scatterph Privacy Policy

1. Introduction

scatterph ("scatterph," "we," "us," or "our") operates the online gaming platform accessible at scatterph.org. We are committed to protecting the privacy and personal data of all users ("you," "Player," or "User") who access or use our Platform.

This Privacy Policy ("Policy") describes how scatterph collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform. It also explains your rights as a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

By registering for an account, accessing the Platform, or using any scatterph service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

2. Personal Data We Collect

scatterph collects personal data that you provide directly, data generated through your use of the Platform, and data received from third parties. The categories of personal data we collect include:

Data You Provide Directly:

• Registration Data: Full name, date of birth, nationality, gender, residential address (including city, e.g., Manila, Cebu, Davao, Quezon City, Makati), email address, and mobile number.
• Identity Verification (KYC) Data: Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence), proof of address, and selfie photographs submitted for identity verification purposes.
• Financial Data: Payment method details including GCash account numbers, PayMaya account details, BPI, BDO, or Metrobank account information used for deposits and withdrawals. Note: scatterph does not store full card numbers or banking credentials.
• Communications Data: Messages, emails, and chat transcripts exchanged with our support team.
• Responsible Gaming Data: Self-exclusion requests, deposit limit settings, and session control preferences.

Data Collected Automatically:

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, betting history, session duration, click patterns, and navigation paths within the Platform.
• Location Data: General geographic location derived from your IP address, used to verify eligibility and comply with jurisdictional restrictions.
• Cookie Data: Data collected through cookies and similar tracking technologies as described in Section 6 of this Policy.

Data from Third Parties:

• Identity verification data from third-party KYC service providers.
• Fraud prevention and anti-money laundering screening data from compliance service providers.
• Payment confirmation data from payment processors including GCash, PayMaya, and banking partners.

3. How We Use Your Personal Data

scatterph uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your scatterph account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to the Platform's games, betting markets, and features, and to process your deposits, withdrawals, and bonus claims.
• Identity Verification & KYC: To verify your identity and age (21+) in compliance with applicable Philippine law and regulatory requirements, and to prevent underage gambling.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Regulatory Compliance: To comply with our obligations under Philippine law, including the DPA, anti-money laundering regulations, and PAGCOR regulatory requirements.
• Customer Support: To respond to your enquiries, resolve complaints, and provide technical assistance.
• Responsible Gaming: To implement and manage responsible gaming tools including deposit limits, self-exclusion, and session reminders, and to identify players who may be at risk of problem gambling.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the functionality, performance, and user experience of the Platform.
• Marketing Communications: To send you promotional offers, bonuses, and news about scatterph, where you have provided consent to receive such communications. You may opt out at any time.
• Legal Proceedings: To establish, exercise, or defend legal claims in connection with the Platform or your account.

4. Legal Basis for Processing

scatterph processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and scatterph (i.e., the Terms and Conditions), including account management, game access, and transaction processing.
• Legal Obligation: Processing is necessary to comply with scatterph's legal obligations under Philippine law, including KYC requirements, anti-money laundering obligations, and PAGCOR regulatory requirements.
• Legitimate Interests: Processing is necessary for scatterph's legitimate interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and interests.
• Consent: For certain processing activities, such as marketing communications and non-essential cookies, scatterph relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

5. Data Sharing & Disclosure

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

• Service Providers: Third-party vendors who provide services on our behalf, including KYC and identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), IT infrastructure providers, and customer support platforms. These providers are contractually bound to process your data only as instructed by scatterph and in accordance with applicable data protection law.
• Regulatory Authorities: Philippine government agencies and regulatory bodies, including PAGCOR and the Anti-Money Laundering Council (AMLC), where disclosure is required by law or regulation.
• Law Enforcement: Law enforcement agencies, courts, or other public authorities where disclosure is required by a valid legal order, warrant, or applicable law.
• Fraud Prevention Agencies: Third-party fraud prevention and compliance screening services used to detect and prevent financial crime on the Platform.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of scatterph's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third parties with whom scatterph shares personal data are required to maintain appropriate technical and organisational security measures and to process data only for the specified purposes.

6. Cookies & Tracking Technologies

scatterph uses cookies and similar tracking technologies (such as web beacons and pixel tags) to operate and improve the Platform. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cookies cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymised information about how players use the Platform, such as which pages are visited most frequently and how long sessions last. This data helps us improve the Platform's performance and user experience.
• Functional Cookies: Used to remember your preferences and settings, such as your preferred language and display options, to provide a more personalised experience.
• Marketing Cookies: Used to deliver relevant promotional content and to measure the effectiveness of our marketing campaigns. These cookies are only set with your consent.

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

7. Data Retention

scatterph retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering regulations and PAGCOR requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• KYC Documents: Identity verification documents are retained for the period required by applicable Philippine law, typically five (5) years from the end of the business relationship.
• Support Communications: Customer support records are retained for up to three (3) years from the date of the last interaction.
• Marketing Data: Retained until you withdraw consent or opt out of marketing communications, after which it is deleted or anonymised.

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

8. Data Security

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

• Encryption: All data transmitted between your device and the Platform is encrypted using 256-bit SSL/TLS technology. Sensitive data stored on our servers is encrypted at rest.
• Access Controls: Access to personal data is restricted to authorised personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Firewalls & Intrusion Detection: scatterph employs enterprise-grade firewalls, intrusion detection systems, and continuous security monitoring to protect the Platform's infrastructure.
• Regular Security Audits: The Platform undergoes regular security assessments and penetration testing by qualified third-party security professionals.
• Incident Response: scatterph maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) and affected individuals in accordance with the DPA's breach notification requirements.

While scatterph takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the security of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

9. Your Rights as a Data Subject

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

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Policy.
• Right of Access: You have the right to request a copy of the personal data scatterph 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 we hold about you. You may update certain account information directly through your account settings.
• 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 scatterph's legal and regulatory retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time by contacting our support team.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: If you believe scatterph has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details provided in Section 13 of this Policy. We will respond to all verified requests within the timeframe required by applicable law.

10. Children & Minors

The scatterph Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine law applicable to casino-style gaming. scatterph does not knowingly collect personal data from individuals under the age of 21.

If scatterph becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any winnings accrued by an underage player will be forfeited.

If you are a parent or guardian and believe that your child has provided personal data to scatterph, please contact our support team immediately so that we can take appropriate action.

11. Third-Party Links

The scatterph Platform may contain links to third-party websites or services for informational purposes. scatterph is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

This Policy applies solely to personal data collected and processed by scatterph through the Platform. It does not apply to data collected by third-party payment processors, identity verification providers, or any other external services, which are governed by their own privacy policies.

12. Changes to This Privacy Policy

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

When material changes are made to this Policy, scatterph will take reasonable steps to notify registered players, which may include posting a prominent notice on the Platform or sending a notification to your registered email address. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how scatterph protects your personal data.

13. Contact & Data Protection Officer

scatterph has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests regarding this Policy or the processing of your personal data, please contact us:

• Data Protection Officer, scatterph
• Email: [email protected]
• General Support: [email protected]

Our support and DPO team are available 24/7 to assist players across the Philippines — whether you're based in Manila, Cebu, Davao, Quezon City, or anywhere else in the country.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.