srpl99 Privacy Policy

01 Overview

srpl99 ("we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who interact with the srpl99 platform. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in connection with your use of srpl99.

This policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission of the Philippines. It also reflects applicable guidelines from PAGCOR with respect to player data handling in the online gaming context.

By accessing or using the srpl99 platform, you consent to the collection and processing of your personal data as described in this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of the srpl99 platform immediately.

02 Data Controller

For the purposes of the Data Privacy Act of 2012, srpl99 acts as the Personal Information Controller (PIC) with respect to the personal data of its registered players and platform visitors. This means srpl99 determines the purposes and means by which your personal data is processed.

Where srpl99 engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, or cloud infrastructure providers — those parties act as Personal Information Processors (PIPs) and are bound by data processing agreements that require them to handle your data in accordance with this policy and applicable Philippine law.

03 Personal Data We Collect

srpl99 collects personal data through several channels, including account registration, identity verification, platform usage, and customer support interactions. The categories of personal data we collect include:

srpl99 does not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data, health information, or political affiliations.

04 How We Use Your Personal Data

srpl99 uses the personal data it collects for the following purposes:

• Account Management: To create, maintain, and administer your srpl99 player account, including processing your registration and verifying your identity.
• KYC and Age Verification: To verify that you meet the minimum age requirement of 21 years and to comply with Know Your Customer obligations under Philippine anti-money laundering regulations.
• Payment Processing: To process PHP deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Platform Operation: To deliver the games, features, and services available on srpl99, including live casino, slots, bingo, and other game categories.
• Regulatory Compliance: To comply with obligations under Philippine law, including reporting requirements to PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission.
• Responsible Gaming: To monitor gaming behaviour and apply responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion where requested or required.
• Customer Support: To respond to your inquiries, complaints, and support requests submitted via live chat or email.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct on the platform.
• Platform Improvement: To analyse usage patterns and technical data in order to improve the performance, reliability, and user experience of the srpl99 platform.
• Communications: To send you account-related notifications, transaction confirmations, and — where you have opted in — promotional communications about srpl99 offers and games.

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, srpl99 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and srpl99 — specifically, to operate your player account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering laws, PAGCOR licensing requirements, and NPC data privacy regulations.
• Legitimate Interests: Processing is necessary for srpl99's legitimate interests in operating a secure, fair, and compliant gaming platform, including fraud prevention and platform security, provided those interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending promotional communications or using non-essential cookies — srpl99 relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

06 Data Sharing and Disclosure

srpl99 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, solely to facilitate PHP deposits and withdrawals on your behalf.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to assist with player identity checks and document verification.
• Cloud and IT Infrastructure Providers: Hosting, database, and security service providers who process data on srpl99's behalf under binding data processing agreements.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies, where disclosure is required by law or court order.
• Professional Advisers: Legal counsel, auditors, and compliance consultants, where necessary and subject to professional confidentiality obligations.

07 Data Retention

srpl99 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under the Anti-Money Laundering Act.
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session.
• Customer Support Communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Technical and Log Data: Retained for up to twelve (12) months, unless required for longer periods for security investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with srpl99's data disposal procedures.

08 Data Security

srpl99 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption of personal and financial data in transit using TLS/SSL protocols and at rest using industry-standard encryption algorithms.
• Role-based access controls limiting access to personal data to authorised personnel on a strict need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of the srpl99 platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While srpl99 takes all reasonable steps to protect your data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your srpl99 account credentials and for notifying us immediately of any suspected unauthorised access.

09 Cookies and Tracking Technologies

srpl99 uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file placed on your device when you visit the srpl99 website. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function correctly, including maintaining your login session and enabling secure transactions. These cannot be disabled.
• Performance Cookies: Collect anonymised data about how players use the platform — such as pages visited and error messages encountered — to help us improve platform performance.
• Functional Cookies: Remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Analytics Cookies: Used to understand aggregate player behaviour and platform usage patterns. Data collected is anonymised and used solely for internal analysis.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the srpl99 platform. srpl99 does not use cookies to serve third-party advertising or to track your activity across other websites.

10 Your Data Subject Rights

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

• Right to Be Informed: The right to be informed about how your personal data is collected and processed, as set out in this Privacy Policy.
• Right of Access: 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: The right to request correction of any inaccurate or incomplete personal data held by srpl99.
• Right to Erasure: 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: 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: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

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 accordance with NPC guidelines.

11 Minors and Age Restriction

The srpl99 platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gaming law. srpl99 does not knowingly collect personal data from individuals under the age of 21.

If srpl99 becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately closed, all associated data will be deleted or anonymised, and any deposits will be returned in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor has provided personal data to srpl99, please contact our Data Protection Officer immediately using the details in Section 14.

12 Cross-Border Data Transfers

In certain circumstances, srpl99 may transfer personal data to service providers or infrastructure partners located outside the Philippines — for example, where cloud hosting or technical support services are provided by entities based in other jurisdictions.

Where such transfers occur, srpl99 ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under Philippine law. srpl99 will not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining your consent.

13 Updates to This Privacy Policy

srpl99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material, srpl99 will notify registered players via the contact details on file at least fourteen (14) days before the changes take effect. For non-material changes — such as clarifications or corrections — the updated policy will be published on this page without prior notice.

Your continued use of the srpl99 platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how srpl99 protects your personal data.

14 Contact & Data Protection Officer

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 designated Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe that srpl99 has not handled your personal data in accordance with the Data Privacy Act of 2012. Information about how to file a complaint with the NPC is available through official Philippine government channels.