suerte99 Privacy Policy

1 About This Policy

This Privacy Policy ("Policy") applies to all personal data collected by suerte99 in connection with the suerte99 platform, website (suerte99.app), mobile interface, games, promotions, customer support interactions, and all related services. It explains how suerte99 handles the personal information of registered players, website visitors, and prospective customers across the Philippines.

This Policy is issued in compliance with Republic Act No. 10173 (Data Privacy Act of 2012) of the Philippines and its Implementing Rules and Regulations, as well as relevant guidelines issued by the National Privacy Commission (NPC). It should be read alongside suerte99's Terms & Conditions and Responsible Gaming Policy.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, suerte99 acts as the personal information controller in respect of data collected through the suerte99 platform. suerte99 determines the purposes and means by which your personal data is processed.

suerte99 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy law. The DPO may be contacted at [email protected] with "Data Privacy" in the subject line.

3 Data We Collect

suerte99 collects personal data in the following categories, depending on how you interact with the platform:

suerte99 does not intentionally collect sensitive personal information (as defined under the Philippine Data Privacy Act) beyond what is required for KYC and PAGCOR compliance, such as government-issued ID data. Such sensitive data is handled with heightened security measures.

4 How We Use Your Data

suerte99 uses the personal data we collect for the following purposes:

• Account Management — Creating, maintaining, and securing your suerte99 account; processing logins; enabling password resets;
• Identity & Age Verification — Confirming you meet the 21+ age requirement and verifying your identity in accordance with PAGCOR's regulatory requirements;
• Transaction Processing — Processing deposits and withdrawals via GCash, Maya, BPI, BDO, and other accepted payment channels;
• Regulatory Compliance — Meeting obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160), the Data Privacy Act (RA 10173), and other applicable Philippine regulations;
• Fraud Prevention & Security — Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and other prohibited conduct;
• Customer Support — Responding to inquiries, complaints, and support requests submitted to suerte99's support team;
• Platform Improvement — Analysing aggregated usage data to improve suerte99's website, games, and user experience;
• Marketing Communications — Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications;
• Responsible Gaming — Monitoring gaming behavior to identify potential gambling harm indicators and reaching out to players in accordance with suerte99's Responsible Gaming commitments.

suerte99 does not use your data for automated decision-making that produces significant legal effects on you without human review, except for fraud and AML screening systems where regulatory obligations require automated flagging.

5 Legal Bases for Processing

suerte99 processes your personal data on one or more of the following lawful bases under the Philippine Data Privacy Act:

• Contract Performance — Processing necessary to provide you with the suerte99 service, including account management, game access, and payment processing;
• Legal Obligation — Processing required to comply with PAGCOR licensing conditions, AMLC reporting requirements, tax obligations, and other Philippine legal requirements;
• Legitimate Interests — Processing for fraud prevention, platform security, and service improvement where these interests are not overridden by your privacy rights;
• Consent — Processing for marketing communications, where you have given explicit opt-in consent. You may withdraw consent at any time by updating your communication preferences in your suerte99 account settings or by contacting support.

6 Data Sharing

suerte99 does not sell your personal data to third parties. We share personal data only in the following limited circumstances:

• Service Providers — suerte99 engages third-party processors (payment processors, KYC verification providers, cloud hosting providers, analytics services) under strict data processing agreements that prohibit use of your data for purposes other than providing services to suerte99;
• Regulatory Authorities — suerte99 discloses data to PAGCOR, the AMLC, the NPC, and other Philippine government authorities where required by law or where suerte99 is compelled by a valid legal order;
• Game Providers — Limited technical data (session tokens, bet logs) is shared with game software providers (such as JILI, Pragmatic Play, Evolution Gaming) solely for the purpose of operating games you play on suerte99;
• Business Transfers — In the event of a merger, acquisition, or sale of suerte99's business, your personal data may be transferred as part of that transaction, subject to equivalent privacy protections.

