lock789 Privacy Policy

1. Who We Are

lock789 ("we," "us," "our," or "the Company") operates the online gaming platform accessible at lock789.org and any associated mobile interfaces. For the purposes of the Data Privacy Act of 2012, lock789 acts as the Personal Information Controller (PIC) in respect of the personal data it collects from registered players and website visitors.

lock789 is registered and operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Our registered office is located in Makati City, Metro Manila, Philippines. All data processing activities described in this Privacy Policy are conducted in accordance with Philippine law and applicable international data protection standards.

This Privacy Policy applies to all individuals who access or use the lock789 platform, including registered players, prospective players who browse the website, and any person who contacts lock789 through our support channels. By using the lock789 platform, you acknowledge that you have read and understood this Privacy Policy.

2. Personal Data We Collect

lock789 collects only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we collect include:

lock789 does not collect sensitive personal information as defined under the Data Privacy Act (such as health data, political opinions, or religious beliefs) unless specifically required for responsible gaming assessments, in which case your explicit consent will be obtained.

3. How We Collect Your Data

lock789 collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the lock789 platform, including through cookies, web beacons, log files, and similar tracking technologies.
• Third-Party Sources: Identity verification data from government databases or third-party KYC service providers; fraud screening data from anti-fraud partners; payment data from GCash, PayMaya, BPI, BDO, Metrobank, and card payment processors.
• Regulatory Sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with compliance obligations.

Where lock789 receives personal data from third-party sources, we ensure that such data has been collected lawfully and that the third party has the right to share it with us for the stated purposes.

4. How We Use Your Personal Data

lock789 uses your personal data for the following purposes:

• Account Management: Creating, maintaining, and managing your lock789 player account, including processing your registration and verifying your identity.
• Service Delivery: Providing access to games, processing deposits and withdrawals, crediting bonuses, and delivering all platform features.
• Regulatory Compliance: Meeting our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, money laundering, and other illegal conduct on the platform.
• Responsible Gaming: Monitoring gaming behaviour to identify potential problem gambling patterns and administering responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: Responding to your queries, resolving disputes, and improving our support services.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates — but only where you have opted in to receive such communications. You may opt out at any time.
• Platform Improvement: Analysing usage patterns and technical data to improve the performance, security, and user experience of the lock789 platform.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, lock789 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you — i.e., to provide the lock789 gaming services you have registered for.
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR regulations, AMLA reporting obligations, and tax requirements.
• Legitimate Interests: Processing necessary for lock789's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights.
• Consent: Where we rely on your consent — for example, for marketing communications or the processing of sensitive personal information — you have the right to withdraw that consent at any time by contacting us at [email protected].

6. Data Sharing & Disclosure

lock789 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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:

• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where required by law or regulatory directive.
• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to verify your identity and age in compliance with PAGCOR requirements.
• Fraud Prevention Partners: Anti-fraud and risk management service providers who assist lock789 in detecting and preventing fraudulent activity on the platform.
• Technology Service Providers: Cloud hosting, data storage, and platform infrastructure providers who process data on lock789's behalf under strict data processing agreements.
• Game Software Providers: Licensed game developers and live dealer studio operators whose games are available on the lock789 platform, to the extent necessary for game delivery and dispute resolution.
• Legal & Professional Advisers: Lawyers, auditors, and other professional advisers engaged by lock789 in connection with legal proceedings, regulatory investigations, or compliance reviews.

All third parties with whom lock789 shares personal data are required to process that data in accordance with the Data Privacy Act of 2012 and are bound by contractual data protection obligations. lock789 remains responsible for ensuring that such third parties handle your data appropriately.

7. Cookies & Tracking Technologies

The lock789 platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and gather analytical data about platform usage. A cookie is a small text file placed on your device when you visit the lock789 website.

lock789 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the operation of the lock789 platform, including maintaining your login session and ensuring platform security. These cookies cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and display options, to personalise your experience on lock789.
• Analytical Cookies: Collect anonymised data about how players use the lock789 platform, helping us identify areas for improvement. This data does not identify you personally.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your gaming activity and preferences, where you have consented to receive marketing communications.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the lock789 platform. For more information on managing cookies, refer to your browser's help documentation.

8. Data Retention

lock789 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 and regulatory obligations. The following retention periods apply:

Upon expiry of the applicable retention period, lock789 will securely delete or anonymise your personal data in accordance with our data disposal procedures. Where data is anonymised, it may be retained indefinitely for statistical and analytical purposes.

9. Data Security

lock789 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security framework includes:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and the lock789 platform is encrypted using industry-standard SSL/TLS protocols.
• Data Encryption at Rest: Sensitive personal and financial data stored on lock789 servers is encrypted using AES-256 encryption.
• Access Controls: Strict role-based access controls ensure that only authorised lock789 personnel can access personal data, and only to the extent necessary for their job functions.
• Multi-Factor Authentication: Internal systems containing personal data are protected by multi-factor authentication requirements for all staff.
• Regular Security Audits: lock789 conducts regular penetration testing, vulnerability assessments, and security audits of its platform and infrastructure.
• Incident Response: lock789 maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) within 72 hours and affected players without undue delay, as required by the Data Privacy Act.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by lock789. To exercise any of these rights, please contact our Data Protection Officer at [email protected].

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data lock789 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have 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 our legal retention obligations.
• Right to Object: You have 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: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that lock789 has processed your personal data in violation of the Data Privacy Act.

lock789 will respond to all data rights requests within 30 calendar days of receipt. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reasons for it.

11. Children's Privacy

The lock789 platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine law and PAGCOR regulations governing casino-style online gambling. lock789 does not knowingly collect personal data from individuals under the age of 21.

lock789 employs robust age verification procedures during the registration process to prevent underage individuals from accessing the platform. If lock789 becomes aware that personal data has been collected from a person under the age of 21, 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 lock789 platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

12. Cross-Border Data Transfers

In the course of providing the lock789 platform, your personal data may be transferred to and processed in countries outside the Philippines — for example, where our technology service providers or game software partners operate servers in other jurisdictions.

Where such cross-border transfers occur, lock789 ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual data protection clauses that impose obligations on the recipient equivalent to those under the Data Privacy Act of 2012.
• Transfers only to countries or organisations that the National Privacy Commission has determined provide an adequate level of data protection.
• Where required, obtaining your explicit consent to the cross-border transfer of your personal data.

lock789 will not transfer your personal data to any jurisdiction that does not provide adequate data protection safeguards without your prior consent.

13. Updates to This Privacy Policy

lock789 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The "Last Updated" date at the top of this page indicates when the policy was most recently revised.

Where changes to this Privacy Policy are material — meaning they significantly affect your rights or how we process your personal data — lock789 will notify registered players by email or through a prominent notice on the platform at least seven (7) days before the changes take effect.

We encourage you to review this Privacy Policy periodically to stay informed about how lock789 protects your personal data. Your continued use of the lock789 platform following the posting of any updates constitutes your acknowledgment of the revised Privacy Policy.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by lock789, please contact our Data Protection Officer (DPO) using the details below: