33superph Privacy Policy

33superph collects the following categories of personal data from players and users of the Platform:

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Philippine mobile number
• Email address
• Username and encrypted password
• Residential address (province, city, barangay)

• Government-issued photo ID (e.g., PhilSys ID, passport, driver's license, UMID, SSS ID, Voter's ID)
• Selfie or live photo for facial verification purposes
• Proof of address documents where required
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account)

• Deposit and withdrawal transaction records
• Payment method details (GCash number, PayMaya number, bank account details — stored in masked form)
• Transaction amounts, dates, and reference numbers
• Bonus and promotional credit history

• Game session logs including games played, bets placed, and outcomes
• Wagering history and account balance records
• Responsible gaming settings and self-exclusion records

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and login history
• Cookie identifiers and similar tracking technologies

• Records of live chat conversations with our support team
• Email correspondence with 33superph
• Feedback, complaints, and dispute records

33superph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from payment processors; geolocation data from IP intelligence services used to enforce jurisdictional restrictions.

33superph uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Registration data, identity data
Age and identity verification (KYC)	KYC documents, date of birth, selfie
Processing deposits and withdrawals	Financial data, payment method details
Providing gaming services and maintaining game records	Gaming activity data, account data
Fraud prevention and anti-money laundering compliance	All categories as required
Customer support and dispute resolution	Communications data, account data
Responsible gaming monitoring and intervention	Gaming activity, responsible gaming settings
Sending transactional notifications (deposit confirmations, withdrawal updates)	Contact data, transaction data
Platform security and technical maintenance	Technical and device data
Legal and regulatory compliance	All categories as required by law

33superph does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by our fraud prevention and AML compliance obligations.

Under the Data Privacy Act of 2012, 33superph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws, including AML regulations, PAGCOR requirements, and tax obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.

33superph does not sell, rent, or trade your personal data to third parties for marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist with document verification and fraud detection.
• Game software providers: Game studios and platform providers whose games are offered on 33superph, to the extent required for game operation and fairness auditing.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or regulatory obligation.
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order, warrant, or subpoena.
• IT and cloud service providers: Hosting, security, and infrastructure providers who process data on our behalf under strict data processing agreements.

All third parties with whom 33superph shares personal data are required to handle such data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the one for which it was shared.

33superph 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 Platform. We use the following types of cookies:

• Strictly necessary cookies: Required for the Platform to function, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits.
• Analytics cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Security cookies: Used for fraud detection, bot prevention, and platform integrity monitoring.

You may manage non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 33superph Platform.

33superph retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Gaming activity logs: Retained for a minimum of three (3) years.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Self-exclusion records: Retained indefinitely to prevent re-registration by excluded players.

When personal data is no longer required, 33superph will securely delete or anonymize it in accordance with our data disposal procedures.

33superph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 33superph Platform
• Encryption of sensitive data at rest, including payment method details and identity documents
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular security assessments and penetration testing of the Platform
• Multi-factor authentication for administrative access to systems containing personal data
• Continuous monitoring for suspicious activity and unauthorized access attempts

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 33superph:

• Right to be informed: You have the right to know what personal data 33superph collects about you and how it is used.
• Right of access: You may request a copy of the personal data 33superph holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: You may request a copy of 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) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer via the contact details provided in Section 14 of this Privacy Policy. We will respond to all verified requests within thirty (30) days in accordance with applicable law.

33superph is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on 33superph or provided us with personal data, please contact our support team immediately so we can investigate and take appropriate action.

Some of the third-party service providers used by 33superph, including cloud infrastructure providers, KYC verification services, and game software providers, may process your personal data outside of the Philippines. Where such cross-border transfers occur, 33superph ensures that appropriate safeguards are in place to protect your personal data, including contractual data processing agreements that require the recipient to apply data protection standards equivalent to those required under Philippine law.

By using the 33superph Platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

33superph reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this page. Where practicable, we will also notify registered players of significant changes via the Platform or by SMS to the registered mobile number.

Your continued use of the 33superph Platform following the posting of any changes to this Privacy Policy constitutes your acceptance of the revised policy. We encourage you to review this page periodically to stay informed about how we protect your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by 33superph, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 on the 33superph Platform on Philippine Standard Time
• Response Time: We aim to respond to all data privacy requests within 30 days

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with our response to your data privacy concern.