suerte99 Privacy Policy

1.1 suerte99 is committed to protecting the privacy and personal data of all players, visitors, and users of the suerte99 platform. This Privacy Policy describes the categories of personal data we collect, the purposes for which we process it, the parties with whom we may share it, and the measures we take to keep it secure.

1.2 This Policy applies to all personal data collected through or in connection with: (a) the suerte99 website at suerte99.vip; (b) the suerte99 account registration and login process; (c) all gaming, wagering, and financial transactions conducted on the Platform; (d) communications between players and the suerte99 support team; and (e) marketing communications sent by suerte99 to players who have opted in.

1.3 By using suerte99, you acknowledge that you have read this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform and may request account closure by contacting support.

1.4 This Policy should be read in conjunction with the suerte99 Terms & Conditions. In the event of any conflict between the two documents in relation to data privacy matters, this Privacy Policy shall prevail.

2.1 For the purposes of the Philippine Data Privacy Act of 2012, suerte99 acts as the Personal Information Controller (PIC) with respect to the personal data of players and users of the Platform.

2.2 As Personal Information Controller, suerte99 determines the purposes and means of processing player personal data. Where suerte99 engages third-party service providers to process data on its behalf, those parties act as Personal Information Processors (PIPs) under documented contractual arrangements that require them to process data only on suerte99's instructions and in compliance with the Data Privacy Act.

2.3 suerte99 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. The DPO may be contacted at [email protected].

suerte99 collects personal data in the following categories:

suerte99 collects personal data through the following means:

• Direct Provision: Information you provide when registering, completing identity verification, making a deposit or withdrawal, contacting support, or submitting a complaint or feedback;
• Platform Activity: Data generated automatically by your use of the suerte99 platform, including game sessions, wagers, login events, and navigation behaviour;
• Payment Processors: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers used for deposit or withdrawal processing;
• Identity Verification Partners: Results and flags from third-party KYC and age verification service providers engaged by suerte99;
• Cookies and Tracking Technologies: Technical data collected automatically through cookies, web beacons, and similar technologies when you access suerte99.vip (see Section 7);
• Fraud Detection Systems: Automated analysis of platform usage patterns for the purpose of detecting suspicious activity, bonus abuse, or violations of the Terms & Conditions.

5.1 suerte99 processes personal data on the following lawful bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing required to perform the contract between suerte99 and the Player — including account registration, gaming services, payment processing, and customer support;
• Legal Obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws;
• Legitimate Interests: Processing for fraud prevention, security, platform improvement, and abuse detection, where such interests are not overridden by the Player's fundamental rights;
• Consent: Processing for direct marketing communications, where the Player has provided explicit opt-in consent.

5.2 The primary purposes for which suerte99 processes personal data are:

• Creating, managing, and maintaining Player accounts;
• Verifying the identity and age (21+) of Players in compliance with PAGCOR requirements;
• Processing deposits and withdrawals via GCash, PayMaya, and other accepted Philippine payment methods;
• Delivering gaming services and personalising the Platform experience;
• Detecting and preventing fraud, money laundering, collusion, and other prohibited activity;
• Fulfilling responsible gaming obligations, including monitoring for problem gambling indicators;
• Responding to Player support queries and resolving disputes;
• Meeting regulatory reporting obligations to PAGCOR and other Philippine authorities;
• Sending opted-in Players relevant promotional communications about suerte99 offers.

6.1 suerte99 does not sell, rent, or commercially trade Player personal data to any third party. Personal data is shared only in the circumstances described below:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment processors receive the minimum data necessary to process deposit and withdrawal transactions;
• Identity Verification Partners: KYC and age verification service providers receive identity documents and biometric data strictly for the purpose of account verification;
• Game Providers: JILI, Pragmatic Play, PG Soft, and other game providers may receive anonymised or pseudonymised session data for technical and RNG audit purposes;
• Fraud Prevention Services: Fraud detection platform providers receive technical and behavioural data under strict data processing agreements;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies receive data as required by applicable law or regulatory instruction;
• Legal Proceedings: Personal data may be disclosed to courts, law enforcement, or legal advisors where required by a court order, subpoena, or applicable law;
• Business Transfers: In the event of a merger, acquisition, or business restructuring involving suerte99, Player data may be transferred to the successor entity, subject to the same privacy protections as described in this Policy.

6.2 All third parties with whom suerte99 shares personal data are contractually required to process that data only for the specified purpose, to maintain appropriate security measures, and to comply with the Philippine Data Privacy Act.

7.1 suerte99 uses cookies and similar tracking technologies on suerte99.vip for the following purposes:

• Strictly Necessary Cookies: Required for the Platform to function, including session management, login authentication, and security. These cannot be disabled without affecting Platform functionality;
• Functional Cookies: Store your preferences such as language settings, responsible gaming limits, and game history to improve your suerte99 experience;
• Analytics Cookies: Collect anonymised data about how players use suerte99.vip to help us improve Platform performance and user experience;
• Security Cookies: Support fraud detection and abuse prevention by identifying unusual access patterns on suerte99 accounts.

7.2 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the suerte99 Platform. Disabling other cookies may reduce personalisation features but will not prevent access to core Platform functions.

7.3 suerte99 does not use third-party advertising or retargeting cookies. No Player data is shared with advertising networks or data brokers through cookie technology.

