mcluck Privacy Policy

1.1 mcluck is the personal information controller responsible for personal data collected through the mcluck platform accessible at mcluck.cam. mcluck operates under a licence issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to both PAGCOR's regulatory oversight and the jurisdiction of the National Privacy Commission of the Philippines.

1.2 mcluck has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection law. You may contact the mcluck DPO for any data privacy concern through the following:

• Email: [email protected] — Please include "Data Privacy" in the subject line;
• Live Chat: Available 24/7 at mcluck.cam — request escalation to the Data Protection Officer;
• Response Time: Data privacy requests will be acknowledged within three (3) business days and resolved within fifteen (15) business days as required by the Data Privacy Act.

2.1 mcluck collects the following categories of personal data from registered players and platform users:

2.2 mcluck does not collect sensitive personal information as defined under the Data Privacy Act — such as health data, religious beliefs, or sexual orientation — unless specifically required by law or voluntarily provided by the player in a responsible gaming context (e.g., self-disclosure of a gambling-related condition).

3.1 mcluck collects personal data through the following means:

• Direct provision by you: When you register a mcluck account, complete KYC verification, make a deposit, request a withdrawal, contact support, or respond to a survey;
• Automated collection: Through cookies, server logs, and tracking technologies as you interact with mcluck.cam — including IP address, device identifiers, and browsing behaviour;
• Third-party verification: From government ID verification services and payment processors used to confirm identity and process transactions;
• AML and fraud screening: From commercially available databases used to screen players against sanctions lists, politically exposed persons (PEP) lists, and adverse media sources as required by Philippine AML regulations.

4.1 mcluck processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: To create and manage your account, process deposits and withdrawals, deliver gaming services, and resolve disputes — processing without which the mcluck service cannot be provided;
• Legal obligation: To comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA) and its amendments, the Data Privacy Act, Bureau of Internal Revenue reporting requirements, and any other applicable Philippine law;
• Legitimate interests: To detect and prevent fraud, protect the security of the mcluck platform, conduct responsible gaming monitoring, and improve the quality of our services — where these interests are not overridden by your rights;
• Consent: For marketing communications, which you may withdraw at any time as described in Section 11 of this Policy.

4.2 mcluck will not use your personal data for purposes incompatible with those described in this Policy without first obtaining your explicit consent or establishing a new legal basis for processing.

5.1 mcluck uses cookies and similar tracking technologies on mcluck.cam to ensure the proper functioning of the platform, maintain your session, detect fraud, and analyse platform usage. The types of cookies used include:

• Essential cookies: Required for the mcluck platform to function correctly — session management, login state, security tokens. These cannot be disabled without impairing platform functionality;
• Analytical cookies: Used to measure how players interact with different sections of mcluck.cam, which games are most accessed, and where technical issues occur — to improve the platform;
• Functional cookies: Used to remember your preferences such as language settings and responsible gaming limit configurations between sessions;
• Security cookies: Used to detect and prevent bot activity, multiple account creation, and suspicious login patterns.

5.2 You may manage cookie preferences through your browser settings. Blocking essential cookies will affect your ability to log in and use the mcluck platform. mcluck does not use cookies for third-party advertising or cross-site behavioural tracking.

6.1 mcluck may share your personal data with the following categories of recipients:

• Payment processors: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, and other licensed payment service providers — for the sole purpose of processing your deposits and withdrawals;
• Game providers: JILI Technology, Evolution Gaming, SA Gaming, Pragmatic Play, PG Soft, and other licensed game suppliers — limited to session data required to operate game outcomes and resolve disputes;
• KYC and AML service providers: Third-party identity verification and screening services engaged to fulfil mcluck's PAGCOR and AMLA obligations;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and any Philippine court or law enforcement authority when required by law, court order, or regulatory direction;
• IT and hosting infrastructure providers: Cloud hosting and cybersecurity providers engaged under data processing agreements that require them to protect your data to at least the same standard as mcluck;
• Professional advisers: Legal, accounting, and auditing firms under strict confidentiality obligations.

6.2 All third parties with whom mcluck shares personal data are required to maintain appropriate security measures and to use the data solely for the specified purpose. mcluck does not permit third-party processors to use your data for their own purposes.

7.1 Some of mcluck's service providers — particularly game technology providers and cloud infrastructure operators — may be located outside the Philippines. Where personal data is transferred to processors outside the Philippines, mcluck ensures that adequate safeguards are in place in accordance with NPC guidelines, including data processing agreements that impose equivalent data protection standards.

7.2 mcluck will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without first putting in place appropriate contractual safeguards and, where required by the Data Privacy Act, obtaining your consent or notifying the NPC.

8.1 mcluck implements technical and organisational measures designed to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser or device and mcluck's servers;
• AES-256 encryption for personal and financial data stored at rest;
• Role-based access controls ensuring that employee access to personal data is limited strictly to what is required for their job function;
• Multi-factor authentication for all administrative system access;
• Regular penetration testing and vulnerability assessments conducted by independent security firms;
• 24/7 intrusion detection and security event monitoring;
• Employee data privacy training covering the requirements of the Philippine Data Privacy Act.

8.2 In the event of a personal data breach that is likely to pose a real risk to your rights and freedoms, mcluck will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay as required by Section 20(f) of the Data Privacy Act.

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

• Account data and KYC documents: Retained for the duration of the active account relationship and for five (5) years following account closure, as required by PAGCOR conditions and AMLA;
• Financial transaction records: Retained for five (5) years from the date of the transaction in compliance with the Anti-Money Laundering Act;
• Responsible gaming records: Retained for a minimum of five (5) years to support self-exclusion enforcement and regulatory audit requirements;
• Technical and usage data: Retained for twelve (12) months unless a longer period is required for an ongoing investigation or regulatory obligation;
• Customer support communications: Retained for three (3) years for dispute resolution and quality assurance purposes.

9.2 Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised in accordance with NPC guidelines for secure data disposal.

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by mcluck:

10.2 To exercise any of the above rights, please contact the mcluck Data Protection Officer by email at [email protected] with "Data Privacy Request" in the subject line. You may be required to verify your identity before your request is processed.

11.1 With your consent provided at registration or through your mcluck account preferences, mcluck may send you promotional communications about bonuses, new game releases, tournaments, VIP rewards, and other mcluck offers via email, SMS, or in-platform notification.

11.2 You may withdraw your consent to receive marketing communications at any time by:

• Updating your notification preferences in your mcluck account settings;
• Clicking the "unsubscribe" link in any marketing email sent by mcluck;
• Contacting mcluck support via live chat or email and requesting removal from all marketing lists.

11.3 Withdrawal of marketing consent does not affect the lawfulness of marketing sent before the withdrawal. mcluck may continue to send you service communications — such as deposit confirmations, withdrawal notifications, security alerts, and policy updates — even after you opt out of marketing, as these are necessary for account operation and not subject to marketing consent rules.

12.1 mcluck requires age verification as a mandatory step in the KYC process. Any account where the player is confirmed to be under 21 years of age will be immediately closed, all deposits returned, and any winnings voided in accordance with PAGCOR regulations and mcluck's Terms and Conditions.

12.2 If you have reason to believe that a person under 21 years of age has registered or is using a mcluck account, please contact our support team immediately via live chat or email. mcluck will investigate and take appropriate action within twenty-four (24) hours.

12.3 Any personal data inadvertently collected from a person confirmed to be under 21 years of age will be deleted as soon as practicable following confirmation of their age.

13.1 The mcluck platform integrates third-party services including game providers, payment gateways, and platform analytics tools that operate under their own privacy policies. mcluck selects third-party processors carefully and requires them to maintain data protection standards consistent with Philippine law.

13.2 mcluck is not responsible for the privacy practices of independent third-party controllers whose services may be accessible through the mcluck platform. Where game providers or payment processors act as independent data controllers in respect of your data, their own privacy policies govern that processing.

14.1 mcluck may update this Privacy Policy from time to time in response to changes in the Data Privacy Act, NPC issuances, PAGCOR requirements, or our platform operations. The date of the most recent revision is displayed at the top of this page.

14.2 Where changes are material — meaning they substantively affect the way mcluck processes your personal data or your rights — we will notify registered players via email or in-platform notification at least seven (7) days before the revised Policy takes effect.

14.3 Continued use of the mcluck platform following the effective date of a revised Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with the revised Policy, you may close your account as described in mcluck's Terms and Conditions.

14.4 The current version of this Privacy Policy is always available at mcluck.cam/privacy-policy. Previous versions are available upon written request to the mcluck Data Protection Officer.

15.1 For any questions, requests, or concerns related to this Privacy Policy or the processing of your personal data by mcluck, please contact us through the following channels:

• Data Privacy Email: [email protected] — subject line "Data Privacy";
• Live Chat: Available 24/7 at mcluck.cam — request to speak with the Data Protection Officer;
• Response SLA: Acknowledgement within 3 business days; resolution within 15 business days per Data Privacy Act requirements.

15.2 If you are not satisfied with mcluck's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines, the independent regulatory body responsible for enforcing the Data Privacy Act. The NPC may be contacted through its official government website.