7 Cookies & Tracking Technologies

suerte99 uses cookies and similar tracking technologies on its website and mobile interface. These are small data files stored on your device that help suerte99 operate its platform effectively. The types of cookies suerte99 uses include:

• Essential Cookies — Required for the platform to function. These include session authentication tokens that keep you logged into your suerte99 account. These cannot be disabled without affecting your ability to use suerte99.
• Performance Cookies — Anonymous analytics data that helps suerte99 understand how players navigate the platform, which games are most popular, and where technical issues occur.
• Functionality Cookies — Store your preferences, such as language settings and last-visited game categories, to improve your suerte99 experience on return visits.
• Marketing Cookies — Used to personalise promotional content shown to you on the suerte99 platform, where you have provided consent for targeted communications.

You may control cookie settings through your browser preferences. Note that disabling essential cookies will impair or prevent your use of the suerte99 platform.

8 Data Retention

suerte99 retains personal data for as long as is necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods required by Philippine law:

• Account and Identity Data — Retained for a minimum of 5 years from account closure, in compliance with PAGCOR's record-keeping requirements and the AMLC's anti-money laundering regulations;
• Transaction Records — Retained for a minimum of 10 years in compliance with Republic Act 9160 (Anti-Money Laundering Act);
• KYC Documents — Retained for the duration of the customer relationship and for 5 years following account closure;
• Marketing Preferences — Retained until you withdraw consent or close your account, whichever is earlier;
• Support Communications — Retained for 3 years from the date of the interaction.

Following the expiry of applicable retention periods, suerte99 will securely delete or anonymise your personal data in accordance with its data destruction procedures.

9 Data Security

suerte99 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the suerte99 platform;
• Encryption at rest for sensitive stored data, including payment information and KYC documents;
• Role-based access controls ensuring only authorized suerte99 personnel can access personal data, on a need-to-know basis;
• Multi-factor authentication for internal administrative access to systems that process player data;
• Regular security assessments and penetration testing of suerte99's infrastructure;
• Incident response procedures for detecting and responding to personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, suerte99 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act.

10 Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by suerte99:

• Right to be Informed — You have the right to know what personal data suerte99 holds about you and how it is processed;
• Right of Access — You have the right to request a copy of the personal data suerte99 holds about you;
• Right to Rectification — You have the right to request correction of inaccurate or incomplete personal data;
• Right to Erasure (Right to be Forgotten) — You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to suerte99's legal obligations to retain certain records;
• Right to Data Portability — You have the right to receive your personal data in a structured, commonly used format;
• Right to Object — You may object to processing of your personal data for direct marketing purposes at any time;
• Right to Lodge a Complaint — If you believe suerte99 has mishandled your personal data, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, contact suerte99 at [email protected] with "Data Privacy Request" in the subject line. suerte99 will respond within 30 days. Note that some requests may be declined where processing is required for legal compliance or to defend legal claims.

11 Children's Privacy

The suerte99 platform is strictly intended for individuals aged 21 years and older in accordance with PAGCOR's minimum age requirement for online gaming in the Philippines. suerte99 does not knowingly collect personal data from individuals under the age of 21.

If suerte99 becomes aware that it has collected personal data from an individual under the age of 21, it will immediately close the associated account, void any balances subject to verification, and delete the relevant personal data. If you believe a minor has registered on suerte99, please notify us immediately at [email protected].

12 Changes to This Policy

suerte99 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Material changes — those that significantly affect your rights or how suerte99 uses your data — will be communicated to registered players via email notification and an in-platform notice at least 14 days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of suerte99 after the effective date of any revised Policy constitutes your acknowledgement of the updated terms.

13 Contact & Data Protection Officer

For all privacy-related inquiries, data subject rights requests, or concerns about suerte99's handling of your personal data, please contact suerte99's Data Protection Officer at:

• Email: [email protected] — subject line: "Data Privacy"
• Response Time: Within 30 calendar days of receiving your request

If you are not satisfied with suerte99's response to your privacy inquiry, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). The NPC handles complaints related to violations of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.