lsvip Privacy Policy

1 Overview & Scope

This Privacy Policy ("Policy") is issued by lsvip ("lsvip," "we," "us," "our"), the operator of the online gaming platform accessible at lsvip.org ("the Platform"). It describes how lsvip collects, uses, discloses, retains, and protects personal data relating to users of the Platform ("you," "Player," "User").

This Policy applies to all personal data collected through: the lsvip website and all Platform pages; the account registration and login process; deposit, withdrawal, and transaction activity; customer support interactions; promotional and marketing communications (where you have opted in); and any other interaction you have with lsvip in connection with the Platform.

lsvip is committed to processing personal data lawfully, fairly, and transparently, in accordance with the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

By registering an account on the lsvip Platform or by continuing to use the Platform after this Policy has been made available to you, you acknowledge that you have read and understood this Policy. This Policy should be read together with the lsvip Terms & Conditions, which govern your use of the Platform.

2 Data We Collect

lsvip collects the following categories of personal data in connection with your use of the Platform:

2.1 Identity Data

Full legal name, date of birth, nationality, and copies of government-issued identification documents (e.g., PhilSys National ID, passport, driver's license, UMID, SSS ID, PRC ID, voter's ID) provided during account registration or KYC verification.

2.2 Contact Data

Email address, Philippine mobile number, and residential address (including city, province, and postal code). Players in Metro Manila, Cebu, Davao, Quezon City, Makati, and other Philippine cities are served through the same data infrastructure.

2.3 Financial Data

Payment method details used for deposits and withdrawals, including GCash account references, Maya account references, bank account numbers (BPI, BDO, Metrobank, UnionBank), and transaction histories. lsvip does not store full bank card numbers or CVV codes directly — payment processing is handled by regulated payment service providers.

2.4 Account & Gaming Data

Account username, login history, session timestamps, game activity records (wagers placed, games played, results), bonus usage history, and responsible gaming settings.

2.5 Technical Data

IP address, browser type and version, operating system, device identifiers, time zone, and referring URLs, collected automatically when you access the Platform.

2.6 Communications Data

Records of your communications with lsvip customer support, including live chat transcripts, email correspondence, and any feedback or complaints submitted through the Platform.

2.7 Marketing Preferences

Your preferences regarding receiving promotional communications from lsvip, including opt-in and opt-out records.

3 How We Collect Your Data

lsvip collects personal data through the following channels:

lsvip collects only the minimum data necessary for the purposes described in this Policy. You are not required to provide data beyond what is needed to operate your account and comply with applicable regulations.

4 Purpose & Legal Basis for Processing

lsvip processes your personal data only where a lawful basis exists under the Data Privacy Act of 2012. The following table summarises the primary purposes for which lsvip processes personal data and the corresponding legal basis for each:

5 Sharing Your Personal Data

5.1 Who We Share Data With

lsvip does not sell, rent, or trade your personal data to unaffiliated third parties for commercial purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

• Payment service providers: GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other payment processors engaged to facilitate deposits and withdrawals;
• Identity verification providers: Third-party KYC and AML service providers that verify the identity and watchlist status of account holders;
• Technology service providers: Cloud hosting, cybersecurity, platform infrastructure, and analytics service providers engaged to operate the Platform;
• Customer support providers: Third-party live chat and ticketing system providers engaged to deliver player support services;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where required by law or court order;
• Professional advisors: Lawyers, auditors, and accountants where necessary for the operation of lsvip's business.

5.2 Data Processing Agreements

All third-party service providers engaged by lsvip who process personal data on our behalf are required to enter into data processing agreements that bind them to process data only in accordance with lsvip's instructions and to implement appropriate security measures consistent with the Data Privacy Act of 2012.

5.3 No Sale of Data

lsvip expressly confirms that it does not and will not sell your personal data to data brokers, advertisers, or other commercial entities for their own use.

6 Data Retention

lsvip retains your personal data only for as long as is necessary for the purposes described in this Policy, or as required by applicable law. The following retention periods apply as a general guide:

After the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents re-identification, unless a longer retention period is required by a specific legal obligation or court order.

7 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the lsvip Platform;
• Encryption at rest for sensitive stored data, including identity documents and financial records;
• Role-based access controls limiting access to personal data to authorised lsvip personnel who require it to perform their duties;
• Multi-factor authentication for internal systems that store or process personal data;
• Regular security audits and penetration testing conducted by qualified third-party security professionals;
• Intrusion detection and monitoring systems to identify and respond to potential security incidents in real time;
• Employee training on data protection obligations under the Data Privacy Act of 2012.

7.1 Data Breach Response

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, lsvip will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, as required under NPC Circular 16-03. Where the breach is likely to result in a high risk to you personally, lsvip will also notify you directly without undue delay, in accordance with applicable NPC guidelines.

8 Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device by a website when you visit it. lsvip uses cookies and similar tracking technologies (including local storage and session identifiers) to operate and improve the Platform.

8.2 Types of Cookies Used by lsvip

8.3 Managing Cookies

You can manage your cookie preferences through your browser settings at any time. Most modern browsers allow you to refuse, delete, or be notified about cookies. Please note that disabling strictly necessary cookies may prevent certain Platform features from functioning correctly. Instructions for managing cookies in commonly used browsers are available on the respective browser's help pages.

9 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by lsvip:

• Right to be Informed: The right to be told how your personal data is collected, used, and disclosed — which this Policy fulfils;
• Right of Access: The right to request a copy of the personal data that lsvip holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure ("Right to be Forgotten"): The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to lsvip's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data, including for direct marketing purposes;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe lsvip has violated your data privacy rights.

9.1 Exercising Your Rights

To exercise any of the above rights, please contact the lsvip Data Protection Officer using the contact details provided in Section 13. lsvip will respond to all valid data subject requests within fifteen (15) business days of receipt. In complex cases, this period may be extended by a further fifteen (15) business days, with notice to you.

9.2 Identity Verification for Requests

To protect your data, lsvip may require you to verify your identity before processing a data subject request. This is to prevent unauthorised access to your personal information by third parties.

10 Minors & Age Restriction

The lsvip Platform is strictly restricted to persons who are 21 years of age or older, in accordance with Philippine gambling laws and PAGCOR regulations. lsvip does not knowingly collect personal data from persons under the age of 21.

If lsvip becomes aware that personal data has been collected from a person under 21 years of age, such data will be deleted promptly and the associated account will be permanently closed. Any deposits made by an underage player will be handled in accordance with applicable Philippine law.

Parents and guardians who believe that their minor child has registered on the lsvip Platform should contact our support team immediately using the contact details in Section 13.

11 Cross-Border Data Transfers

lsvip primarily stores and processes personal data within the Philippines or in jurisdictions that provide an adequate level of data protection as recognised under applicable Philippine law. Where data is transferred outside the Philippines — for example, to cloud service providers or technology partners with infrastructure in other countries — lsvip ensures that appropriate safeguards are in place to protect your data, including:

• Contractual clauses that bind the recipient to data protection standards equivalent to those required under the Philippine Data Privacy Act of 2012;
• Selection of service providers located in jurisdictions recognised by the NPC as providing adequate protection;
• Binding corporate rules or equivalent arrangements where applicable.

By using the lsvip Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside the Philippines, subject to the safeguards described above.

12 Amendments to This Policy

lsvip reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, NPC guidelines, PAGCOR regulations, or lsvip's data processing practices. The "Last Updated" date at the top of this page will be revised whenever material changes are made.

Where changes are material, lsvip will endeavour to notify registered players via email or an in-Platform notification prior to the changes taking effect. Your continued use of the lsvip Platform after any amendments have been posted constitutes your acknowledgment of the updated Policy.

lsvip encourages you to review this Policy periodically to stay informed of how your personal data is being protected and used.

13 Contact & Data Protection Officer

lsvip has appointed a Data Protection Officer (DPO) in accordance with Section 21 of the Data Privacy Act of 2012 and NPC Circular 17-01. The DPO is responsible for overseeing lsvip's compliance with data privacy obligations and handling data subject requests and complaints.

To contact the lsvip Data Protection Officer, or for any privacy-related enquiry, request, or complaint, please use the following:

• Email: [email protected] (Subject line: "Data Privacy Request")
• Response Time: Within 15 business days of receipt
• Languages: English and Filipino
• Live Chat: Available to logged-in players via lsvip Login

If you are not satisfied with lsvip's response to a data privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines, the competent supervisory authority for data protection matters under Republic Act 10173.