luubet Privacy Policy

1Introduction

luubet ("we," "us," or "our") operates the online gaming platform accessible at luubet.one (the "Platform"). We take the privacy and security of your personal data seriously. This Privacy Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy describes how luubet collects, uses, stores, shares, and protects personal data relating to registered account holders, visitors to luubet.one, and any other individuals whose personal data luubet processes in connection with the operation of the Platform ("Data Subjects," "you," or "your").

Please read this Privacy Policy carefully alongside our Terms & Conditions and Responsible Gaming Policy, which together govern your use of the luubet Platform.

2Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, luubet is the Personal Information Controller in respect of the personal data collected and processed through the luubet Platform. This means luubet determines the purposes and means of processing your personal data.

If you have any questions, concerns, or requests relating to the processing of your personal data by luubet, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Privacy Policy.

3Personal Data We Collect

luubet collects the following categories of personal data in connection with the operation of the Platform:

luubet does not intentionally collect sensitive personal information as defined under RA 10173 (such as health data, religious beliefs, or political affiliations) unless specifically required for responsible gaming purposes (e.g., self-exclusion requests supported by medical documentation) and only with your explicit consent.

4How We Collect Your Data

luubet collects personal data through the following means:

• Direct Collection: Information you provide when registering a luubet account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access and use the luubet Platform, including through cookies, web beacons, and server logs. See Section 10 for more information on cookies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment transaction data from GCash, Maya, and banking partners.
• Publicly Available Sources: In limited circumstances, luubet may verify information against publicly available Philippine government databases for identity verification or fraud prevention purposes.

5How We Use Your Personal Data

luubet uses the personal data we collect for the following purposes:

• Account Management: Creating and maintaining your luubet account, verifying your identity and age (21+), processing KYC documentation, and managing account security.
• Service Delivery: Processing deposits and withdrawals, crediting winnings, applying bonuses, and providing access to games and Platform features.
• Legal and Regulatory Compliance: Fulfilling obligations under Philippine gaming regulations, anti-money laundering (AML) laws, and the Data Privacy Act of 2012, including reporting to PAGCOR and other relevant authorities where required.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, multi-accounting, and other prohibited conduct.
• Responsible Gaming: Monitoring gaming behavior to identify potential problem gambling indicators, enforcing deposit limits and self-exclusion requests, and delivering session time alerts.
• Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance through our 24/7 support team.
• Platform Improvement: Analyzing usage patterns to improve the luubet Platform's performance, features, and user experience for Filipino players.
• Marketing Communications: Sending you promotional offers, bonus notifications, and Platform updates via SMS or email, where you have consented to receive such communications. You may opt out at any time.

luubet will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6Legal Basis for Processing

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

• Contractual Necessity: Processing required to perform our contract with you (the luubet Terms & Conditions), including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including gaming regulations, AML obligations, and tax reporting requirements.
• Legitimate Interests: Processing necessary for luubet's legitimate business interests, including fraud prevention, Platform security, and responsible gaming monitoring, where such interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications and certain sensitive data processing. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7Data Sharing and Disclosure

luubet does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, Maya, and banking partners, for the purpose of processing deposits and withdrawals. These providers process your financial data under their own privacy policies and applicable Philippine financial regulations.
• KYC and Identity Verification Providers: Third-party service providers engaged to assist with identity verification, age verification, and document authentication.
• AML and Fraud Screening Providers: Compliance service providers engaged to assist with anti-money laundering screening and fraud detection.
• Game Content Providers: Game studios and live dealer platform providers whose games are available on luubet. These providers may receive limited technical data (such as session identifiers) necessary to deliver game content.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or regulatory directive.
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by luubet, subject to professional confidentiality obligations.

All third-party service providers engaged by luubet are required to process personal data only in accordance with luubet's instructions and applicable data protection laws. luubet does not transfer personal data outside the Philippines except where necessary and subject to appropriate safeguards in accordance with RA 10173.

