Privacy Policy — suerph

1. Introduction

suerph ("suerph," "we," "us," "our") is committed to protecting the privacy and personal data of all players who use the suerph platform, including the suerph website, mobile application, and any related services. This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

This Policy applies to all registered players, visitors to the suerph website, and any individual whose personal data is processed by suerph in connection with the provision of our online casino and sports betting services to Filipino players across Manila, Cebu, Davao, Quezon City, Makati, and the rest of the Philippines.

By registering a suerph account, making a deposit, or otherwise using the suerph platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree with this Policy, you must not use the suerph platform.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming policy, which together govern your use of the suerph platform.

2. Data Controller

For the purposes of applicable data protection legislation, suerph is the data controller responsible for your personal data collected through the suerph platform. As data controller, suerph determines the purposes and means of processing your personal information.

If you have any questions about how suerph handles your personal data, or if you wish to exercise any of your data rights described in this Policy, you may contact our Data Privacy Officer at:

3. Personal Data We Collect

suerph collects personal data that is necessary to provide you with a safe, compliant, and functional online gaming experience. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Residential address (including barangay, city, and province)
• Email address
• Philippine mobile number
• Username and encrypted password
• Gender (optional, for personalization purposes)

3.2 Identity Verification (KYC) Data

• Government-issued photo ID (passport, driver's license, Philippine national ID, or SSS/GSIS ID)
• Proof of address documents (utility bill, bank statement, or barangay certificate dated within 90 days)
• Selfie or live photo for identity matching purposes
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account showing your name)

3.3 Financial & Transaction Data

• Deposit and withdrawal amounts and timestamps
• Payment method details (GCash number, PayMaya number, bank account name — we do not store full bank account numbers or card numbers)
• Transaction history and wallet balance records
• Bonus and promotional activity records

3.4 Gaming Activity Data

• Games played, bet amounts, win/loss records, and session durations
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, session reminders)
• Game preferences and platform interaction history

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Cookie identifiers and session tokens
• Platform access logs and timestamps

3.6 Communications Data

• Live chat transcripts and email correspondence with suerph support
• Feedback, survey responses, and complaint records
• Marketing communication preferences

4. How We Collect Your Data

suerph collects personal data through the following means:

• Directly from you: When you register a suerph account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions.
• Automatically: When you access the suerph platform, we automatically collect technical and device data through cookies, log files, and similar tracking technologies.
• From third-party verification providers: suerph uses licensed KYC and identity verification service providers to assist with document verification and fraud detection. These providers process your data on our behalf under strict data processing agreements.
• From payment processors: When you make a deposit or withdrawal via GCash, PayMaya, BPI, BDO, Metrobank, or UnionBank, our payment processing partners share transaction confirmation data with suerph.

5. How We Use Your Personal Data

suerph uses your personal data for the following purposes:

suerph does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have provided explicit consent.

6. Legal Basis for Processing

suerph processes your personal data on the following legal bases under applicable Philippine data protection law (Republic Act No. 10173, the Data Privacy Act of 2012, and its Implementing Rules and Regulations):

• Contractual necessity: Processing required to fulfill our obligations under the suerph Terms & Conditions, including account management, payment processing, and KYC verification.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, age verification requirements, and regulatory reporting.
• Legitimate interests: Processing necessary for suerph's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and optional personalization features. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

suerph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following circumstances:

7.1 Service Providers

suerph engages trusted third-party service providers who process personal data on our behalf under strict data processing agreements. These include KYC and identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank), cloud hosting and infrastructure providers, customer support platform providers, and fraud detection and cybersecurity services. All service providers are contractually required to process your data only as instructed by suerph and to maintain appropriate security standards.

7.2 Regulatory and Legal Authorities

suerph may disclose your personal data to Philippine government agencies, law enforcement authorities, or regulatory bodies where required by law, court order, or regulatory directive. This includes disclosures required under the Anti-Money Laundering Act (AMLA) and related regulations.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of suerph's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

7.4 With Your Consent

suerph may share your personal data with third parties in other circumstances where you have provided explicit, informed consent to do so. You may withdraw such consent at any time by contacting [email protected].

