lakiwim Privacy Policy

1 Who We Are

1.1 lakiwim is a Philippines-based online gaming platform operating at lakiwim.net. For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, lakiwim acts as the personal information controller (PIC) in respect of the personal data it collects from players and visitors.

1.2 lakiwim operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and is required to maintain records of personal data processing activities in accordance with applicable Philippine law.

1.3 Our designated Data Protection Officer (DPO) is responsible for overseeing compliance with data privacy obligations. Contact details for our DPO are provided in Section 14 of this Policy.

2 Personal Data We Collect

2.1 lakiwim collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include:

2.2 Identity & Contact Information

• Full legal name (as it appears on your government-issued ID);
• Date of birth (to verify you meet the 21+ age requirement);
• Residential address in the Philippines;
• Mobile number and email address;
• Government-issued ID details (e.g., Philippine passport number, driver's license number, PhilSys National ID, SSS/GSIS ID, or Voter's ID).

2.3 Financial Information

• Payment method details (e.g., GCash-registered mobile number, PayMaya account reference, bank account name and partial number for BPI, BDO, Metrobank, or UnionBank);
• Transaction history including deposits, withdrawals, and bonus redemptions;
• Account wallet balance and gaming activity records.

2.4 Technical & Usage Data

• IP address and approximate geographic location;
• Device type, operating system, and browser information;
• Session duration, pages visited, and navigation patterns on lakiwim.net;
• Game play logs including stakes, outcomes, and session timestamps.

2.5 Communications Data

• Records of your interactions with our customer support team via live chat, email, or Messenger/Viber;
• Feedback, survey responses, and complaint records.

3 How We Collect Your Data

3.1 lakiwim collects your personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions;
• Automatically — through cookies, web beacons, and similar tracking technologies when you browse lakiwim.net (see Section 6 for full details);
• From payment providers — transaction confirmation and account ownership data from GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank to verify payment method ownership and process transactions;
• From identity verification services — where third-party KYC or anti-fraud services are used to verify the authenticity of documents submitted;
• From regulatory bodies — information shared by PAGCOR or other Philippine authorities in connection with regulatory compliance, responsible gaming enforcement, or dispute resolution.

4 Purpose & Legal Basis for Processing

4.1 lakiwim processes your personal data only where a valid lawful basis exists under the Data Privacy Act of 2012. The table below summarises our processing activities, the purposes, and the applicable legal bases:

4.2 Where processing is based on your consent (e.g., marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent, contact our support team or use the unsubscribe link in any marketing email.

5 Data Sharing & Disclosure

5.1 lakiwim does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following circumstances and with the following categories of recipients:

5.2 Service Providers & Processors

We engage third-party companies to provide services on our behalf, including game software providers (e.g., Pragmatic Play, Evolution Gaming), payment processors (GCash, PayMaya, banking partners), KYC and identity verification services, fraud detection technology providers, IT infrastructure and cloud hosting providers, and customer support platform operators. These parties act as personal information processors (PIPs) under RA 10173 and are bound by data processing agreements that require them to handle your data only as instructed by lakiwim and to maintain appropriate security measures.

5.3 Regulatory & Legal Disclosures

lakiwim may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts when required to do so by Philippine law, court order, or lawful regulatory demand. In such cases, disclosure is limited to what is strictly required by the applicable legal obligation.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of lakiwim's business assets, personal data held by lakiwim may be transferred to the acquiring entity. You will be notified in advance of any such transfer and of any changes to how your data will be processed.

6 Cookies & Tracking Technologies

6.1 lakiwim uses cookies and similar technologies (web beacons, pixel tags, local storage) to operate the platform, remember your preferences, maintain your session security, and analyse platform usage.

6.2 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the platform to function. These cannot be disabled and do not require your consent. They include session authentication tokens and security cookies.
• Functional Cookies: Remember your preferences such as language, lobby layout, and game history. These improve your experience but are not essential.
• Analytics Cookies: Help us understand how players use lakiwim — which games are most popular, where users encounter issues, and how to improve the platform. Data is aggregated and anonymised.
• Marketing Cookies: Used to deliver relevant promotions and measure the effectiveness of our marketing campaigns. These are only set with your explicit consent.

6.3 You can manage non-essential cookie preferences through the cookie settings panel available on the lakiwim platform. Disabling certain cookies may limit some platform functionality.

