lgplay Privacy Policy

1. Who We Are

lgplay is a PAGCOR-regulated online gaming platform operating lgplay.bet, providing Filipino players with access to slots, bingo, live casino games, Tower, Monster Mine, sports betting, and related gaming entertainment. lgplay acts as the Personal Information Controller (PIC) with respect to the personal data of its registered account holders and website visitors, as that term is defined under the Philippine Data Privacy Act of 2012.

lgplay has appointed a Data Protection Officer (DPO) responsible for overseeing data privacy compliance, responding to data subject requests, and acting as the point of contact with the National Privacy Commission (NPC). You may contact our DPO directly at [email protected] with the subject line "Data Privacy — DPO Request".

lgplay operates under a PAGCOR gaming license and is subject to PAGCOR's compliance framework, which includes specific data governance obligations for licensed online gaming operators serving players in the Philippines.

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2. Personal Data We Collect

2.1 Registration and Identity Data

When you register an lgplay account, we collect the information necessary to create and verify your account identity. This includes your full legal name, date of birth, Philippine residential address, email address, and mobile phone number. This data is required to fulfil our contractual obligation to you and to satisfy our KYC obligations under PAGCOR regulations and the Philippine Anti-Money Laundering Act (AMLA).

2.2 Identity Verification (KYC) Documents

To verify your identity as required under PAGCOR licensing conditions and AMLA, lgplay collects copies of government-issued identification documents. Acceptable documents include a Philippine passport, SSS ID, UMID card, driver's license, voter's ID, or PhilSys National ID. In some cases, we may also request proof of address (such as a utility bill or bank statement) and source-of-funds documentation for high-value transactions.

2.3 Financial and Transaction Data

lgplay collects data relating to your deposits and withdrawals, including transaction amounts, dates, payment method identifiers (such as GCash mobile number, bank account details, or e-wallet reference numbers), and transaction history. lgplay does not store full credit card numbers or CVV codes on its servers. Payment processing for card transactions is handled by PCI-DSS compliant third-party payment processors.

2.4 Gaming Activity Data

lgplay records your gaming activity on the platform, including games played, wagers placed, outcomes, session durations, and bonus usage. This data is used to provide you with the gaming service, to meet PAGCOR audit and reporting requirements, to detect and prevent problem gambling behaviour, and to personalise your gaming experience where you have consented to such personalisation.

2.5 Technical and Device Data

When you access lgplay.bet, our systems automatically collect certain technical data about your device and connection. This includes your IP address, browser type and version, operating system, device identifiers, screen resolution, referring URL, pages visited on lgplay.bet, time and duration of visits, and error logs. This data is collected to maintain platform security, prevent fraud, detect multiple-account registrations, and improve platform performance.

2.6 Communications Data

When you contact lgplay's customer support team — whether by email, live chat, or other channels — we retain records of those communications, including the content of your messages and our responses. This data is kept to maintain service quality, resolve disputes, and for training purposes. Live chat and support call recordings (where applicable) may be retained for a period of up to two (2) years.

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3. How We Collect Your Data

lgplay collects your personal data through the following channels and methods:

• Direct registration: Data you provide when creating your lgplay account, completing KYC verification, or updating your account profile.
• Platform interactions: Data generated automatically as you navigate lgplay.bet, place wagers, access games, and use platform features.
• Payment transactions: Data received from payment processors (GCash, Maya, BPI, BDO, Metrobank, and others) when you initiate deposits or withdrawals.
• Customer support: Data you provide when you contact lgplay via email or live chat, including information shared in support conversations.
• Cookies and tracking technologies: Data collected automatically via cookies, web beacons, and similar technologies as described in Section 7 of this Policy.
• Third-party KYC providers: Identity verification data received from licensed KYC verification service providers engaged by lgplay to assist with document verification and identity checks.
• Regulatory sources: In limited circumstances, PAGCOR or law enforcement authorities may provide lgplay with information relevant to a compliance or AML investigation.

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4. Why We Use Your Personal Data

lgplay uses your personal data for the following specific purposes:

• Account creation and management: To register your lgplay account, verify your identity, and manage your ongoing account relationship with us.
• Service delivery: To provide you with access to lgplay's gaming products, process your deposits and withdrawals, and deliver the features you use on the platform.
• PAGCOR regulatory compliance: To fulfil our obligations as a PAGCOR-licensed operator, including player registration reporting, transaction reporting, and audit trail maintenance.
• AML and fraud prevention: To monitor transactions and gaming behaviour for signs of money laundering, terrorism financing, fraud, or bonus abuse, as required by AMLA and PAGCOR guidelines.
• Responsible gaming: To detect signs of problem gambling, enforce self-exclusion requests, apply deposit and session limits, and comply with PAGCOR's responsible gaming framework.
• Customer support: To handle your enquiries, resolve disputes, and maintain records of support interactions.
• Security and fraud prevention: To protect the integrity of the lgplay platform, detect multi-accounting, and prevent unauthorised access to player accounts.
• Legal compliance: To respond to lawful requests from courts, regulators, law enforcement authorities, and other government agencies in the Philippines.
• Marketing communications (with consent): To send you promotional offers, bonus notifications, and personalised game recommendations where you have provided separate, explicit consent to receive such communications. You may withdraw marketing consent at any time.
• Platform improvement: To analyse aggregated, anonymised usage data to improve the performance, usability, and content of lgplay.bet.