8. Data Retention

suerph retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your suerph account and for a minimum of 5 years following account closure, in compliance with AML and regulatory record-keeping obligations.
• KYC documents: Retained for a minimum of 5 years from the date of verification or account closure, whichever is later.
• Transaction and financial records: Retained for a minimum of 5 years from the date of each transaction, as required under Philippine financial regulations.
• Gaming activity data: Retained for 3 years from the date of activity, or longer where required for responsible gaming monitoring or regulatory purposes.
• Communications and support records: Retained for 3 years from the date of the last communication.
• Marketing consent records: Retained until you withdraw consent, plus 1 year thereafter as evidence of prior consent.
• Technical and device logs: Retained for 12 months from the date of collection, unless required longer for security investigations.

When personal data is no longer required, suerph will securely delete or anonymize it in accordance with our internal data disposal procedures.

9. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the suerph platform.
• Encryption at rest for sensitive personal data stored on suerph servers, including KYC documents and payment details.
• Two-factor authentication (2FA) available to all suerph account holders to protect against unauthorized login.
• Access controls: Personal data is accessible only to suerph staff and service providers who require it to perform their specific functions, on a strict need-to-know basis.
• Regular security audits and penetration testing conducted by independent cybersecurity professionals.
• Fraud monitoring systems that detect and flag suspicious account activity in real time.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, suerph will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

10. Cookies & Tracking Technologies

suerph uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and deliver relevant content. The types of cookies we use are:

• Strictly necessary cookies: Essential for the suerph platform to function. These include session cookies that keep you logged in and security tokens that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics cookies: Help suerph understand how players use the platform — which pages are visited most, where players encounter issues, and how to improve the overall experience. Data collected is aggregated and anonymized where possible.
• Marketing cookies: Used to deliver relevant promotional content within the suerph platform based on your gaming activity and preferences. suerph does not use third-party advertising networks that track you across external websites.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the suerph platform. For strictly necessary cookies, no opt-out is available as they are required for the platform to operate.

11. Your Data Rights

Under the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by suerph:

• Right to be informed: You have the right to know what personal data suerph collects about you, why we collect it, and how it is used — as set out in this Privacy Policy.
• Right of access: You may request a copy of the personal data suerph holds about you, including your account information, transaction history, and KYC records.
• Right to rectification: If any personal data suerph holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You can update basic account details directly in your suerph account settings.
• Right to erasure: You may request that suerph delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations under Philippine law.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where you believe your rights and freedoms override those interests.
• Right to data portability: You may request that suerph provide your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to lodge a complaint: If you believe suerph has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Privacy Officer at [email protected] with the subject line "Data Privacy Request." suerph will respond to all verified requests within 5 business days. We may need to verify your identity before processing your request.

12. Minors & Age Restriction

The suerph platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine regulations governing online casino and sports betting activities. suerph does not knowingly collect personal data from individuals under the age of 21.

All suerph accounts are subject to age verification as part of the KYC process. If suerph discovers that personal data has been collected from a player who is under 21 years of age, we will immediately suspend the account, delete the personal data collected, and return any deposits at our discretion.

13. Changes to This Privacy Policy

suerph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform features. When material changes are made, suerph will notify registered players via email or an in-platform notification at least seven days before the changes take effect, where reasonably practicable.

The most current version of this Privacy Policy will always be available on this page, with the "Last Updated" date reflecting the date of the most recent revision. Your continued use of the suerph platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

If you do not agree with any amendment to this Privacy Policy, you must stop using the suerph platform and may request account closure in accordance with the Terms & Conditions.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way suerph handles your personal data, please contact our Data Privacy Officer through any of the following channels:

• Email: [email protected] — Subject: "Data Privacy Request"
• Live Chat: Available 24/7 via the suerph platform

For complaints that cannot be resolved through suerph's internal process, you may contact the National Privacy Commission (NPC) of the Philippines, the regulatory body responsible for enforcing the Data Privacy Act of 2012.