8.1 suerte99 implements appropriate technical and organisational security measures to protect Player personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between the Player's device and suerte99 servers;
• Encryption at rest for stored personal and financial data;
• Password hashing using industry-standard algorithms — suerte99 staff cannot view Player passwords;
• Role-based access controls limiting employee access to Player data strictly on a need-to-know basis;
• Regular security audits and vulnerability assessments of the suerte99 Platform infrastructure;
• Two-factor authentication available on Player accounts and mandatory for suerte99 administrative access;
• Network security controls including firewalls and intrusion detection systems.

8.2 While suerte99 employs robust security measures, no internet-based service can guarantee absolute security. Players should also take responsibility for the security of their own suerte99 account credentials and should never share their login information with any third party.

9.1 suerte99 retains Player personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Philippine law and regulatory obligation, whichever is longer.

9.2 The following retention periods apply to the principal categories of Player data:

• Account and Identity Data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AMLA obligations;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA record-keeping requirements;
• Gaming Session Data: Retained for a minimum of five (5) years for regulatory reporting purposes;
• Support Communications: Retained for three (3) years from the date of the communication for dispute resolution and quality assurance;
• Technical and Log Data: Retained for a minimum of twelve (12) months for security and fraud investigation purposes;
• Marketing Consent Records: Retained for the duration of the opt-in period plus three (3) years as evidence of consent.

9.3 Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised in accordance with suerte99's data destruction procedures. Anonymised aggregate data may be retained indefinitely for analytical and reporting purposes, as it no longer constitutes personal data.

10.1 As a data subject under the Philippine Data Privacy Act of 2012, Filipino players and all users of suerte99 have the following rights in relation to their personal data:

10.2 To exercise any of the above rights, please contact the suerte99 Data Protection Officer at [email protected]. suerte99 will respond to verified data rights requests within thirty (30) calendar days of receipt.

10.3 Players also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if they believe suerte99 has processed their personal data in violation of the Data Privacy Act of 2012.

11.1 suerte99 performs mandatory age verification as part of the account registration process. Any account found to belong to a person under 21 will be immediately suspended and all personal data associated with that account will be deleted in accordance with this Policy, except where retention is required for regulatory reporting or legal purposes.

11.2 If suerte99 becomes aware that personal data of a person under 21 has been inadvertently collected, it will take immediate steps to delete that data. If you believe that a minor under 21 has accessed or registered on the suerte99 Platform, please contact [email protected] or [email protected] immediately.

12.1 suerte99 may send Players information about promotions, bonuses, new games, and other platform updates via email or SMS where the Player has explicitly opted in to receive such communications during registration or through their account settings.

12.2 Players may withdraw consent to receive marketing communications at any time by updating their communication preferences in their suerte99 account settings, or by contacting the support team.

12.3 Transactional and account communications — such as deposit confirmations, withdrawal notifications, security alerts, identity verification requests, and responsible gaming reminders — are not marketing communications and will be sent to all registered Players regardless of their marketing preferences, as they are necessary for the operation of the Player's account.

12.4 suerte99 does not engage in unsolicited bulk messaging. Marketing communications are sent only to Players who have provided explicit consent and only for products and services offered by suerte99.

13.1 The suerte99 Platform integrates third-party services including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), game providers (JILI, Pragmatic Play, PG Soft, and others), and identity verification partners. These third parties operate under their own privacy policies. suerte99 is not responsible for the privacy practices of third-party services once you interact with them directly outside of the suerte99 platform environment.

13.2 All third-party service providers engaged by suerte99 are subject to due diligence assessments and are contractually required to maintain data protection standards consistent with the Philippine Data Privacy Act and suerte99's own data protection requirements.

14.1 suerte99 primarily processes and stores Player data within the Philippines. Where the engagement of third-party service providers — such as international game providers or technology partners — results in personal data being processed outside the Philippines, suerte99 ensures that appropriate safeguards are in place in compliance with the Data Privacy Act's requirements for cross-border data transfers.

14.2 Such safeguards may include contractual clauses requiring the recipient to maintain an equivalent level of data protection, and verification that the recipient jurisdiction provides an adequate level of protection for personal data. suerte99 maintains a record of all international data transfers involving Player personal data.

15.1 suerte99 reserves the right to update or amend this Privacy Policy at any time in response to changes in applicable law, regulatory requirements, or Platform operations. The current version of this Policy, together with its effective date, is always accessible at suerte99.vip/privacy-policy.

15.2 Where a material change to this Policy affects the way suerte99 processes existing Player personal data, suerte99 will provide reasonable notice to affected Players via email or in-platform notification prior to the change taking effect, and will seek fresh consent where required by the Data Privacy Act.

15.3 Players are encouraged to review this Privacy Policy periodically to remain informed of how suerte99 handles their personal data. Continued use of the Platform following publication of an updated Policy constitutes acceptance of the revised terms, subject to any consent requirements noted above.

16.1 For all privacy-related enquiries, data subject rights requests, or concerns about how suerte99 processes your personal data, please contact the suerte99 Data Protection Officer:

16.2 For general account or support queries unrelated to data privacy, please contact the suerte99 support team at [email protected] or via the 24/7 live chat facility on suerte99.vip (average response: 3–5 minutes).

16.3 Players who are not satisfied with suerte99's response to a privacy complaint have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.