super291 Privacy Policy

1 Introduction

super291 Casino takes the privacy and security of your personal information seriously. This Privacy Policy ("Policy") sets out in clear terms how we collect, use, store, share, and protect the personal data of players and visitors who use super291.vip and any related services operated by super291.

This Policy applies to all personal data collected through: the super291 website at super291.vip; the super291 mobile platform; communications between you and super291 customer support; and any other interaction you have with super291 as a registered player or site visitor.

Please read this Policy carefully. If you do not agree with the practices described here, you should not use super291. This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal information is:

super291 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO directly for privacy-related enquiries at the email address listed in Section 15 of this Policy.

3 Personal Data We Collect

super291 collects the following categories of personal data, depending on how you interact with our platform:

3.1 Registration & Identity Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, Makati)
• Email address and mobile number
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• Government-issued ID (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys ID)
• Proof of address documents
• Selfie or facial verification image (where required)
• Source of funds documentation (where required by AML regulations)

3.3 Financial Data

• GCash or PayMaya account reference (not full credentials)
• Philippine bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, or other)
• Debit card details (card number masked; only last 4 digits retained)
• Transaction history: deposits, withdrawals, and bonus activity

3.4 Gaming & Activity Data

• Game history, bet amounts, win/loss records
• Session duration and login timestamps
• Responsible gaming tool usage (deposit limits, self-exclusion requests)
• Bonus and promotion participation records

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser
• Cookie identifiers and session tokens
• Referring URL and pages visited on super291.vip

3.6 Communications Data

• Live chat transcripts with super291 customer support
• Email correspondence with super291
• Feedback, complaints, and dispute records

4 How We Collect Your Data

super291 collects 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: When you browse super291.vip, our servers and analytics tools automatically record technical data such as your IP address, device type, browser, and pages visited. Cookies and similar tracking technologies also collect data automatically — see Section 8 for details.
• From third parties: super291 may receive data from KYC verification providers, payment processors (e.g., GCash, PayMaya, Philippine banks), fraud detection services, and PAGCOR or other regulatory authorities where required by law.
• From your use of our games: Game providers integrated into super291 may share gameplay data with us for the purpose of operating your account, resolving disputes, and detecting fraud.

5 How We Use Your Personal Data

super291 uses your personal data for the following purposes:

• Account management: To create, verify, and maintain your super291 player account, including processing your registration and KYC verification.
• Service delivery: To provide access to games, process deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers, and deliver customer support.
• Legal compliance: To comply with PAGCOR regulations, the Philippine Data Privacy Act, Anti-Money Laundering Act (AMLA), and other applicable Philippine laws. This includes verifying your identity, monitoring transactions for suspicious activity, and reporting to regulatory authorities where required.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, and other prohibited conduct on super291.
• Responsible gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling.
• Communications: To send you account-related notifications, transaction confirmations, and — where you have opted in — promotional communications about super291 offers and games.
• Platform improvement: To analyse usage patterns, fix technical issues, and improve the super291 platform experience for all Filipino players.
• Dispute resolution: To investigate and resolve complaints, chargebacks, and disputes relating to your super291 account.

6 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, super291 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to when registering your super291 account — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA requirements, KYC obligations, and other applicable Philippine laws.
• Legitimate interests: Processing necessary for super291's legitimate business interests, including fraud prevention, platform security, and service improvement — provided these interests are not overridden by your privacy rights.
• Consent: Where we rely on your consent — for example, for marketing communications — you may withdraw that consent at any time by contacting super291 support or updating your account preferences.

7 Data Sharing & Disclosure

super291 does not sell your personal data. We may share your data with the following categories of recipients only where necessary and lawful:

• Payment processors: GCash, PayMaya, and Philippine banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist super291 in verifying your identity and age in compliance with PAGCOR and AMLA requirements.
• Game providers: Licensed game studios and live dealer providers whose games are integrated into super291, to the extent necessary to operate those games and resolve disputes.
• Fraud and security services: Third-party providers that help super291 detect and prevent fraudulent activity, money laundering, and account abuse.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers engaged by super291, subject to strict confidentiality obligations.