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5. Legal Basis for Processing

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

• Contractual necessity: Processing is necessary to perform our contract with you — specifically, to create and manage your account, deliver gaming services, and process financial transactions.
• Legal obligation: Processing is required to comply with applicable Philippine law, including PAGCOR licensing conditions, AMLA, and orders from competent regulatory and law enforcement authorities.
• Legitimate interests: Processing is necessary for lgplay's legitimate interests in maintaining platform security, preventing fraud, detecting problem gambling, and improving service quality — provided these interests are not overridden by your data protection rights.
• Consent: For specific processing activities such as direct marketing communications and certain cookie-based tracking, lgplay relies on your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

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6. Sharing Your Personal Data

6.1 Categories of Recipients

lgplay shares your personal data with third parties only where necessary and on a strictly limited basis. The categories of third parties with whom your data may be shared are as follows:

• PAGCOR: As our licensing and regulatory authority, PAGCOR may require lgplay to submit player data, transaction reports, and audit information. lgplay complies with all such regulatory data requests.
• Anti-Money Laundering Council (AMLC): lgplay is required to report covered transactions and suspicious transactions to the AMLC as mandated by the AMLA. Such reporting may include your identity and transaction data.
• KYC verification providers: Licensed identity verification service providers who assist lgplay in verifying the authenticity of KYC documents and confirming player identities.
• Payment processors: Philippine and international payment processors and financial institutions (including GCash, Maya, GrabPay, BPI, BDO, Metrobank, and InstaPay network participants) required to process your deposits and withdrawals.
• Technology and platform providers: Cloud hosting, cybersecurity, and platform technology vendors who process data on lgplay's behalf under binding data processing agreements that require them to maintain appropriate security standards.
• Law enforcement and courts: Where lgplay receives a lawful order, subpoena, or regulatory directive from a Philippine court, law enforcement agency, or government authority, we will disclose the required data in compliance with that order.

6.2 No Sale of Data

lgplay does not sell, rent, license, or otherwise commercially transfer your personal data to any third party for their own marketing, advertising, or commercial purposes. Any data sharing arrangement lgplay enters into is governed by a formal data sharing agreement or data processing agreement that binds the recipient to use the data only for the stated purpose and to maintain appropriate security measures.

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7. Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device by a website when you visit it. lgplay uses cookies and similar tracking technologies (such as web beacons and local storage objects) on lgplay.bet to operate the platform, maintain your session, remember your preferences, and analyse how players use the site.

7.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the operation of lgplay.bet. These include session management cookies that keep you logged in during your visit, security tokens, and cookies that enable core platform functions such as the game lobby and cashier. These cannot be disabled without impairing platform functionality.
• Performance and analytics cookies: Used to collect anonymised data about how players navigate lgplay.bet, which pages are visited most frequently, and where errors occur. This data helps lgplay improve the platform. These cookies do not identify you personally.
• Functional cookies: Used to remember your preferences such as your chosen language, preferred game category, or responsible gaming settings. Disabling these cookies may affect your user experience.
• Marketing cookies (with consent only): Used, where you have given explicit consent, to deliver personalised promotional content and track the effectiveness of lgplay's marketing campaigns. You may opt out of marketing cookies at any time through the cookie preference centre.

7.3 Managing Your Cookie Preferences

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies entirely, delete cookies that have already been set, or receive a notification before a cookie is placed. Note that disabling strictly necessary cookies will impair your ability to use lgplay.bet, including your ability to log in and play. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

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8. Data Retention

lgplay retains your personal data for the periods set out below, after which data is securely deleted or anonymised:

• Account and identity data: Retained for the duration of your active account relationship with lgplay and for a minimum of five (5) years following account closure, as required under AMLA record-keeping obligations and PAGCOR licensing conditions.
• KYC documents: Retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later, in compliance with AMLA requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by AMLA and PAGCOR.
• Gaming activity data: Retained for the duration of your active account and for five (5) years following account closure for PAGCOR audit purposes. Anonymised, aggregated gaming data may be retained indefinitely for statistical and platform improvement purposes.
• Customer support records: Retained for up to two (2) years from the date of the last interaction, unless the matter is subject to ongoing dispute resolution or legal proceedings.
• Marketing data (with consent): Retained until you withdraw your consent to marketing communications or for a maximum of three (3) years from the date of last engagement, whichever is earlier.
• Technical and device data: Retained for up to twelve (12) months from collection, unless required for longer retention as part of a security or fraud investigation.

Where lgplay is required by law, regulatory order, or ongoing legal proceedings to retain data beyond these standard retention periods, the data will be kept for the duration required and then securely deleted.

