supreph Privacy Policy

1Introduction

supreph ("we," "us," or "our") is committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by supreph in connection with your use of the supreph platform available at supreph.net (the "Platform").

This Policy is issued in accordance with and governed by the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC) of the Philippines. It also takes into account our obligations under PAGCOR's regulatory framework for licensed online gaming operators serving Filipino players.

Please read this Policy carefully before using the supreph Platform. By registering an account, accessing the Platform, or otherwise providing personal data to supreph, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree, please discontinue use of the Platform immediately.

2Who We Are

supreph is an online gaming platform operating under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and serving players located within the Philippines. The Platform offers a range of gaming services including online slots, live casino tables powered by Playtech and other licensed providers, sports betting covering PBA, NBA, UFC, boxing and international markets, sabong, and bingo.

For the purposes of the Philippine Data Privacy Act, supreph acts as the Personal Information Controller (PIC) in respect of all personal data collected through the Platform. This means supreph determines the purposes and means of processing your personal data and is legally responsible for ensuring that processing complies with RA 10173.

Third-party game providers, payment processors, and identity verification services engaged by supreph who process data on our behalf act as Personal Information Processors (PIP) under binding data processing agreements that require them to handle your data only in accordance with our documented instructions and to maintain standards at least equivalent to those required under Philippine law.

3Data We Collect

supreph collects personal data from you in the course of providing the Platform and its services. The categories of data we collect are outlined in the table below:

4How We Collect Your Data

supreph collects personal data through the following channels:

4.1 Directly from You

• When you register an account on the supreph Platform (name, date of birth, contact details);
• When you complete KYC verification and submit identity documents;
• When you make a deposit or request a withdrawal (payment account details);
• When you contact our support team via live chat or email;
• When you set responsible gaming limits, cooling-off periods, or request self-exclusion;
• When you participate in promotions, surveys, or feedback requests.

4.2 Automatically During Platform Use

• Technical data such as IP address, device identifiers, browser type, and session information collected automatically as you navigate the Platform;
• Gaming activity data generated as you play games on supreph;
• Cookies and similar tracking technologies (see Section 9 for full details).

4.3 From Third Parties

• Identity verification service providers who assist with KYC document authentication;
• Payment processors (GCash, Maya, BPI, BDO, Metrobank, and others) who confirm transaction details;
• Fraud prevention and AML screening services that cross-reference your data against regulatory watchlists;
• PAGCOR or other Philippine regulatory authorities where we are legally required to receive or share information.

5How We Use Your Data

supreph processes your personal data only where we have a lawful basis to do so under RA 10173. The primary lawful bases we rely upon are: fulfillment of our contractual obligations to you, compliance with our legal and regulatory obligations, and your consent (particularly for marketing communications). In limited circumstances, we also rely on legitimate interests where these are not overridden by your rights and freedoms.

• Account Management: Creating and maintaining your supreph account, processing login and authentication, and administering your profile settings;
• Age & Identity Verification: Confirming that you meet the mandatory 21+ age requirement for casino-style gaming in the Philippines, and verifying your identity as required by PAGCOR and AML regulations;
• Payment Processing: Facilitating deposits via GCash, Maya, BPI, BDO, Metrobank, and other channels, and processing your withdrawal requests back to your verified payment method;
• Regulatory Compliance: Meeting our obligations under PAGCOR licensing conditions, the Philippine Anti-Money Laundering Act (RA 9160, as amended), and applicable NPC data privacy regulations;
• Fraud & Security: Detecting and preventing fraudulent activity, multi-accounting, bonus abuse, and unauthorised access to your account;
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling indicators, administering self-exclusion and limit tools, and complying with PAGCOR responsible gaming standards;
• Platform Improvement: Analysing aggregated, anonymised usage data to improve game offerings, platform performance, and user experience for Filipino players;
• Marketing & Promotions: Sending you information about supreph bonuses, promotions, and new game releases — but only where you have given your explicit consent and subject to your right to withdraw consent at any time;
• Customer Support: Responding to your queries, complaints, and support requests, and maintaining records of communications for quality assurance purposes;
• Legal Claims: Establishing, exercising, or defending legal claims arising from your use of the supreph Platform.

6Sharing Your Data

supreph does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We share personal data only in the limited circumstances described below, and always subject to contractual protections that require recipients to handle your data in accordance with applicable Philippine privacy law.

6.1 Service Providers & Processors

We engage trusted third-party service providers to assist us in operating the Platform. These include:

• Payment processors: GCash, Maya, GrabPay, BPI, BDO, Metrobank, and other Philippine payment channels — to facilitate deposits and withdrawals;
• KYC & identity verification providers: To authenticate government-issued IDs and verify that players meet the 21+ requirement;
• Game software providers: Including Playtech and other licensed studios — limited technical data is shared to facilitate game session delivery;
• Fraud prevention & AML screening services: To monitor transactions and screen accounts against Philippine and international sanctions lists;
• Cloud hosting & IT infrastructure providers: Who store Platform data on secure servers in compliance with our data protection requirements.

6.2 Regulatory & Legal Disclosure

supreph may disclose personal data to regulatory and law enforcement authorities where required to do so by Philippine law, a valid court order, or PAGCOR directive. This includes mandatory reporting under the Anti-Money Laundering Act and cooperation with NPC investigations into data privacy complaints.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of supreph's business or assets, personal data held on the Platform may be transferred to the acquiring entity as part of that transaction, subject to the incoming entity assuming the same data protection obligations as supreph under this Policy.

