superace1 Privacy Policy

Introduction

superace1 is committed to protecting the privacy and personal data of every player who uses our platform. We understand that trust is the foundation of any relationship between a player and an online gaming operator, and we take our data protection obligations seriously. This Policy applies to all personal data collected through the superace1 website, mobile platform, customer support channels, and any other touchpoints through which you interact with superace1.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, which together govern your use of the superace1 platform. In the event of any conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, superace1 is the personal information controller responsible for the personal data collected through the superace1 platform. This means superace1 determines the purposes and means of processing your personal data.

superace1 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO at any time using the details provided in Section 14 of this Policy.

Data We Collect

3.1 Registration Data

When you create a superace1 account, we collect the following personal data: your full legal name, date of birth, residential address in the Philippines, email address, and mobile number. This information is required to create and maintain your account and to verify your identity in accordance with our KYC obligations.

3.2 Identity Verification (KYC) Data

To comply with Philippine anti-money laundering regulations and PAGCOR requirements, superace1 may collect copies of government-issued identification documents such as a Philippine passport, SSS ID, UMID, driver's license, or PhilSys national ID. We may also collect proof of address documents and proof of payment method ownership.

3.3 Financial Data

When you make deposits or request withdrawals, superace1 collects transaction data including payment method details (GCash account number, PayMaya account, BPI, BDO, or Metrobank account information), transaction amounts in Philippine Peso (PHP), and transaction timestamps. superace1 does not store full bank account credentials or card numbers on its servers.

3.4 Gaming Activity Data

superace1 collects data about your gaming activity on the platform, including game sessions played, wagers placed, wins and losses, bonus usage, and session durations. This data is used to operate the platform, detect fraud, and support responsible gaming monitoring.

3.5 Technical and Device Data

When you access the superace1 platform, we automatically collect certain technical data including your IP address, browser type and version, operating system, device type, screen resolution, and referring URL. This data is used for security monitoring, fraud prevention, and platform optimization.

3.6 Communications Data

If you contact superace1 customer support, we collect and retain records of your communications, including emails, live chat transcripts, and any documents you submit. This data is used to resolve your queries and improve our support services.

How We Collect Your Data

superace1 collects your personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions.
• Automatically: Through cookies, web beacons, and similar tracking technologies when you browse or use the superace1 platform. See Section 8 for details on our cookie practices.
• From third parties: From payment processors (GCash, PayMaya, BPI, BDO, Metrobank) when you conduct transactions, from KYC verification service providers, and from fraud prevention and analytics partners.
• From regulatory authorities: In certain circumstances, superace1 may receive information about you from PAGCOR or other Philippine regulatory bodies in connection with compliance obligations.

How We Use Your Data

superace1 uses your personal data for the following purposes:

• Account Management: To create, maintain, and operate your superace1 player account, including processing deposits and withdrawals in Philippine Peso.
• Identity Verification: To verify your identity and age (21+) in compliance with PAGCOR requirements and Philippine anti-money laundering laws.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the superace1 platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, session limits, and self-exclusion.
• Customer Support: To respond to your queries, complaints, and requests through our support channels.
• Legal Compliance: To comply with applicable Philippine laws and regulations, including the Anti-Money Laundering Act, the Data Privacy Act, and PAGCOR regulatory requirements.
• Platform Improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the superace1 platform.
• Marketing Communications: To send you promotional offers, bonuses, and updates about superace1 games and services, where you have consented to receive such communications. You may opt out at any time.

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, superace1 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you – specifically, to operate your superace1 account, process transactions, and provide gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including KYC and anti-money laundering obligations under the AMLA and PAGCOR regulatory requirements.
• Legitimate Interests: Processing is necessary for superace1's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and certain non-essential cookies, superace1 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.

Data Sharing & Disclosure

superace1 does not sell your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

7.1 Payment Processors

We share necessary financial data with GCash, PayMaya, BPI, BDO, and Metrobank to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial regulations.

7.2 KYC and Fraud Prevention Providers

We share identity documents and related data with third-party KYC verification and fraud prevention service providers to verify your identity and detect suspicious activity. These providers are contractually bound to process your data only on superace1's instructions and in accordance with applicable law.

7.3 Regulatory Authorities

superace1 may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other Philippine government authorities where required by law, court order, or regulatory directive.

7.4 Technology and Hosting Partners

superace1 uses third-party technology providers for platform hosting, data storage, analytics, and customer support infrastructure. These providers act as personal information processors on superace1's behalf and are bound by data processing agreements that require them to maintain appropriate security standards.

Cookies & Tracking Technologies

superace1 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit the superace1 website. We use the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the superace1 platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Performance and Analytics Cookies: These cookies collect anonymized data about how players use the superace1 platform, such as which pages are visited most frequently and how long sessions last. This data helps us improve platform performance.
• Functional Cookies: These cookies remember your preferences, such as your preferred language and display settings, to provide a more personalized experience.
• Marketing Cookies: With your consent, we may use cookies to deliver relevant promotional content about superace1 games and offers. You may opt out of marketing cookies at any time through your browser settings.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the superace1 platform.

Data Retention

superace1 retains your personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following retention periods:

• Account Data: Retained for the duration of your active account and for a minimum of 5 years after account closure, in accordance with Philippine anti-money laundering record-keeping requirements.
• KYC and Identity Documents: Retained for a minimum of 5 years from the date of submission or account closure, whichever is later, as required by the AMLA and PAGCOR regulations.
• Transaction Records: Retained for a minimum of 5 years from the date of each transaction.
• Customer Support Communications: Retained for 3 years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications, after which it will be deleted or anonymized within 30 days.

After the applicable retention period expires, superace1 will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

Data Security

superace1 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the superace1 platform is encrypted using industry-standard SSL/TLS protocols.
• Access Controls: Access to personal data is restricted to authorized superace1 personnel on a strict need-to-know basis. All access is logged and audited.
• Secure Data Storage: Personal data is stored on secure servers with physical and logical access controls, firewalls, and intrusion detection systems.
• Regular Security Audits: superace1 conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in our systems.
• Employee Training: All superace1 employees who handle personal data receive regular training on data protection obligations and security best practices.
• Incident Response: superace1 maintains a documented data breach response procedure. In the event of a breach, we will notify affected players and the National Privacy Commission as required by law.

Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by superace1:

• Right to be Informed: You have the right to be informed about how superace1 collects and processes your personal data. This Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data superace1 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 superace1 holds about you.
• 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 legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe superace1 has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. superace1 will respond to all data subject rights requests within 15 business days of receipt, in accordance with NPC guidelines.

Children's Privacy

The superace1 platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law and PAGCOR regulatory requirements. superace1 does not knowingly collect personal data from persons under the age of 21.

If superace1 discovers that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data, and report the matter to the appropriate authorities where required. If you believe a minor has registered on the superace1 platform, please notify us immediately at [email protected].

Updates to This Policy

superace1 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. When material changes are made, superace1 will notify registered players by email or via an in-platform notification at least 7 days before the changes take effect.

The effective date at the top of this Policy indicates when it was last updated. Your continued use of the superace1 platform after the effective date of any amendment constitutes your acceptance of the revised Policy. We recommend reviewing this page periodically to stay informed about how superace1 protects your personal data.

Contact & Data Protection Officer

If you have any questions, concerns, or complaints about this Privacy Policy or superace1's data processing practices, or if you wish to exercise your data subject rights, please contact our Data Protection Officer: