Privacy Policy

This Privacy Policy ("Policy") applies to all personal data processed by tikluck in connection with the operation of the online gaming and sports betting platform accessible at tikluck.app and its associated mobile interface (collectively, the "tikluck Platform" or "Platform").

This Policy governs the personal data of the following individuals:

• Registered Players: individuals who have created a tikluck account and use the Platform to participate in games, place bets, make deposits, or claim promotions.
• Prospective Players: individuals who visit the tikluck website or mobile platform but have not yet completed registration.
• Support Contacts: individuals who contact tikluck's customer support team via live chat, email, or other channels, regardless of registration status.

By accessing the tikluck Platform, creating a tikluck account, or submitting any personal data to tikluck through any channel, you acknowledge that you have read and understood this Privacy Policy and consent to the data processing activities described herein.

This Policy should be read alongside tikluck's Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and tikluck.

For the purposes of this Privacy Policy, tikluck acts as the data controller in respect of personal data collected from players and visitors who use the tikluck Platform. As data controller, tikluck determines the purposes and means by which your personal data is processed.

tikluck is responsible for ensuring that personal data collected through the Platform is processed lawfully, fairly, and transparently in accordance with applicable Philippine data protection law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

If you have any questions about how tikluck processes your personal data, or if you wish to exercise any of your data subject rights, please refer to Section 14 (Contact & Complaints) of this Policy for contact details.

tikluck collects the following categories of personal data from players and platform visitors. The specific data collected in each category depends on the nature of your interaction with the tikluck Platform:

3.1 Registration & Identity Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth (used to verify you meet the 21+ age requirement)
• Gender
• Nationality and country of residence
• Email address
• Mobile phone number
• Username and encrypted password

3.2 KYC Verification & Identity Documents

• Copies of government-issued photo identification (Philippine passport, driver's license, SSS/UMID card, PhilSys National ID, or equivalent)
• Proof of address documents (utility bills, bank statements, or government correspondence dated within 90 days)
• Selfie or liveness check image submitted during identity verification
• Payment method ownership verification documents (e.g., screenshot of GCash account showing registered name)

3.3 Financial & Transaction Data

• Deposit amounts, dates, and payment method references
• Withdrawal requests, amounts, and processing status
• Account balance history
• Bonus and promotional credit activity
• Payment method identifiers (GCash number, BPI/BDO account last four digits, PayMaya account reference) — tikluck does not store full card numbers or full bank account numbers

3.4 Gaming & Betting Activity Data

• Game sessions played, including game type, duration, and stakes
• Bet history, outcomes, and resulting account balance changes
• Sports betting selections, markets wagered on, and settlement results
• Bonus wagering progress and bonus expiry events
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion status)

3.5 Device & Technical Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser/app version
• Unique device identifiers
• Session timestamps and session duration logs
• Pages visited, features used, and clickstream data within the Platform

3.6 Communications Data

• Records of live chat conversations with tikluck support agents
• Email correspondence sent to or received from tikluck
• Feedback, complaints, and dispute records
• Marketing communication preferences and opt-in/opt-out history

tikluck collects personal data through the following channels and mechanisms:

• Directly from you: Information you provide during account registration, KYC submission, payment setup, support interactions, and any other form you complete on the tikluck Platform.
• Automatically through platform use: Technical and behavioral data collected via server logs, session tracking, and cookies or similar technologies when you access the tikluck website or mobile interface. See Section 9 for full cookie details.
• From third-party payment providers: Transaction confirmation data shared by GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank when you initiate a deposit or withdrawal through those services.
• From identity verification partners: Verification outcomes and fraud screening signals provided by third-party KYC and AML screening services that tikluck engages to comply with regulatory obligations.
• From fraud prevention services: Risk signals, device reputation data, and IP intelligence from fraud prevention platforms used to protect the integrity of the tikluck Platform.

tikluck processes your personal data only for clearly defined, legitimate purposes. The table below summarizes the primary purposes for which we use your data and the legal basis for each:

tikluck does not sell your personal data to third parties. We share personal data only in the limited circumstances described below, and only to the extent strictly necessary for each purpose:

6.1 Payment Service Providers

To process your deposits and withdrawals, tikluck shares relevant transaction data with our authorized Philippine payment partners — GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank. These providers process data solely to facilitate the specific payment transaction requested and are bound by their own regulatory obligations as Philippine-licensed financial service providers.