7Data Retention

supreph retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with our legal and regulatory obligations, and to resolve disputes or enforce our agreements. Specific retention periods are governed by Philippine law requirements, including:

• Account & KYC data: Retained for a minimum of five (5) years after account closure, as required by PAGCOR licensing conditions and AML regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with the Anti-Money Laundering Act;
• Customer support records: Retained for three (3) years from the date of the last communication, for quality assurance and dispute resolution purposes;
• Gaming activity logs: Retained for three (3) years for responsible gaming monitoring and regulatory audit purposes;
• Marketing preference records: Retained until you withdraw your consent or request deletion, whichever is earlier.

Once the applicable retention period has expired, personal data is securely deleted or anonymised so that it can no longer be linked to you as an individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

8Security Measures

supreph takes the security of your personal data seriously. We implement a comprehensive set of technical, organisational, and physical security measures designed to protect your data against unauthorised access, accidental loss, destruction, or disclosure. Key security measures include:

• Encryption in transit: All data transmitted between your device and the supreph Platform is encrypted using TLS (Transport Layer Security) protocols;
• Encryption at rest: Sensitive personal data — including KYC documents, financial records, and authentication credentials — is encrypted at rest using industry-standard AES-256 encryption;
• Access controls: Access to personal data within supreph is restricted on a strict need-to-know basis. Staff with access to player data undergo background checks and are bound by confidentiality obligations;
• Multi-factor authentication: Internal systems containing player data are protected by multi-factor authentication requirements for all supreph staff;
• Continuous monitoring: supreph employs 24/7 automated monitoring and intrusion detection systems to identify and respond to potential security threats in real time;
• Regular security audits: The Platform undergoes periodic independent security assessments and penetration testing to identify and remediate vulnerabilities;
• Incident response: supreph maintains a data breach response plan. In the event of a personal data breach that poses a real risk to Filipino players, we will notify affected individuals and the NPC within the timeframes required by RA 10173.

9Cookies & Tracking Technologies

supreph uses cookies and similar tracking technologies (including local storage and session tokens) to operate the Platform, improve your experience, and comply with our security and responsible gaming obligations. A cookie is a small text file placed on your device when you visit the Platform.

9.1 Types of Cookies We Use

9.2 Managing Cookies

You can manage or delete cookies through your browser settings. Note that disabling strictly necessary cookies will impair the functionality of the supreph Platform, including your ability to log in and maintain an active session. Performance and functional cookies may be disabled without affecting core Platform access. For detailed instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

supreph does not use third-party advertising cookies or share cookie-derived data with advertising networks for behavioural targeting purposes.

10Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights as a data subject in relation to the personal data supreph holds about you. These rights are in addition to any other rights you may have under Philippine consumer protection or gaming regulations.

Please note that certain rights are subject to legal limitations. For example, supreph cannot erase transaction records that we are legally required to retain under AML regulations, and we cannot delete account data while a withdrawal claim or regulatory investigation remains open.

11Minors & Age Policy

The supreph Platform is strictly intended for use by individuals aged 21 years and above, in accordance with Philippine gaming regulations governing casino-style online gambling. supreph enforces a zero-tolerance policy toward underage access to the Platform.

supreph does not knowingly collect personal data from any person under the age of 21. If supreph discovers or is notified that personal data has been collected from a minor, we will:

• Immediately suspend the associated account;
• Permanently delete all personal data associated with the minor from our systems;
• Refund any deposits made, at supreph's discretion, in accordance with our Terms and Conditions;
• Report the incident to PAGCOR as required by our licensing obligations.

If you are a parent or guardian and believe your child (under 21) has registered on the supreph Platform, please contact us immediately via live chat or email so we can take swift corrective action.

12Cross-Border Data Transfers

Some of supreph's service providers — including cloud infrastructure providers and game software vendors such as Playtech — may process personal data outside of the Philippines. Where such cross-border transfers occur, supreph ensures that:

• The recipient country provides an adequate level of protection for personal data, or
• The transfer is governed by binding contractual clauses that impose data protection obligations on the recipient equivalent to those required under Philippine law, or
• The transfer is otherwise authorised under RA 10173 and applicable NPC guidelines.

supreph will not transfer personal data internationally in circumstances where we cannot ensure an adequate level of protection for your rights as a Philippine data subject. If you have questions about specific international transfer arrangements, you may contact our Data Protection Officer for details.

13Changes to This Privacy Policy

supreph reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made, we will notify registered players via:

• A prominent notice displayed on the supreph Platform upon your next login;
• An email notification to your registered email address (where material changes affect your rights or how we process your data); and/or
• An updated "Last Updated" date at the top of this Policy page.

Your continued use of the supreph Platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the revised Policy, you should discontinue use of the Platform and may request account closure by contacting our support team.

We encourage you to review this Privacy Policy periodically so that you remain informed about how supreph is protecting your personal data. The current version will always be accessible at supreph.net/privacy-policy.

14Contact & Data Protection Officer

supreph has appointed a Data Protection Officer (DPO) in compliance with the requirements of the Philippine Data Privacy Act. The DPO is responsible for overseeing supreph's data protection strategy and implementation, ensuring compliance with RA 10173, and serving as the primary point of contact for data privacy matters — including requests from data subjects and inquiries from the National Privacy Commission.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by supreph, you may contact our DPO through the following channels: