luxjili Privacy Policy

This Privacy Policy ("Policy") describes how luxjili ("luxjili," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the luxjili website at https://luxjili.app and all associated services, games, and features (collectively, the "Platform").

luxjili is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC) of the Philippines.

By registering an account, accessing the Platform, or otherwise providing your personal information to luxjili, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

For the purposes of the Data Privacy Act of 2012 and this Policy, luxjili is the Personal Information Controller in respect of the personal data collected through the Platform. This means luxjili determines the purposes and means of processing your personal information.

luxjili has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO at any time using the contact details provided in Section 14 of this Policy.

luxjili collects the following categories of personal data, depending on how you interact with the Platform:

luxjili does not intentionally collect sensitive personal information (as defined under the DPA) unless strictly required for regulatory compliance, such as for anti-money laundering (AML) purposes. Where sensitive data is collected, we apply heightened security and access controls.

luxjili collects personal data through the following means:

• 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, log files, and similar tracking technologies when you access and navigate the Platform (see Section 7 for details);
• From third parties — including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification service providers, fraud prevention agencies, and regulatory authorities where permitted by law;
• From publicly available sources — such as public records or social media profiles, where relevant to fraud prevention or regulatory compliance.

luxjili processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

• Account creation and management — to register your account, verify your identity, and provide access to the Platform (contractual necessity);
• Payment processing — to process deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers (contractual necessity);
• Regulatory compliance — to fulfill our obligations under Philippine AML laws, PAGCOR regulations, and the Data Privacy Act, including KYC verification and suspicious transaction reporting (legal obligation);
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, cheating, and unauthorized access (legitimate interest);
• Responsible gaming — to monitor gameplay patterns, enforce deposit limits, and administer self-exclusion requests (legal obligation and legitimate interest);
• Customer support — to respond to your queries, complaints, and feedback (contractual necessity and legitimate interest);
• Marketing communications — to send you promotional offers, bonus notifications, and platform updates, where you have provided consent (consent-based; you may withdraw consent at any time);
• Platform improvement — to analyze usage patterns and improve the performance, features, and user experience of the Platform (legitimate interest).

luxjili does not sell, rent, or trade your personal data to unaffiliated third parties for their own commercial 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:

• Payment processors — GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions;
• Identity verification providers — third-party KYC and AML service providers engaged to verify your identity and screen against sanctions lists;
• Game providers — licensed third-party game studios whose games are hosted on the Platform, to the extent necessary to deliver gameplay services;
• IT and infrastructure providers — cloud hosting, cybersecurity, and technical support providers who process data on our behalf under strict data processing agreements;
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities, where required by law or court order;
• Professional advisers — lawyers, auditors, and accountants, subject to professional confidentiality obligations.

All third-party service providers who process personal data on behalf of luxjili are required to implement appropriate technical and organizational security measures and to process data only in accordance with our documented instructions.

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

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and display options to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how players use the Platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

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

luxjili retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of 5 years following account closure, in compliance with AML and PAGCOR record-keeping requirements;
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, as required by the Anti-Money Laundering Act;
• KYC verification documents: Retained for a minimum of 5 years following account closure or the completion of the relevant transaction;
• Customer support communications: Retained for 2 years from the date of the last interaction, unless a longer period is required for dispute resolution;
• Technical and usage data: Retained for up to 12 months in identifiable form, after which it may be anonymized and retained for analytical purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

luxjili implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• AES-256 encryption for all personal data stored on luxjili servers;
• TLS 1.3 encryption for all data transmitted between your device and the Platform;
• Multi-factor authentication (MFA) for all internal staff accounts with access to personal data;
• Role-based access controls limiting data access to authorized personnel on a strict need-to-know basis;
• Regular penetration testing and vulnerability assessments conducted by qualified security professionals;
• 24/7 security monitoring and intrusion detection systems;
• Documented incident response procedures to ensure prompt action in the event of a data breach.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, luxjili will notify the National Privacy Commission and affected players in accordance with the timelines prescribed by the Data Privacy Act and NPC regulations.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by luxjili. You may exercise any of these rights by contacting our Data Protection Officer using the details in Section 14:

luxjili will respond to all verified data subject requests within 30 calendar days of receipt. We may request proof of identity before processing your request to protect against unauthorized access to your data.

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

If luxjili becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and return any deposits made, in accordance with our Terms and Conditions.

If you are a parent or guardian and believe that your child has provided personal data to luxjili, please contact our Data Protection Officer immediately using the contact details in Section 14.

luxjili primarily stores and processes personal data within the Philippines. In certain circumstances, your personal data may be transferred to and processed in countries outside the Philippines — for example, where we use cloud infrastructure providers or game studios with servers located abroad.

Where such international transfers occur, luxjili ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries that the NPC has determined provide an adequate level of data protection;
• Implementing contractual clauses approved by the NPC with the recipient organization;
• Ensuring that recipient organizations are bound by binding corporate rules or equivalent data protection standards.

You may request further information about the safeguards applicable to any specific international transfer by contacting our Data Protection Officer.

luxjili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email or a prominent notice on the Platform at least 7 days before the changes take effect, where reasonably practicable.

The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how luxjili protects your personal data.

Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure in accordance with our Terms & Conditions.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way luxjili handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 via the chat widget on the luxjili Platform
• General Support: [email protected]

luxjili will acknowledge your privacy inquiry within 3 business days and provide a substantive response within 30 calendar days.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory authority responsible for enforcing the Data Privacy Act of 2012.