8Data Retention

luubet retains personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account Data: Retained for the duration of your luubet account and for a minimum of five (5) years following account closure, in accordance with applicable Philippine gaming and AML regulations.
• Transaction and Gaming Records: Retained for a minimum of five (5) years from the date of each transaction or gaming session, as required by PAGCOR regulations and AML obligations.
• KYC Documentation: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Support Communications: Retained for a minimum of two (2) years from the date of the communication, or longer if the communication relates to an ongoing dispute or legal matter.
• Marketing Consent Records: Retained for the duration of your consent and for a reasonable period thereafter to demonstrate compliance.

When personal data is no longer required for any lawful purpose, luubet will securely delete or anonymize it in accordance with our data disposal procedures.

9Data Security

luubet implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data transmitted between your device and the luubet Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized luubet personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular data privacy training.
• Two-Factor Authentication: SMS OTP-based two-factor authentication is available for all luubet accounts and is strongly recommended to protect against unauthorized account access.
• Fraud Detection Systems: Automated systems monitor account activity for suspicious patterns, unauthorized access attempts, and other security threats on a continuous basis.
• Regular Security Audits: luubet conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in the Platform.
• Incident Response: luubet maintains a data breach response procedure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, luubet will notify the National Privacy Commission and affected Data Subjects in accordance with RA 10173 and NPC regulations.

While luubet takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your luubet account credentials and for notifying us immediately if you suspect unauthorized access to your account.

10Cookies and Tracking Technologies

luubet uses cookies and similar tracking technologies on the luubet Platform to enhance your experience, maintain session security, and analyze Platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the luubet Platform, including session management, authentication, and security functions. These cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences and settings, such as your preferred language and display options, to provide a more personalized experience.
• Analytics Cookies: Used to collect aggregated, anonymized data about how visitors use the luubet Platform, including pages visited, session duration, and navigation paths. This data helps luubet improve the Platform for Filipino players.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats, including bot detection and device fingerprinting for fraud prevention purposes.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the luubet Platform. Strictly necessary and security cookies cannot be disabled as they are essential to the secure operation of the Platform.

11Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data processed by luubet:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right to Access: The right to request a copy of the personal data luubet 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 luubet holds about you. You can update most account information directly through your luubet account settings.
• 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 luubet's legal and regulatory 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 luubet's legitimate interests. You may opt out of marketing communications at any time by contacting our support team.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe luubet has processed your personal data in violation of RA 10173.

To exercise any of the above rights, please contact luubet's Data Protection Officer using the contact details in Section 14. luubet will respond to all data privacy rights requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. We may need to verify your identity before processing your request.

12Children's Privacy and Age Restriction

The luubet Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. luubet does not knowingly collect personal data from individuals under the age of 21.

luubet employs age verification measures at the point of registration and on an ongoing basis to prevent underage access to the Platform. If luubet discovers that personal data has been collected from an individual under the age of 21, the associated account will be immediately closed and all personal data relating to that individual will be securely deleted, subject to any legal obligations to retain records of the underage access attempt.

If you are a parent or guardian and believe that your child under the age of 21 has registered a luubet account or provided personal data to luubet, please contact our support team immediately via live chat or at the email address provided in Section 14. We will take prompt action to close the account and delete the relevant data.

13Changes to This Privacy Policy

luubet reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine laws and regulations, or the features and services offered on the luubet Platform.

When material changes are made to this Privacy Policy, luubet will notify registered account holders via SMS to their registered Philippine mobile number and will update the "Effective Date" at the top of this page. The most current version of this Privacy Policy is always available at luubet.one/privacy-policy.

Your continued use of the luubet Platform after the effective date of any amendment to this Privacy Policy constitutes your acknowledgment of the updated policy. If you do not agree with the amended Privacy Policy, you must stop using the Platform and may request account closure in accordance with the luubet Terms & Conditions.

14Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or luubet's processing of your personal data, please contact our Data Protection Officer (DPO):

luubet is committed to resolving all data privacy concerns promptly and transparently. We aim to acknowledge all DPO inquiries within two (2) business days and to provide a substantive response within fifteen (15) business days.