suerte99 Privacy Policy

1. Data Controller

For the purposes of the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and all implementing rules and regulations issued by the National Privacy Commission ("NPC"), suerte99 ("Company," "we," "us," or "our") is the data controller responsible for your personal information collected through the suerte99 platform at suerte99.org (the "Platform").

By registering an account or using any part of the suerte99 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing, and use of your personal data as described herein.

2. Data We Collect

suerte99 collects personal data in the following categories:

suerte99 does not collect sensitive personal information (as defined under the DPA) unless required for identity verification or compliance purposes, in which case it is handled with heightened security measures.

3. How We Use Your Data

suerte99 processes your personal data for the following purposes:

• Account management: To create, verify, and maintain your suerte99 account, including identity and age verification required under applicable regulations.
• Service delivery: To provide access to games, process deposits and withdrawals in Philippine Peso, and manage your account balance.
• Regulatory compliance: To comply with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, and applicable Philippine law and gaming regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, cheating, and other misconduct.
• Customer support: To respond to your inquiries, resolve disputes, and improve support quality.
• Responsible gaming: To monitor gaming behavior and apply responsible gaming tools where warranted, in accordance with the suerte99 Responsible Gaming Policy.
• Marketing communications: To send you promotional offers, bonuses, and updates about suerte99 where you have provided consent or where permitted by applicable law. You may opt out at any time.
• Platform improvement: To analyze aggregated usage data for performance optimization, feature development, and user experience improvement.

4. Legal Basis for Processing

suerte99 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the suerte99 Terms & Conditions, including account management, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, gaming regulations, and tax obligations.
• Legitimate interests: Processing conducted in pursuit of suerte99's legitimate business interests, including fraud prevention, security monitoring, and platform improvement, where those interests are not overridden by your rights.
• Consent: Processing based on your explicit consent, particularly in relation to marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

5. Data Sharing and Disclosure

suerte99 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data in the following limited circumstances:

• Service providers: Third-party companies that process data on our behalf, including payment processors (GCash, Maya, BPI, BDO, and other partners), identity verification providers, cloud hosting providers, and customer support platforms. All such providers are contractually bound to process data only as instructed by suerte99 and to maintain appropriate security standards.
• Regulatory and law enforcement authorities: Where required by law, court order, or competent Philippine government authority, including PAGCOR, the Anti-Money Laundering Council (AMLC), or the National Privacy Commission.
• Business transfers: In the event of a merger, acquisition, or sale of assets involving suerte99, your data may be transferred to the successor entity, subject to equivalent privacy protections.
• Fraud prevention networks: Shared fraud signals may be exchanged with other licensed operators or industry fraud prevention services to protect the integrity of the gaming ecosystem.

Any third party receiving your data is required to handle it in accordance with applicable data protection law and suerte99's data processing standards.

6. Data Retention

suerte99 retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

• Account and identity data is retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with Philippine AML and tax record-keeping obligations.
• Financial transaction records are retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications are retained for three (3) years from the date of each interaction.
• Marketing consent records are retained until consent is withdrawn plus a reasonable period for compliance documentation purposes.

When retention periods expire, suerte99 will securely delete or anonymize your personal data in accordance with applicable standards.

7. Data Security

suerte99 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and suerte99 servers.
• Encryption at rest for sensitive data stored on suerte99 infrastructure.
• Role-based access controls ensuring that suerte99 personnel access personal data only to the extent required for their specific role.
• Regular security audits and vulnerability assessments of the suerte99 Platform.
• Two-factor authentication (2FA) available for all player accounts.

Despite these measures, no system is entirely immune to security incidents. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, suerte99 will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act and NPC Circular 16-03.

8. Cookies and Tracking Technologies

suerte99 uses cookies and similar tracking technologies on the Platform. These include:

• Strictly necessary cookies: Required for the Platform to function, including session authentication and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, displayed currency, and game lobby layout.
• Analytics cookies: Help suerte99 understand how players interact with the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Marketing cookies: Used to deliver relevant promotional content to you where consent has been provided.

You can manage non-essential cookies through your browser settings. Note that disabling certain cookies may affect Platform functionality. For full details on cookies used by suerte99, refer to the cookie management settings accessible within your account.

9. Your Data Rights

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by suerte99:

• Right to be informed: The right to know whether suerte99 holds personal data about you and how it is processed.
• Right of access: The right to obtain a copy of your personal data in a structured, commonly used format.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected.
• 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 legal retention obligations.
• Right to object: The right to object to the processing of your personal data, including for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a portable format and to transmit it to another data controller where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact the suerte99 Data Protection Officer at: [email protected]. Requests will be acknowledged within 72 hours and responded to within 30 days, in accordance with NPC guidelines.

10. Minors

The suerte99 Platform is strictly intended for persons aged 21 years or older. suerte99 does not knowingly collect or process personal data of individuals below this age. If suerte99 discovers that personal data has been collected from a person under 21, the account will be suspended immediately, all related data deleted, and any funds held subject to regulatory review. If you believe a minor has registered on suerte99, please contact us immediately at [email protected].

11. International Data Transfers

suerte99 may transfer your personal data to service providers or partners located outside the Philippines where necessary to deliver our services. Any such transfer will be conducted in compliance with the Data Privacy Act of 2012 and NPC guidelines, ensuring that adequate safeguards are in place — including contractual data protection clauses — to protect your personal information to a standard equivalent to Philippine data protection requirements.

12. Changes to This Privacy Policy

suerte99 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Where changes are material, we will provide advance notice via email or on-platform notification. The updated Privacy Policy will display a revised "Last Updated" date at the top of this page. Your continued use of the suerte99 Platform following the effective date of any change constitutes your acceptance of the revised policy.

13. Contact & Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by suerte99, please contact our Data Protection Officer:

Email: [email protected]

suerte99 is committed to resolving privacy concerns promptly and transparently. If you are not satisfied with our response, you have the right to escalate your concern to the National Privacy Commission of the Philippines.