6.2 KYC and Identity Verification Partners

tikluck engages third-party identity verification and AML screening providers to fulfill its regulatory compliance obligations. Your KYC documents and identity data are shared with these providers for the sole purpose of identity confirmation, sanctions screening, and fraud risk assessment. These providers are contractually bound to process your data only for these stated purposes.

6.3 Regulatory and Law Enforcement Authorities

tikluck may be required by law to disclose personal data to Philippine regulatory bodies, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or law enforcement agencies. Such disclosures are made only where legally required and to the minimum extent necessary to comply with applicable legal obligations or lawful orders.

6.4 Technology and Infrastructure Providers

tikluck uses third-party cloud hosting, database management, and IT security providers to operate the Platform. These providers process personal data only as data processors acting on tikluck's documented instructions and are contractually prohibited from using your data for their own purposes.

6.5 Fraud Prevention and Platform Integrity Services

To detect and prevent fraud, collusion, and bonus abuse, tikluck shares limited device and behavioral data with specialist fraud prevention services. This sharing is carried out on the basis of tikluck's legitimate interest in maintaining a fair and secure gaming environment for all players.

tikluck retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required to comply with applicable legal, regulatory, and contractual obligations. The following retention periods apply as a general guide:

• Active Account Data: Retained for the full duration of your tikluck account and for a minimum of five (5) years following permanent account closure, in accordance with Philippine AML record-keeping requirements.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of submission or the date of account closure, whichever is later, as required under applicable AML regulations.
• Transaction and Financial Records: Retained for a minimum of five (5) years following the date of each transaction, consistent with Philippine financial record-keeping obligations.
• Gaming and Betting History: Retained for a minimum of three (3) years from the date of each session or bet, for dispute resolution, regulatory audit, and responsible gaming monitoring purposes.
• Support and Communications Records: Retained for three (3) years from the date of each interaction for quality assurance and dispute resolution purposes.
• Technical and Device Logs: Retained for up to twelve (12) months for fraud detection, security monitoring, and platform performance analysis.
• Marketing Preferences: Retained until you withdraw consent or close your account, plus a suppression record to ensure opt-out preferences are honored.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with any individual player.

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

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the tikluck Platform is encrypted using industry-standard TLS encryption, ensuring that your login credentials, payment details, and personal data cannot be intercepted in transit.
• Encryption at Rest: Sensitive personal data — including identity documents and financial information — is encrypted at rest within tikluck's secure data infrastructure.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. tikluck staff and authorized service providers are granted only the minimum level of data access required to perform their designated functions.
• Password Security: Player passwords are stored using strong one-way cryptographic hashing. tikluck staff cannot view or retrieve your password in plain text.
• Two-Factor Authentication (2FA): tikluck offers optional 2FA for player accounts as an additional layer of login security. Players are encouraged to enable 2FA from their account security settings.
• Regular Security Testing: tikluck conducts regular security assessments and penetration testing of its Platform and data infrastructure to identify and remediate vulnerabilities proactively.
• Breach Response Procedures: In the event of a personal data breach that poses a risk to your rights and freedoms, tikluck will notify the Philippine National Privacy Commission (NPC) and affected players in accordance with the timeframes specified under the Data Privacy Act of 2012 and its implementing rules.

tikluck uses cookies and similar tracking technologies on the Platform to ensure proper functionality, improve user experience, and support fraud prevention and analytics activities. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the basic operation of the tikluck Platform — for example, maintaining your logged-in session, remembering your language preference, and managing load balancing across servers. These cookies cannot be disabled without severely impacting Platform functionality.
• Functional Cookies: These cookies remember your preferences and settings — such as responsible gaming tool configurations and display preferences — to provide a more personalized experience on tikluck.
• Analytics Cookies: These cookies collect aggregated, pseudonymous data about how players navigate and use the Platform, helping tikluck identify areas for improvement. Analytics data is not used to build individual advertising profiles.
• Security and Fraud Prevention Cookies: These cookies support tikluck's fraud detection systems by collecting device fingerprinting signals and session anomaly indicators. They are essential for protecting the security of every player's account.

You may manage your cookie preferences through your browser settings. Disabling cookies other than strictly necessary ones may limit some Platform features. tikluck does not use third-party advertising or targeting cookies.

As a data subject under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by tikluck. To exercise any of these rights, please contact tikluck's Data Privacy Officer using the details in Section 14:

• Right to be Informed: You have the right to be informed about how your personal data is collected, processed, and used. This Privacy Policy fulfills tikluck's obligation to provide that transparency.
• Right to Access: You may request a copy of the personal data that tikluck holds about you, along with information about how it has been processed. tikluck will respond to verified access requests within thirty (30) days.
• Right to Rectification: If any of your personal data held by tikluck is inaccurate or incomplete, you have the right to request correction. You may update basic profile details directly through your account settings; for KYC data corrections, please contact support.
• Right to Erasure: You may request deletion of your personal data. tikluck will honor erasure requests where there is no overriding legal obligation to retain the data (e.g., AML record-keeping requirements may prevent immediate deletion of certain financial records).
• Right to Object: You may object to the processing of your personal data for marketing purposes or, in certain circumstances, for processing based on tikluck's legitimate interests. Marketing opt-out takes effect immediately upon receipt of your request.
• Right to Data Portability: You may request a copy of your personal data in a structured, machine-readable format for transfer to another data controller, where technically feasible and where processing is based on your consent or a contract.
• Right to Lodge a Complaint: If you believe tikluck has not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC) at privacy.gov.ph.

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

As part of the account registration and KYC process, tikluck verifies the age of all players. If tikluck becomes aware that personal data has been collected from an individual under the age of 21, we will:

• Immediately suspend the associated account.
• Void any transactions, bonuses, or winnings associated with the underage account.
• Delete or anonymize the personal data of the underage individual as soon as practicable, subject to any legal obligations that may require temporary retention for audit purposes.

tikluck primarily stores and processes player data within secure data center infrastructure serving the Philippine market. In certain circumstances, personal data may be processed by tikluck's technology partners or service providers whose systems are located outside the Philippines — for example, cloud infrastructure providers or fraud screening services operating internationally.

Where personal data is transferred outside the Philippines, tikluck ensures that appropriate safeguards are in place to protect your data in accordance with the requirements of the Data Privacy Act of 2012. These safeguards may include:

• Contractual data processing agreements incorporating data protection obligations equivalent to those required under Philippine law.
• Transfers to jurisdictions recognized as providing an adequate level of data protection for the specific processing activity.
• Binding corporate rules or other legally recognized transfer mechanisms where applicable.

tikluck does not transfer personal data to third parties in other countries for their own marketing or commercial purposes.

tikluck 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 guidance. When material changes are made to this Policy, tikluck will notify registered players by posting a prominent notice on the Platform upon login or by sending a notification to your registered email address.

The "Last Updated" date at the top of this Policy will always reflect the date on which the most recent revision took effect. Your continued use of the tikluck Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this Policy, you should discontinue use of the Platform and may request account closure by contacting tikluck support.

tikluck recommends that all players review this Privacy Policy periodically. The most current version will always be accessible at tikluck.app/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or tikluck's handling of your personal data, please reach out to our dedicated support team. tikluck is committed to responding to all data privacy inquiries promptly and in good faith.

If you are not satisfied with tikluck's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph. tikluck will cooperate fully with any NPC investigation.