Privacy Policy

1 Introduction and Scope

This Privacy Policy governs the collection, processing, storage, and disclosure of personal information by luubet.cam ("luubet," "we," "us," or "our"), a PAGCOR-licensed online casino and sports betting platform operating in the Philippines. This policy applies to all users ("you," "User," or "Player") who access or use our website, mobile applications, and related services (collectively, the "Platform").

luubet acts as the Data Controller for all personal information collected through the Platform. We are committed to transparency in our data handling practices and to providing you with meaningful control over your personal information. This policy should be read in conjunction with our Terms and Conditions, which govern your use of luubet services.

By creating an account, accessing the Platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with this policy, you must immediately discontinue use of the Platform and refrain from creating an account.

2 Information We Collect

luubet collects several categories of personal information necessary to provide, secure, and improve our services. We collect information directly from you during account registration, through your use of the Platform, and from certain third-party sources as described below.

2.1 Information You Provide Directly

When you register an account with luubet, you provide the following personal information:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (for verification purposes).
• Contact Information: Email address, mobile phone number (including verification via SMS), and residential address.
• Account Credentials: Username, password, and security questions/answers for account access and recovery.
• Financial Information: Payment method details including GCash number, PayMaya account, bank account numbers (BPI, BDO, UnionBank, etc.), cryptocurrency wallet addresses, and transaction history.
• Verification Documents: Copies of government-issued IDs (Philippine ID, passport, driver's license), proof of address (utility bills, bank statements), and proof of payment method ownership submitted during Know Your Customer (KYC) verification.
• Communication Records: Content of your communications with customer support via live chat, email, or phone, including timestamps and conversation history.

2.2 Information Collected Automatically

When you access or use the luubet Platform, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, screen resolution, and device identifiers.
• Connection Data: IP address, internet service provider, geographic location (city/region level), and timezone.
• Usage Data: Pages visited, games played, bets placed, betting patterns, time spent on platform, features accessed, and navigation paths.
• Cookie Data: Information stored in cookies and similar tracking technologies including session IDs, preferences, and authentication tokens.
• Gaming Activity: Detailed records of all bets, game rounds, wins, losses, deposits, withdrawals, and account balance changes with timestamps.
• Security Logs: Login attempts (successful and failed), IP addresses used for login, device fingerprints, and security event logs.

2.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment Processors: Transaction confirmation, payment status, and fraud prevention data from GCash, PayMaya, bank partners, and cryptocurrency networks.
• Identity Verification Services: Age verification, identity authentication, and anti-fraud screening results from third-party verification providers.
• Responsible Gaming Organizations: Self-exclusion status if you have registered with third-party exclusion programs linked to PAGCOR systems.
• Publicly Available Sources: Information from public databases to verify identity and comply with anti-money laundering regulations.

3 Data Sharing and Disclosure

luubet does not sell, rent, or trade your personal information to third parties for marketing purposes. We share your information only in the following limited circumstances, and only with parties bound by confidentiality obligations:

3.1 Service Providers

We share necessary information with trusted third-party service providers who perform services on our behalf, including:

• Payment Processors: GCash, PayMaya, bank partners, cryptocurrency payment gateways, and other financial institutions to process deposits and withdrawals.
• Game Providers: Software suppliers who host games on our platform and require limited player data to deliver gaming content.
• Identity Verification Services: KYC/AML compliance providers who verify your age, identity, and address.
• Cloud Hosting Providers: Secure data centers and cloud infrastructure providers who store our databases and host our platform.
• Customer Support Tools: Live chat platforms, ticketing systems, and communication tools used to provide customer service.
• Analytics Providers: Tools that help us understand platform usage, identify technical issues, and improve user experience (data is anonymized where possible).

All service providers are contractually required to protect your information, use it only for the specified purposes, and comply with applicable data protection laws.

3.2 Legal and Regulatory Authorities

We disclose personal information to government authorities, regulators, and law enforcement when required by law or to protect our legal rights:

• PAGCOR: Gaming activity reports, player verification data, and responsible gaming records as required by our licensing conditions.
• Bureau of Internal Revenue (BIR): Tax reporting for winnings above statutory thresholds as required by Philippine tax law.
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports and customer due diligence information when required by AML regulations.
• Law Enforcement: Information requested through valid legal process (court orders, subpoenas, search warrants) in criminal investigations.
• Dispute Resolution Bodies: Relevant records when required for arbitration, mediation, or legal proceedings involving player disputes.

3.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email and/or prominent notice on the Platform before your information is transferred and becomes subject to a different privacy policy.

3.4 With Your Consent

We may share your information for purposes not described in this policy when we have obtained your explicit consent to do so.

4 Data Security Measures

luubet implements comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS technology. Sensitive data at rest (passwords, financial information) is encrypted using industry-standard algorithms.
• Secure Infrastructure: Our servers are hosted in Tier III+ certified data centers with 24/7 physical security, redundant power supplies, and environmental controls.
• Access Controls: Role-based access controls limit employee access to personal information on a strict need-to-know basis. All access is logged and audited.
• Authentication: Multi-factor authentication (MFA) is available for player accounts and required for all employee access to production systems.
• Firewalls and Intrusion Detection: Network-level firewalls, web application firewalls (WAF), and intrusion detection/prevention systems (IDS/IPS) protect against unauthorized access and attacks.
• Regular Security Audits: Independent third-party security audits, penetration testing, and vulnerability assessments are conducted regularly.
• Employee Training: All employees receive data protection and security awareness training and are bound by confidentiality agreements.
• Incident Response: We maintain a documented incident response plan to quickly detect, contain, and remediate security breaches.

