mcluck Privacy Policy

1 Introduction

mcluck ("we," "us," or "our") is committed to protecting the privacy and personal data of all users ("you," "Player," or "data subject") who access and use the mcluck Platform at mcluck.app. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

This Policy applies to all personal data collected through the mcluck website, mobile-optimized platform, customer support channels, and any other touchpoints through which you interact with mcluck. It should be read together with our Terms and Conditions and Responsible Gaming Policy.

By registering an account or continuing to use the mcluck Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, mcluck acts as the Personal Information Controller (PIC) with respect to the personal data of its registered players and website visitors.

As the PIC, mcluck determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently in accordance with applicable Philippine data protection law.

If you have any questions or concerns regarding the processing of your personal data, you may contact our Data Protection Officer (DPO) at the contact details provided in Section 14 of this Policy.

3 Data We Collect

mcluck collects the following categories of personal data from its users:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., PhilSys ID number, passport number, driver's license number).
• Contact Data: Email address, Philippine mobile number, and residential address (including barangay, city/municipality, province, and postal code).
• Account Data: Username, encrypted password, account registration date, account status, and communication preferences.
• Financial Data: Deposit and withdrawal transaction records, payment method details (e.g., GCash mobile number, bank account name and last four digits), transaction amounts in Philippine Peso (PHP), and wallet balance history.
• Gaming Activity Data: Game history, bet amounts, win/loss records, session duration, game preferences, and bonus utilization records.
• Technical Data: IP address, device type and model, operating system, browser type and version, screen resolution, and time zone.
• Usage Data: Pages visited, features accessed, click-through patterns, session timestamps, and referral source.
• Communications Data: Records of your correspondence with mcluck customer support, including chat transcripts, email exchanges, and support ticket history.
• KYC Verification Data: Copies of government-issued identification documents and proof of address submitted during the Know Your Customer (KYC) verification process.

4 How We Collect Data

mcluck collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access the Platform.
• Third-Party Sources: Identity verification data from KYC service providers; fraud detection signals from payment processors; and, where applicable, publicly available information used for compliance screening.
• Payment Processors: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment partners used to process your deposits and withdrawals.

5 Purpose of Processing

mcluck processes your personal data for the following specific, legitimate purposes:

• Account Management: To create, maintain, verify, and manage your mcluck player account.
• Service Delivery: To provide access to casino games, sportsbook markets, live dealer tables, and all other Platform features.
• Financial Transactions: To process deposits, withdrawals, and bonus credits accurately and securely in Philippine Peso.
• KYC & Identity Verification: To verify your identity and age (21+) in compliance with PAGCOR licensing requirements and Philippine anti-money laundering regulations.
• Regulatory Compliance: To fulfill obligations under the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and applicable PAGCOR regulations.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer self-exclusion, deposit limit, and other responsible gaming tools.
• Platform Improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the mcluck Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, subject to your communication preferences and applicable opt-out rights.

6 Legal Basis for Processing

mcluck processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and mcluck — specifically, the Terms and Conditions governing your use of the Platform.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to mcluck, including AMLA reporting requirements and PAGCOR regulatory obligations.
• Legitimate Interests: Where processing is necessary for the legitimate interests of mcluck, such as fraud prevention, platform security, and service improvement, provided such interests are not overridden by your rights and freedoms.

7 Data Sharing & Disclosure

mcluck does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment partners, for the purpose of processing your financial transactions.
• KYC & Identity Verification Providers: Third-party service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Game Content Providers: Licensed game studios and software providers whose games are available on the mcluck Platform, to the extent necessary for game delivery and dispute resolution.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities, where disclosure is required by law or regulatory order.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and data analytics providers engaged by mcluck under strict data processing agreements that require them to handle your data in accordance with this Policy.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors engaged by mcluck, subject to professional confidentiality obligations.

All third-party service providers engaged by mcluck are required to implement appropriate technical and organizational measures to protect your personal data and are prohibited from using it for any purpose other than those specified by mcluck.

8 Data Retention

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

• Active Account Data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required under Philippine anti-money laundering regulations.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer Support Records: Support correspondence is retained for three (3) years from the date of the last interaction.
• Marketing Data: Retained until you withdraw your consent or opt out of marketing communications, after which it is deleted within thirty (30) days.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with mcluck's data disposal procedures.

9 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 mcluck:

• Right to Be Informed: The right to be informed of the existence of processing, the nature of the data collected, and the purposes for which it is being processed — as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data mcluck holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by mcluck.
• Right to Erasure: 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 mcluck's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 14. mcluck will respond to all verified data subject requests within fifteen (15) business days of receipt.

10 Cookies & Tracking Technologies

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

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management, authentication, and security features. These cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics Cookies: Used to collect aggregated, anonymized data about how users interact with the Platform, helping us identify areas for improvement.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and other security threats.

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

11 Security Measures

mcluck implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the mcluck Platform.
• Encryption of sensitive data at rest, including financial records and KYC documents.
• Role-based access controls limiting access to personal data to authorized personnel only, on a need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Staff training on data privacy obligations and secure data handling practices.

While mcluck takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying mcluck immediately if you suspect unauthorized access to your account.

12 Children's Privacy

The mcluck Platform is strictly intended for individuals who are at least 21 years of age, in accordance with the minimum legal age for participation in casino-style gambling activities in the Philippines. mcluck does not knowingly collect personal data from individuals under the age of 21.

If mcluck becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, all associated data will be deleted, and any deposits will be returned to the originating payment method pending verification.

If you believe that a minor has registered on the mcluck Platform, please contact our support team immediately at the details provided in Section 14.

13 Policy Updates

mcluck 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. Where changes are material, we will notify registered players via email or an in-Platform notification prior to the changes taking effect.

The "Last updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the mcluck Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how mcluck protects your personal data.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact mcluck's Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. For more information, visit the NPC's official channels through Philippine government resources.