This Policy applies to all individuals interacting with LaVie Resort and Casino Manila, including those who:

• Make room or amenity reservations
• Apply for membership or loyalty programs
• Participate in casino activities and services
• Register for events and functions
• Conduct online transactions and use third-party booking engines
• Submit feedback or contact forms
• Use our official mobile application
• Visit our premises and are captured by our CCTV/FRS systems
• For other purposes as may be necessary to provide our services in accordance with applicable laws and regulations

We may collect and process the categories of personal data, and collect and process data including but not limited to the kind of data as provided below, as necessary to provide our services and comply with applicable laws:

• Identity Information: Full name, birthdate, nationality, government-issued ID
• Contact Details: Mobile number, email address, home address
• Booking Details: Check-in/check-out dates, room preferences, payment methods, flight details
• Gaming Activity: Membership ID, reward points, betting history (if enrolled)
• Payment Data: Credit/debit card details, billing address (via secure third-party gateway)
• Digital Identifiers: IP address, device information, browser details, location data
• Employment Data: (for applicants/employees): Educational background, employment history, biometric and payroll records
• CCTV/FRS Recordings: Video and/or audio footage for security and regulatory compliance
• Mobile App Data:
  1. Device permissions granted (e.g., location, camera, storage
  2. Push notification preferences
  3. App usage statistics (via third-party analytics such as Google Firebase or Apple Analytics)
  4. Advertising identifiers, where consented

Your personal data may be used for:

• Processing hotel and amenity bookings
• Facilitating check-in/check-out and guest services
• Enrolling you in LaVie Rewards and other loyalty programs
• Administering casino-related services in line with PAGCOR regulations
• Complying with AMLA, PAGCOR, and other regulatory obligations
• Conducting recruitment, onboarding, and HR administration
• Processing secure payments and online transactions
• Security monitoring, incident investigation, and regulatory compliance (CCTV/FRS)
• Sending push notifications and app updates (with your consent)
• Performing analytics to improve our mobile app and services
• Marketing and promotional communications (with your consent)
• Providing tailored experiences based on user preferences
• For other purposes in order to deliver efficient services

Payments made via our website, mobile application, or authorized third-party booking partners are processed through secure gateways using SSL/TLS encryption. We do not store payment card details on our servers. Please review the privacy policies of our third-party partners for their policies and practices.

As a licensed operator under PAGCOR, we process personal data for:

• Player registration and identity verification
• Monitoring of gaming activity
• KYC and customer due diligence protocols
• Compliance with AMLA reporting requirements
• Disclosure to PAGCOR and other competent authorities when legally required

We rely on:

• Contract performance (e.g., fulfilling reservations or employment agreements)
• Legal compliance (e.g., AMLA, PAGCOR, BIR)
• Legitimate interests (e.g., security, fraud prevention, service improvement)
• Consent (e.g., marketing communications, push notifications, app tracking)

We may share personal data with:

• Affiliates within the LaVie Group
• Accredited service providers for IT, bookings, payment, analytics, and marketing
• Third-party service providers such as Google Firebase, Google Analytics, or Apple Analytics to support app functionality and performance
• Regulatory bodies (NPC, PAGCOR, AMLC, BIR, courts, law enforcement)
• External partners under lawful data-sharing agreements

All sharing is subject to confidentiality and data protection safeguards.

We retain personal data only as long as necessary:

• Guest Booking Records: Retained only as long as necessary for the purposes stated in this policy, or as required by applicable laws and regulations (e.g., AMLA, PAGCOR), regardless of withdrawal of consent
• Gaming & Financial Records: Retained as required under AMLA, PAGCOR, and other applicable laws and regulations, regardless of withdrawal of consent
• Marketing Data: Until you withdraw consent
• HR Data: As long as necessary for employment or regulatory obligations
• CCTV/FRS Footage: Retained only as long as necessary for security, compliance, or legal purposes, after which securely deleted, unless required longer by law or investigation
• Mobile App Data: Retained only for as long as necessary to provide app services, or as required by law. Users may request deletion of app-related data at any time by contacting the DPO.

We may retain your personal data beyond standard periods if required to comply with legal obligations, resolve disputes, enforce our agreements, or as mandated by regulatory bodies.

Under the DPA, you have the right to:

• Be informed about the collection and use of your data
• Access your data and request corrections
• Request erasure or block inaccurate data
• Object to processing or withdraw consent
• Request data portability (where applicable)
• File complaints with the NPC for violations

Requests may be submitted using our Data Privacy Request Forms, available through the DPO.

We implement organizational, physical, and technical measures, including:

• Role-based access controls and employee confidentiality agreements
• Secure premises with restricted access and CCTV monitoring
• Encrypted communications, firewalls, and intrusion prevention systems
• Regular audits, vulnerability assessments, and disposal protocols

Data Breach Notification: In the event of a personal data breach that may compromise your rights and freedoms, LaVie Resort and Casino Manila will notify the National Privacy Commission (NPC) and affected individuals within the period prescribed by law, providing details of the breach, potential risks, and measures taken to address it.

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This website, mobile application, and our casino-related services are not intended for persons under 21 years of age, in compliance with PAGCOR regulations.

We do not knowingly collect personal data from individuals under 13 years old. For individuals between 13 and 20 years old, access to casino-related services is strictly prohibited.

During recruitment, onboarding, and employment, LaVie Resort and Casino Manila and its affiliates collects and processes personal data of applicants, employees, and other personnel. This includes:

• Identity information (e.g., full name, birthdate, government ID)
• Contact details
• Educational and employment history
• Pre-employment requirements (e.g., NBI clearance, medical records)
• Payroll and tax-related information
• Biometric data (e.g., timekeeping or access control)
• Performance evaluations and disciplinary records
• Other information as may be necessary for employment

Applicant records are retained only for a reasonable period if not hired. Employee records are retained in accordance with legal requirements, labor regulations, and company policies.

LaVie Resort and Casino Manila may use Closed-Circuit Television (CCTV) systems and, where applicable, Facial Recognition Systems (FRS) to ensure the safety, security, and protection of our guests, employees, and property, and to comply with regulatory requirements.

• Purpose: Security monitoring, crime prevention, fraud detection, incident investigation, and regulatory compliance
• Signage and Transparency: Notices are displayed in areas under surveillance
• Access and Disclosure: Restricted to authorized personnel; disclosure only when legally required or upon valid requests
• Data Subject Rights: Individuals may request access to footage involving them, subject to verification and redaction protocols, via the DPO
• Safeguards: Recordings stored securely with encryption, access logs, and audits

In addition to the above, this section applies to the LaVie Resort and Casino Manila mobile application available on Google Play and the Apple App Store:

• Permissions: The app may request access to device features (such as location, camera, or storage) solely to enable app functionality. You will be prompted to grant or deny such permissions.
• Analytics and Third-Party Services: We may use third-party tools such as Google Firebase, Google Analytics, or Apple Analytics to improve app performance and user experience. These may collect anonymized usage data, which is not used to personally identify you.
• Push Notifications: With your consent, we may send push notifications related to bookings, promotions, or account activity. You may disable these through your device settings.
• Tracking Transparency (Apple Users): If our iOS app requests permission to track your activity across other apps and websites for advertising or analytics purposes, you will be asked for your explicit consent via Apple’s AppTrackingTransparency (ATT) framework. You may change your preferences at any time in your device settings.
• Data Retention and Deletion Requests: Data collected through the app is retained only as long as necessary to provide services. Users may request deletion of their app data at any time by contacting the DPO.

We may update this Policy to reflect changes in laws, platform requirements, or service improvements. Material changes will be notified through appropriate channels.