activities on the Platform.
• Responsible Gaming: To monitor player behaviour for signs of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion requests.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonus notifications, and news about locky88, where you have consented to receive such communications. You may opt out at any time by contacting our support team.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the locky88 Platform.

Under the Data Privacy Act of 2012, locky88 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you, including account registration, game access, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including AML, KYC, and tax reporting obligations.
• Legitimate Interests: Processing carried out for locky88's legitimate business interests, such as fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

locky88 does not sell, rent, or trade your personal data to third parties. We may share your 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 Visa, for the purpose of processing your deposits and withdrawals.
• KYC and Identity Verification Providers: Third-party services that assist locky88 in verifying your identity and age in compliance with our regulatory obligations.
• Fraud Prevention and Security Partners: Service providers that help locky88 detect and prevent fraudulent activity on the Platform.
• IT and Cloud Infrastructure Providers: Companies that provide the technical infrastructure on which the locky88 Platform operates, subject to strict confidentiality and data security obligations.
• Regulatory and Law Enforcement Authorities: Where required by law, court order, or regulatory directive, locky88 may disclose your personal data to the relevant Philippine authorities, including the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and law enforcement agencies.

All third-party service providers engaged by locky88 are contractually required to process your personal data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable data protection laws.

The locky88 Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and collect analytical data. Cookies are small text files stored on your device when you visit the Platform.

• Essential Cookies: Required for the Platform to function correctly, including maintaining your login session and remembering your language preferences. These cannot be disabled.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Platform, helping locky88 identify areas for improvement.
• Functional Cookies: Used to remember your preferences and personalise your experience on the Platform.
• Marketing Cookies: Used to deliver relevant promotional content to you, where you have consented to receive marketing communications from locky88.

You can control or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

locky88 retains your personal data only 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 and Identity Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in accordance with AML and KYC regulatory requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• Customer Support Communications: Retained for three (3) years from the date of the last interaction, for dispute resolution and quality assurance purposes.
• Technical and Usage Data: Retained for up to twelve (12) months, after which it is anonymised or deleted.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year after withdrawal of consent, as evidence of compliance.

When personal data is no longer required, locky88 will securely delete or anonymise it in accordance with industry best practices.

locky88 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the locky88 Platform.
• Two-factor authentication (2FA) available for all player accounts.
• Encrypted storage of sensitive data, including financial information and government ID details.
• Regular penetration testing and security audits conducted by independent third-party specialists.
• Strict access controls ensuring that only authorised locky88 personnel can access personal data, on a need-to-know basis.
• Real-time fraud monitoring and anomaly detection systems.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by locky88. To exercise any of these rights, please contact our Data Protection Officer at [email protected].

• Right to be Informed: The right to be told how your personal data is being collected and processed, as set out in this Policy.
• Right of Access: The right to request a copy of the personal data locky88 holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose 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.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

locky88 will respond to all data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with prior notice to you.

The locky88 Platform is strictly intended for individuals aged 21 years and older. locky88 does not knowingly collect personal data from anyone under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the locky88 Platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

locky88 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. When material changes are made, we will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy will always reflect the most recent revision. We encourage you to review this Policy periodically to stay informed about how locky88 protects your personal data. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way locky88 handles your personal data, please contact our Data Protection Officer. We are committed to addressing all privacy-related enquiries promptly and transparently.