While we implement robust security measures, no system is completely secure. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify us of any unauthorized account access.

5 Data Retention

luubet retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Accounts: Personal information is retained for the duration of your account's active status and for 7 years after account closure to comply with PAGCOR record-keeping requirements and financial regulations.
• Gaming Records: All betting activity, game rounds, wins, losses, and transaction records are retained for 7 years from the date of the transaction as required by gaming regulations.
• Financial Records: Deposit and withdrawal records, payment method information, and financial transaction history are retained for 7 years to comply with anti-money laundering laws and tax regulations.
• KYC Documents: Identity verification documents (government IDs, proof of address) are retained for 7 years after account closure to comply with Know Your Customer and anti-money laundering regulations.
• Communication Records: Customer support conversations, emails, and chat logs are retained for 3 years for quality assurance and dispute resolution purposes.
• Marketing Data: Email addresses and marketing preferences for inactive accounts are retained for 2 years after last account activity, after which you are automatically unsubscribed unless you reactivate your account.
• Security Logs: Login records, IP addresses, and security event logs are retained for 1 year for fraud prevention and security monitoring.
• Self-Excluded Players: Records of players who have self-excluded are retained indefinitely to prevent account reopening and protect vulnerable individuals, as required by responsible gaming regulations.

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with data protection best practices. Anonymized data that cannot be used to identify you may be retained indefinitely for analytics and research purposes.

6 Cookies and Tracking Technologies

luubet uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you on subsequent visits.

Types of Cookies We Use:

• Essential Cookies: Required for the Platform to function properly, including session management, authentication, and security features. These cannot be disabled without affecting core functionality.
• Performance Cookies: Collect anonymous information about how you use the Platform, including pages visited, time spent, and errors encountered. This helps us improve performance and user experience.
• Functional Cookies: Remember your preferences (language, region, display settings) and provide enhanced features based on your usage patterns.
• Analytics Cookies: Help us understand user behavior through aggregated statistics. We use analytics tools to measure traffic, identify popular features, and optimize the Platform.
• Advertising Cookies: Track your activity across websites to deliver relevant promotional content and measure the effectiveness of marketing campaigns (only with your consent).

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Note that disabling certain cookies may limit your ability to use some features of the Platform. You can manage cookie preferences through your account settings or by adjusting your browser's privacy settings.

7 Third-Party Links and Services

The luubet Platform may contain links to third-party websites, services, or applications that are not owned or controlled by luubet. This Privacy Policy applies only to information collected by luubet. We are not responsible for the privacy practices of third-party sites or services.

When you use third-party payment methods (GCash, PayMaya, online banking), those transactions are subject to the privacy policies and terms of service of the respective payment providers. We encourage you to read the privacy policies of any third-party services you interact with.

Game content provided by third-party software suppliers may collect limited technical information (game session data, device type) to deliver gaming services. These providers are contractually required to comply with data protection standards equivalent to those described in this policy.

8 Children's Privacy

luubet services are strictly intended for individuals aged 21 years or older, as required by Philippine gaming regulations. We do not knowingly collect personal information from minors. Our registration process includes age verification measures to prevent underage access.

If we become aware that we have inadvertently collected personal information from an individual under 21 years of age, we will immediately delete that information from our systems and permanently close the associated account. No refunds will be issued for accounts found to be operated by minors.

Parents or guardians who believe their child has created an account on luubet should immediately contact our support team at [email protected]. We take underage gambling prevention seriously and cooperate fully with authorities on all such matters.

9 International Data Transfers

luubet primarily processes personal information within the Philippines. However, some of our service providers (cloud hosting, payment processors, game providers) may store or process data in facilities located outside the Philippines, including in the United States, European Union, and other jurisdictions.

When we transfer personal information internationally, we ensure that adequate safeguards are in place to protect your information, including:

• Standard contractual clauses approved by the National Privacy Commission
• Certifications demonstrating compliance with internationally recognized data protection standards
• Binding corporate rules for transfers within multinational service provider groups
• Verification that the receiving jurisdiction provides adequate data protection laws

All international data transfers are conducted in compliance with the Data Privacy Act of 2012 and applicable cross-border data transfer regulations.

10 Changes to This Privacy Policy

luubet reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. The "Last Updated" date at the top of this policy indicates when the most recent revisions were made.

We will notify you of material changes to this Privacy Policy through one or more of the following methods:

• Email notification to the address associated with your account
• Prominent notice on the Platform homepage and/or in your account dashboard
• In-app notification when you next log in after the policy change
• SMS notification for significant changes affecting your rights

Your continued use of luubet services after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with the revised policy, you must stop using the Platform and may close your account by contacting customer support.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information. Previous versions of this policy are archived and available upon request.