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9. Data Security

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

• Transport Layer Security (TLS 1.3): All data in transit between your device and lgplay.bet is encrypted using TLS 1.3 protocols. lgplay.bet is served exclusively over HTTPS.
• AES-256 encryption at rest: Sensitive personal data — including KYC documents, financial data, and identity information — is encrypted at rest using AES-256 standards on lgplay's cloud infrastructure.
• Access controls: Access to personal data within lgplay's systems is restricted on a strict need-to-know basis. All lgplay staff with access to personal data undergo mandatory data privacy training and are bound by confidentiality obligations.
• Two-factor authentication (2FA): lgplay's internal systems require two-factor authentication for all staff accessing player data. lgplay strongly recommends that players also enable 2FA on their lgplay accounts for additional account security.
• Intrusion detection and monitoring: lgplay's infrastructure is continuously monitored for security anomalies, unusual access patterns, and potential intrusion attempts. Security logs are reviewed by lgplay's security team on an ongoing basis.
• Penetration testing: lgplay conducts periodic independent penetration testing of its platform and infrastructure to identify and remediate security vulnerabilities before they can be exploited.
• Data minimisation: lgplay applies data minimisation principles and collects only the personal data that is strictly necessary for each stated purpose. Data that is no longer needed is securely deleted in accordance with our retention schedules.

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10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by lgplay. To exercise any of these rights, contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request". lgplay will respond to all verified requests within fifteen (15) business days of receipt.

• Right to be informed: You have the right to be informed of what personal data lgplay holds about you, the purposes for which it is processed, and how it is used. This Privacy Policy is the primary vehicle through which lgplay fulfils this right.
• Right of access: You have the right to request a copy of the personal data lgplay holds about you. lgplay will provide this in a structured, commonly used format. lgplay may charge a reasonable administrative fee for repeat or manifestly unfounded requests.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data lgplay holds about you. For basic account information (such as your email address or mobile number), corrections can also be made directly through your lgplay account profile.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent (and there is no other legal basis for processing), or where processing is unlawful. Note that lgplay may be required to retain certain data for the minimum periods prescribed by AMLA and PAGCOR regulations, which takes precedence over erasure requests during those mandatory retention periods.
• Right to data portability: You have the right to receive a copy of the personal data you have provided to lgplay in a structured, commonly used, and machine-readable format, and to transmit that data to another personal information controller where technically feasible.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on lgplay's legitimate interests, though lgplay may demonstrate compelling legitimate grounds to continue processing in certain circumstances.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe lgplay has violated your data privacy rights. Contact the NPC at its official channels as published on the NPC's website.

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11. Children's Privacy

lgplay's services are strictly restricted to individuals who are at least 21 years of age, in accordance with PAGCOR regulations and Philippine law on online gaming. lgplay does not knowingly collect personal data from individuals under the age of 21. All registration applicants are required to verify their date of birth and submit government-issued identification as part of the mandatory KYC process.

If lgplay becomes aware that it has inadvertently collected personal data from a person under 21 years of age, that account will be immediately closed, all personal data associated with the account will be deleted in accordance with our data retention procedures, and the matter will be handled in accordance with PAGCOR's guidelines on underage gaming.

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12. Cross-Border Data Transfers

lgplay's primary data processing infrastructure is located within the Philippines or in jurisdictions that provide an adequate level of data protection as recognised by the National Privacy Commission. Where it is necessary to transfer your personal data to a third party located outside the Philippines — for example, to an internationally hosted cloud infrastructure provider or a global KYC verification service — lgplay ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012.

Such safeguards include binding contractual clauses that require overseas recipients to maintain data protection standards equivalent to those required under Philippine law, and, where applicable, the use of NPC-approved standard contractual clauses or equivalent mechanisms. lgplay will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without first implementing appropriate compensating controls.

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13. Third-Party Links

lgplay.bet may contain links to third-party websites or services — for example, links to PAGCOR's official website or the National Privacy Commission's resources. This Privacy Policy applies solely to lgplay.bet and to lgplay's own data processing activities. lgplay is not responsible for the privacy practices or content of any third-party website. When you navigate away from lgplay.bet to a third-party site, you should read that site's own privacy policy to understand how your data is handled.

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14. Amendments to This Policy

lgplay may update this Privacy Policy from time to time to reflect changes in our data processing practices, updates to Philippine privacy law or PAGCOR regulations, or improvements to our platform. When we make a material change to this Policy — meaning a change that significantly affects your rights or how we use your data — we will notify you by email to your registered lgplay address and by posting a prominent notice on lgplay.bet at least fourteen (14) days before the change takes effect.

For minor or non-material changes (such as typographical corrections or clarifications that do not alter the substance of our data practices), the updated Policy will take effect upon publication on lgplay.bet. The "Last Updated" date at the top of this page will always reflect when the most recent revision was made. We encourage you to review this Policy periodically. Your continued use of lgplay.bet following any update to this Policy constitutes your acceptance of the updated terms.

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15. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or lgplay's handling of your personal data, please contact our Data Protection Officer using the details below. We are committed to addressing all data privacy enquiries promptly and transparently.

If you are not satisfied with lgplay's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority for data protection matters under the Data Privacy Act of 2012.