srpl99 Privacy
Policy

This Privacy Policy applies to all personal data collected, processed, and stored by srpl99 in connection with your use of the srpl99 website at srpl99.net, including all associated services, games, features, promotions, and customer support interactions (collectively, the "Platform").

This policy applies to all users of the srpl99 Platform, including registered account holders, visitors who browse the Platform without registering, and individuals who interact with srpl99 through customer support channels. It covers personal data collected through the website, through our mobile-optimized interface, and through any other digital touchpoint operated by srpl99.

This Privacy Policy should be read together with srpl99's Terms & Conditions, which govern your overall use of the Platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters relating to personal data, this Privacy Policy shall prevail.

srpl99 may update this Privacy Policy from time to time. The most current version will always be available at srpl99.net/privacy-policy. We encourage you to review this policy periodically to stay informed of how we handle your personal data.

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), srpl99 acts as the Personal Information Controller (PIC) with respect to the personal data of its users. As the PIC, srpl99 determines the purposes and means of processing your personal data.

srpl99 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with RA 10173 and this Privacy Policy. The DPO can be contacted using the details provided in Section 14 of this policy.

srpl99 operates under the oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and complies with all applicable data protection requirements imposed by PAGCOR as part of its licensing and regulatory framework.

srpl99 collects personal data from you in several ways: directly when you provide it to us, automatically when you use the Platform, and from third parties where permitted by law. The categories of personal data we collect include:

srpl99 does not collect sensitive personal information beyond what is strictly necessary for identity verification, fraud prevention, and compliance with PAGCOR and Anti-Money Laundering (AML) regulations. We do not collect information about your race, religion, political opinions, or health status unless specifically required by law.

srpl99 processes your personal data only for specific, legitimate purposes. We do not use your data in ways that are incompatible with the purposes for which it was originally collected. The primary purposes for which we process your personal data are:

• Account Registration & Management: To create and maintain your srpl99 account, verify your identity, and manage your account settings and preferences.
• Service Delivery: To provide you with access to all games, betting markets, and features available on the srpl99 Platform.
• Payment Processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card in Philippine Peso (₱).
• KYC & AML Compliance: To verify your identity and comply with PAGCOR requirements, the Anti-Money Laundering Act (RA 9160), and related regulations.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized access, and other security threats to the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor gaming behavior, enforce self-exclusion requests, and implement deposit limits and other responsible gaming tools.
• Marketing & Promotions: To send you information about srpl99 promotions, bonuses, and new features — but only where you have given your consent or where we have a legitimate interest to do so.
• Legal Compliance: To comply with applicable Philippine laws, court orders, and regulatory requirements, including reporting obligations to PAGCOR and the Anti-Money Laundering Council (AMLC).
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the overall user experience on the srpl99 Platform.

srpl99 will not use your personal data for automated decision-making that produces legal or similarly significant effects without your knowledge, except where required by law or where you have given explicit consent.

Under the Philippine Data Privacy Act of 2012 (RA 10173), srpl99 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and srpl99 — i.e., to provide you with the gaming services you have registered for. This covers account creation, payment processing, and service delivery.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests: Processing is necessary for srpl99's legitimate business interests, including fraud prevention, platform security, and improving our services — provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — srpl99 relies on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

srpl99 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions.
• KYC & Identity Verification Providers: Third-party identity verification services that assist srpl99 in verifying the authenticity of your identity documents.
• Game Content Providers: Licensed game providers whose games are available on the srpl99 Platform may receive limited technical data necessary to deliver their games.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law or regulation.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or other legal process.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and fraud detection service providers who process data on srpl99's behalf under strict data processing agreements.

All third parties with whom srpl99 shares personal data are required to handle that data in accordance with RA 10173 and are bound by contractual obligations that prohibit them from using your data for any purpose other than the specific service they provide to srpl99.

srpl99 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 and PAGCOR regulations. The following general retention periods apply:

Upon expiry of the applicable retention period, srpl99 will securely delete or anonymize your personal data in accordance with its data disposal procedures. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

srpl99 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the srpl99 Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including passwords and financial information, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to srpl99 personnel and authorized third parties who have a legitimate need to access it. Role-based access controls and multi-factor authentication are enforced for all internal systems.
• Intrusion Detection: srpl99 employs real-time intrusion detection and prevention systems to monitor for and respond to unauthorized access attempts and other security threats.
• Regular Security Audits: srpl99 conducts regular security assessments, penetration testing, and vulnerability scans to identify and remediate potential security weaknesses.
• Data Breach Response: srpl99 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, srpl99 will notify the National Privacy Commission (NPC) within 72 hours and affected users without undue delay, as required by RA 10173.

srpl99 uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain your session, and analyze Platform usage. A cookie is a small text file placed on your device by a website you visit.

The types of cookies used by srpl99 include:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as user authentication, session management, and security. These cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: These cookies remember your preferences and settings (such as language preference and display settings) to provide a more personalized experience.
• Analytics Cookies: These cookies collect anonymized information about how users interact with the Platform, helping srpl99 understand usage patterns and improve the Platform. Analytics data is aggregated and does not identify individual users.
• Marketing Cookies: These cookies are used to deliver relevant promotional content. They are only placed with your consent and can be withdrawn at any time through your browser settings or by contacting srpl99 support.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the srpl99 Platform. For more information on managing cookies, refer to your browser's help documentation.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by srpl99:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data srpl99 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data srpl99 holds about you.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to srpl99's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe srpl99 has violated your data privacy rights.

To exercise any of these rights, please contact srpl99's Data Protection Officer using the contact details in Section 14. srpl99 will respond to all data subject requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with notice provided to you.

The srpl99 Platform is strictly intended for adults aged 21 years and above. This is the minimum legal age for casino-style gambling in the Philippines. srpl99 does not knowingly collect personal data from individuals under the age of 21.

During the registration process, all users are required to confirm that they are at least 21 years of age. srpl99 conducts age verification as part of its KYC process and will suspend any account where the account holder is found to be under 21 years of age. Any personal data collected from a minor will be deleted immediately upon discovery.

In certain circumstances, srpl99 may transfer your personal data to recipients located outside the Philippines — for example, to cloud infrastructure providers or game content providers whose servers are located in other jurisdictions.

Where such transfers occur, srpl99 ensures that appropriate safeguards are in place to protect your personal data in accordance with RA 10173. These safeguards may include:

• Contractual clauses that require the recipient to protect your personal data to a standard equivalent to RA 10173.
• Transfers to countries that have been assessed by the National Privacy Commission (NPC) as providing an adequate level of data protection.
• Binding corporate rules where the recipient is part of the same corporate group as srpl99.

srpl99 will not transfer your personal data to jurisdictions that do not provide adequate data protection safeguards without your explicit consent, except where required by Philippine law.

srpl99 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, srpl99 will update the effective date at the top of this page and, where appropriate, notify registered users via email or an in-platform notification.

Your continued use of the srpl99 Platform after any changes to this Privacy Policy have been posted constitutes your acknowledgment of the updated policy. If you do not agree with the changes, you should stop using the Platform and may request account closure in accordance with the Terms & Conditions.

We encourage you to review this Privacy Policy periodically. The most current version will always be available at srpl99.net/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by srpl99, please contact our Data Protection Officer (DPO):

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 on the srpl99 Platform after logging in to your account.
• Response Time: srpl99 aims to respond to all privacy-related inquiries within 5 business days and all formal data subject requests within 30 days.

If you are not satisfied with srpl99's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing RA 10173.