Contents
Summary: super291a Casino collects only the personal data necessary to operate a safe, compliant, and enjoyable gaming platform for Filipino players. We do not sell your personal data to third parties. We comply with the Republic Act No. 10173 — the Data Privacy Act of 2012 (DPA) — and its Implementing Rules and Regulations. By using super291a, you consent to the practices described in this Privacy Policy.
01 Introduction
This Privacy Policy ("Policy") describes how super291a Casino ("super291a," "we," "us," "our") collects, uses, stores, shares, and protects the personal information of users ("you," "Player," "Data Subject") who access or use the super291a Casino website, mobile platform, and all related services (collectively, the "Platform").
super291a Casino operates in the Philippines and is committed to full compliance with Republic Act No. 10173, the Data Privacy Act of 2012, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). This Policy applies to all personal data processed by super291a in connection with your use of the Platform, whether you are a registered player, a visitor, or a prospective user.
This Policy should be read together with our Terms & Conditions, which govern your use of the Platform. By registering an account or using any feature of super291a, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.
02 Personal Data We Collect
super291a collects the following categories of personal data, depending on how you interact with the Platform:
2.1 Registration & Identity Data
- Full legal name (as it appears on your government-issued ID);
- Date of birth (to verify the 21+ age requirement);
- Gender;
- Nationality and country of residence;
- Valid email address;
- Philippine mobile number.
2.2 Identity Verification (KYC) Data
- Copies of government-issued Philippine ID (UMID, PhilSys National ID, driver's license, or passport);
- Selfie or live photo for facial verification purposes;
- Proof of address (utility bill, bank statement, or similar document).
2.3 Financial Data
- GCash or PayMaya account number (last digits only — full account numbers are not stored);
- Bank account details for withdrawal processing (bank name, account name, account number);
- Transaction history: deposit amounts, withdrawal amounts, dates, and payment method used.
2.4 Gaming Activity Data
- Game history, bet amounts, win/loss records, and session durations;
- Bonus and promotion usage history;
- Responsible gaming tool settings (deposit limits, self-exclusion status).
2.5 Technical & Device Data
- IP address and approximate geographic location;
- Device type, operating system, and browser version;
- Session timestamps and login history;
- Cookies and similar tracking technologies (see Section 7).
2.6 Communications Data
- Records of live chat conversations with super291a support;
- Email correspondence;
- Feedback, complaints, and dispute records.
| Data Category | Examples | Required? |
|---|---|---|
| Identity | Name, date of birth, email, mobile | Mandatory |
| KYC / Verification | Government ID, selfie, proof of address | For withdrawals |
| Financial | GCash number, bank details, transactions | Mandatory |
| Gaming Activity | Bet history, session data, bonus usage | Automatic |
| Technical | IP address, device info, cookies | Automatic |
| Communications | Chat logs, emails, complaints | When applicable |
03 How We Collect Your Data
super291a collects personal data through the following means:
- Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions;
- Automatically — through cookies, web beacons, and server logs when you access and use the Platform (see Section 7);
- From third parties — from KYC verification providers, payment processors (GCash, PayMaya, banks), fraud prevention services, and regulatory authorities where required by law;
- From public sources — publicly available information used for identity verification or fraud prevention purposes.
04 How We Use Your Personal Data
super291a processes your personal data for the following purposes:
- Account creation and management — to register, verify, and maintain your super291a account;
- Age and identity verification — to confirm you meet the 21+ age requirement and to comply with KYC obligations;
- Payment processing — to process deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers;
- Game delivery — to provide access to casino games, live dealer tables, bingo rooms, and sports betting;
- Bonus and promotion administration — to apply, track, and manage promotional offers and wagering requirements;
- Responsible gaming — to enforce deposit limits, self-exclusion requests, and other player protection tools;
- Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, money laundering, and unauthorized account access;
- Regulatory compliance — to meet obligations under Philippine law, PAGCOR regulations, and the Data Privacy Act of 2012;
- Customer support — to respond to your queries, complaints, and disputes;
- Platform improvement — to analyze usage patterns and improve the super291a user experience;
- Marketing communications — to send you promotional offers and updates, where you have consented to receive them. You may opt out at any time.
05 Legal Basis for Processing
Under the Data Privacy Act of 2012, super291a processes your personal data on the following legal bases:
- Contractual necessity — processing required to perform the contract between you and super291a (account registration, payment processing, game delivery);
- Legal obligation — processing required to comply with Philippine law, PAGCOR regulations, anti-money laundering requirements, and NPC directives;
- Legitimate interests — processing for fraud prevention, platform security, and responsible gaming enforcement, where these interests are not overridden by your rights;
- Consent — processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
06 Data Sharing & Disclosure
super291a does not sell your personal data to third parties. We may share your data with the following categories of recipients only where necessary and lawful:
6.1 Service Providers
Third-party vendors who assist in operating the Platform, including KYC verification providers, payment processors (GCash, PayMaya, BPI, BDO, and other Philippine banks), cloud hosting providers, and customer support platforms. These providers are contractually bound to process your data only on super291a's instructions and in compliance with the DPA.
6.2 Game Providers
Licensed game software providers may receive limited technical data (such as player session tokens) necessary to deliver game content. Game providers do not receive your full identity or financial data.
6.3 Regulatory & Law Enforcement Authorities
super291a may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities where required by law, court order, or regulatory directive.
6.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer.
We do not sell, rent, or trade your personal data to advertisers, data brokers, or any other third party for commercial purposes.
07 Cookies & Tracking Technologies
super291a uses cookies and similar technologies to operate the Platform, remember your preferences, and analyze usage. The following types of cookies are used:
| Cookie Type | Purpose | Required? |
|---|---|---|
| Essential | Session management, login authentication, security tokens | Always active |
| Functional | Language preferences, game settings, responsible gaming tool states | Optional |
| Analytics | Aggregated usage statistics to improve Platform performance | Optional |
| Marketing | Personalized promotional content (only with your consent) | Consent-based |
You may manage your cookie preferences through your browser settings. Disabling essential cookies may affect Platform functionality. Non-essential cookies are only activated upon your consent via the cookie preference banner displayed on your first visit.
08 Data Retention
super291a retains your personal data only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law. The following retention periods apply:
- Account and identity data — retained for the duration of your account and for a minimum of 5 years after account closure, in compliance with PAGCOR and AMLC record-keeping requirements;
- Financial transaction records — retained for a minimum of 5 years from the date of each transaction, as required by the Anti-Money Laundering Act;
- KYC documents — retained for the duration of your account and for 5 years post-closure;
- Gaming activity logs — retained for 2 years from the date of each session;
- Support communications — retained for 3 years from the date of the last interaction;
- Marketing consent records — retained until you withdraw consent, plus 1 year thereafter.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC guidelines.
09 Data Security
super291a implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:
- SSL/TLS encryption — all data transmitted between your device and super291a servers is encrypted using industry-standard TLS protocols;
- Two-factor authentication (2FA) — available for all player accounts to prevent unauthorized login;
- Access controls — personal data is accessible only to authorized super291a personnel on a strict need-to-know basis;
- Secure data storage — data is stored on servers with physical and logical access controls, regular security audits, and intrusion detection systems;
- Payment data tokenization — full payment account numbers are never stored on super291a servers; only tokenized references are retained;
- Regular security assessments — super291a conducts periodic vulnerability assessments and penetration testing of its systems.
Despite these measures, no system is completely immune to security risks. In the event of a personal data breach that is likely to result in serious harm to you, super291a will notify the National Privacy Commission and affected players within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.
10 Your Data Privacy Rights
Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by super291a:
- Right to be informed — you have the right to know what personal data super291a collects and how it is used, as described in this Policy;
- Right of access — you may request a copy of the personal data super291a 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 legal retention obligations;
- Right to object — you may object to the processing of your personal data for direct marketing purposes at any time;
- Right to data portability — you may request a copy of your personal data in a structured, commonly used, machine-readable format;
- Right to lodge a complaint — you have the right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.
To exercise any of the above rights, please contact super291a's Data Protection Officer (DPO) via live chat or by email at the address provided in Section 15. super291a will respond to all verified data subject requests within 15 business days of receipt.
Identity verification is required before processing any data subject request to ensure we do not disclose your data to unauthorized parties.
11 Children's Privacy
super291a Casino is strictly intended for persons who are 21 years of age or older, in accordance with PAGCOR regulations applicable to online casino platforms in the Philippines. super291a does not knowingly collect personal data from persons under 21 years of age.
If super291a becomes aware that personal data has been collected from a person under 21, the account will be immediately suspended, all data will be deleted, and any funds deposited will be returned to the originating payment method after verification. If you believe a minor has registered on super291a, please contact support immediately via live chat.
12 International Data Transfers
super291a primarily processes and stores personal data on servers located within or accessible from the Philippines. Where data is transferred to service providers located outside the Philippines (for example, cloud infrastructure or game software providers), super291a ensures that such transfers are subject to appropriate safeguards, including contractual data processing agreements that require the recipient to maintain data protection standards equivalent to those required under the Data Privacy Act of 2012.
super291a will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your explicit consent or without implementing appropriate contractual safeguards.
13 Third-Party Links
The super291a Platform may contain links to third-party websites or services (for example, payment provider portals). This Privacy Policy applies only to super291a Casino and does not cover the privacy practices of any third-party websites. super291a is not responsible for the content or privacy practices of third-party sites. We encourage you to review the privacy policies of any third-party services you access.
14 Updates to This Privacy Policy
super291a reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. Material changes will be communicated to registered players via email or in-platform notification at least 7 days before taking effect.
The "Last Updated" date at the top of this page indicates when the most recent revision was made. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with any changes, you may request account closure in accordance with our Terms & Conditions.
15 Contact & Data Protection Officer
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact super291a's Data Protection Officer:
Data Protection Officer — super291a Casino
Email: [email protected]
Live Chat: Available 24/7 via the super291a Platform. Average response time under 3 minutes.
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.