All third parties with whom super291 shares personal data are required to handle that data securely and in accordance with applicable Philippine data protection law. super291 does not transfer personal data outside the Philippines except where required by law or with appropriate safeguards in place.

8 Cookies & Tracking Technologies

super291 uses cookies and similar tracking technologies on super291.vip to improve your experience and operate the platform effectively. The following types of cookies are used:

• Essential cookies: Required for the basic operation of super291.vip, including maintaining your login session, remembering your language preference, and enabling secure transactions. These cannot be disabled without affecting platform functionality.
• Analytics cookies: Used to collect anonymised data about how visitors use super291.vip — such as which pages are visited most frequently and how long sessions last. This data helps us improve the platform.
• Functional cookies: Used to remember your preferences and personalise your super291 experience, such as your preferred game categories or responsible gaming settings.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and account abuse on super291.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may prevent you from accessing certain features of super291. By continuing to use super291.vip, you consent to our use of cookies as described in this Policy.

9 Data Retention

super291 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active super291 account, plus a minimum of five (5) years after account closure, as required by PAGCOR regulations and AMLA obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA and tax record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years after account closure or the completion of the relevant transaction, whichever is later.
• Gaming activity data: Retained for the duration of your account plus three (3) years after closure, for dispute resolution and regulatory audit purposes.
• Customer support communications: Retained for three (3) years from the date of the communication.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter as evidence of consent.

When personal data is no longer required, super291 will securely delete or anonymise it in accordance with our data disposal procedures.

10 Data Security

super291 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and super291.vip.
• Encrypted storage of sensitive data including passwords (hashed with bcrypt) and financial account references.
• Access controls: Personal data is accessible only to super291 staff and systems that require it to perform their functions, on a strict need-to-know basis.
• Regular security audits and penetration testing of super291's systems and infrastructure.
• Two-factor authentication (2FA) available to all players to protect their super291 accounts.
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC requirements.

While super291 takes all reasonable steps to protect your data, no system is completely immune to security risks. You also play a role in keeping your account secure — please use a strong, unique password for your super291 account and enable 2FA.

11 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by super291:

• Right to be informed: The right to know what personal data super291 collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data super291 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data in your super291 account.
• Right to erasure: The right to request deletion of your personal data, subject to super291's legal obligations to retain certain data (e.g., under AMLA and PAGCOR regulations).
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe super291 has violated your data privacy rights.

To exercise any of these rights, please contact super291's Data Protection Officer using the contact details in Section 15. super291 will respond to all data rights requests within thirty (30) days of receipt, as required by Philippine law.

12 Children's Privacy

super291 Casino is strictly for adults aged 21 years and above, in compliance with Philippine law governing casino-style gambling. super291 does not knowingly collect personal data from individuals under the age of 21.

If super291 discovers that personal data has been collected from a person under 21, that account will be immediately suspended, all associated data will be deleted, and any funds in the account will be handled in accordance with our Terms & Conditions and applicable law.

If you believe a minor has registered on super291, please contact us immediately at [email protected] so we can take prompt action.

13 Third-Party Links

super291.vip may contain references to third-party services such as payment providers (GCash, PayMaya) and game studios. These third parties operate their own privacy policies, which are independent of super291's Privacy Policy.

super291 is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of super291.

14 Updates to This Privacy Policy

super291 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will update the "Last updated" date at the top of this page and, where appropriate, notify registered players via email or in-platform notification.

Your continued use of super291 following the posting of any updates constitutes your acceptance of the revised Privacy Policy. We recommend reviewing this page periodically to stay informed of how super291 protects your data.

15 Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data held by super291, please contact our Data Protection Officer:

super291 aims to respond to all privacy-related enquiries within 30 days of receipt. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through its official channels.