6.4 lakiwim does not use third-party advertising networks that track you across other websites without your knowledge.

7 Data Retention

7.1 lakiwim retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account plus five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act;
• Transaction records: Retained for a minimum of five (5) years following each transaction, as required under the AMLA and its implementing rules;
• Customer support communications: Retained for two (2) years from the date of the interaction;
• Marketing consent records: Retained for as long as you remain opted in, plus one (1) year after withdrawal of consent;
• Technical and usage logs: Retained for twelve (12) months on a rolling basis.

7.2 When personal data is no longer required and the applicable retention period has expired, lakiwim will securely delete or anonymise it in accordance with our data disposal procedures.

8 Data Security

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

• TLS/SSL encryption for all data in transit between your device and our servers;
• AES-256 encryption for sensitive data stored at rest, including KYC documents and payment references;
• Role-based access controls limiting data access to authorised personnel only;
• Multi-factor authentication (MFA) for all internal system access;
• Regular security audits, vulnerability assessments, and penetration testing;
• 24/7 system monitoring and intrusion detection;
• Staff training on data privacy and information security obligations.

8.2 In the event of a personal data breach that is likely to result in harm to affected players, lakiwim will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with NPC Circular 16-03.

9 Your Rights as a Data Subject

9.1 Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by lakiwim:

9.2 To exercise any of the above rights, contact our Data Protection Officer at the details provided in Section 14. We may need to verify your identity before processing your request.

10 Minors & Age Restriction

10.1 lakiwim is strictly prohibited to persons under the age of 21 years, as required under PAGCOR regulations. We do not knowingly collect personal data from persons below this age threshold.

10.2 If we discover that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the collected data, and — where applicable — refer the matter to the appropriate Philippine authorities.

10.3 Parents and guardians who believe that a minor has registered on lakiwim should contact our support team immediately. We will act on any such report without delay.

11 Marketing Communications

11.1 lakiwim may send you promotional emails, SMS notifications, and in-platform messages about bonuses, new games, platform updates, and special events, but only where you have provided explicit opt-in consent to receive such communications.

11.2 You may withdraw your marketing consent at any time by:

• Clicking the unsubscribe link in any marketing email you receive from lakiwim;
• Updating your communication preferences in your account settings;
• Contacting our support team directly and requesting opt-out.

11.3 Withdrawing marketing consent does not affect transactional communications. We will continue to send you account-related messages such as deposit confirmations, withdrawal notifications, KYC requests, and security alerts, as these are necessary for the operation of your account.

11.4 lakiwim does not engage in unsolicited cold marketing to non-registered individuals. All marketing communications are directed only to consenting registered players.

12 Cross-Border Data Transfers

12.1 Some of lakiwim's third-party service providers — particularly game software suppliers and cloud infrastructure providers — may be located outside the Philippines. Where personal data is transferred to a recipient in a foreign country, lakiwim ensures that adequate safeguards are in place in accordance with NPC guidelines on cross-border data transfers.

12.2 Safeguards applied to cross-border transfers include standard contractual clauses approved by the NPC, binding corporate rules where applicable, and transfers only to countries or organisations that the NPC has determined provide an adequate level of data protection.

12.3 Notwithstanding any cross-border transfer, lakiwim remains the personal information controller responsible for your data, and our obligations under RA 10173 continue to apply regardless of where processing takes place.

13 Changes to This Privacy Policy

13.1 lakiwim may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory guidance from the National Privacy Commission or PAGCOR.

13.2 Where changes are material — meaning they significantly affect how we collect or use your personal data, or your rights as a data subject — lakiwim will notify you by email to your registered address at least fourteen (14) days before the changes take effect.

13.3 Non-material changes (such as typographical corrections or clarifications that do not affect your rights) may be made without advance notice.

13.4 The "Effective Date" at the top of this Policy indicates when the current version came into force. The most current version of this Policy is always available at lakiwim.net/privacy-policy. We encourage you to review this Policy periodically.

13.5 Continued use of the lakiwim platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with the updated Policy, you must cease using lakiwim and may request account closure.

14 Contact Us & Data Protection Officer

14.1 If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how lakiwim processes your personal data, please contact us through any of the following channels:

14.2 We will acknowledge your request within three (3) business days and aim to resolve all data privacy queries within thirty (30) days, consistent with NPC guidelines.

14.3 If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.