sureph Privacy Policy
At sureph, your personal data belongs to you. This Privacy Policy explains exactly what information we collect when you use the sureph platform, why we collect it, how we protect it, and what rights you have as a Filipino player under applicable Philippine data privacy laws.
Data Security First
sureph uses industry-standard SSL encryption and secure data storage to protect every piece of personal information you share with us. Your data is never sold to third parties.
Philippine Data Privacy Act
sureph complies with Republic Act No. 10173 — the Data Privacy Act of 2012 — and the regulations issued by the National Privacy Commission (NPC) of the Philippines.
Your Rights as a Data Subject
As a sureph player, you hold the right to access, correct, erase, and object to the processing of your personal data at any time, in accordance with the Philippine Data Privacy Act.
Transparent Data Collection
We only collect data that is necessary to operate the sureph platform safely and legally. We are upfront about what we collect, why we collect it, and how long we keep it.
No Spam. No Selling.
sureph will never sell, rent, or trade your personal information to any third-party advertiser. Marketing communications from sureph are always opt-in and easy to unsubscribe from.
Privacy Support 24/7
Have a question about your data? The sureph support team is available via live chat 24 hours a day, 7 days a week, to assist with any data privacy concerns or requests.
Introduction
Welcome to the sureph Privacy Policy. sureph ("we", "us", "our") is committed to protecting the personal information of every Filipino player who registers, deposits, plays, and interacts with our platform at sureph.bet. This Privacy Policy has been prepared in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and the implementing rules and regulations issued by the National Privacy Commission (NPC).
This Privacy Policy describes in detail the categories of personal data we collect from you when you use the sureph platform, the purposes for which that data is processed, the legal bases on which we rely, the parties with whom we share your data, and the rights you hold as a data subject under Philippine law.
By registering an account on sureph, depositing funds, or otherwise using any feature of the sureph platform, you acknowledge that you have read, understood, and agreed to this Privacy Policy. If you do not agree with any part of this Privacy Policy, you must cease using the sureph platform immediately.
Scope: This Privacy Policy applies to all personal data collected through the sureph website at sureph.bet, the sureph mobile-optimised web interface, customer support interactions (including live chat and email), and any other channel through which sureph receives personal information from you.
Data Controller
For the purposes of the Philippine Data Privacy Act of 2012, sureph acts as the personal information controller in respect of your personal data collected through the sureph platform. As the personal information controller, sureph determines the purposes and means of processing your personal information and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.
sureph has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with applicable Philippine data privacy laws and for handling data subject rights requests. You may contact the sureph DPO through the live chat support channel or by emailing [email protected] with the subject line "Data Privacy Request".
Data Protection Officer: All formal data subject rights requests, privacy complaints, and data breach notifications should be directed to the sureph Data Protection Officer. Requests will be acknowledged within seventy-two (72) hours and resolved within thirty (30) days in accordance with NPC guidelines.
Personal Data We Collect
sureph collects personal data from you through several channels during the course of your registration and ongoing use of the platform. The categories of personal data we collect are described below.
3.1 Registration Data
When you create a sureph account, we collect the personal information you provide during the registration process, including:
- Full legal name (as it appears on your government-issued Philippine ID)
- Date of birth (to verify you are at least 21 years of age)
- Residential address in the Philippines (including city, province, and postal code)
- Email address
- Philippine mobile number
- Username and password (password is stored in encrypted form)
- Preferred currency (Philippine Peso / PHP)
3.2 Identity Verification (KYC) Data
To comply with Philippine anti-money laundering regulations and to verify your identity, sureph may request and collect:
- Copies of government-issued Philippine identification documents (e.g., PhilSys National ID, passport, driver's licence, UMID, SSS ID, Voter's ID)
- Proof of current address documents (e.g., recent utility bill, barangay certificate)
- Source of funds documentation where required by applicable AML regulations
- Selfie photographs for liveness verification purposes
3.3 Financial Transaction Data
sureph collects data related to your financial transactions on the platform, including:
- Deposit and withdrawal amounts, dates, and payment method details (GCash number, Maya account, BPI/BDO/Metrobank/UnionBank account reference, Coins.ph wallet, or USDT TRC20 wallet address)
- Transaction reference numbers and confirmation codes
- Account balance history and transaction logs
3.4 Gaming Activity Data
sureph records data related to your gaming activity on the platform, including game sessions played, bet amounts, game results, bonus usage, and wagering history. This data is used for account management, bonus integrity monitoring, responsible gaming purposes, and regulatory compliance.
3.5 Technical and Usage Data
When you access sureph, we automatically collect certain technical data through cookies and server logs, including:
- IP address and approximate geographic location
- Device type, operating system, and browser version
- Pages visited on sureph, time spent, and click-through patterns
- Referral source (how you arrived at sureph.bet)
- Session start and end times
3.6 Customer Support Data
When you contact sureph through the live chat support channel or via email, we collect the content of your communication, your account details, the nature of your query, and any supporting documentation you provide. This data is retained for quality assurance and dispute resolution purposes.
Summary of Data Categories
| Data Category | Examples | Primary Purpose |
|---|---|---|
| Registration Data | Name, DOB, email, mobile number | Account creation & 21+ age verification |
| KYC / Identity Data | Government ID, selfie, proof of address | AML compliance, fraud prevention |
| Financial Data | GCash number, transaction history | Deposit & withdrawal processing |
| Gaming Activity | Bet history, game sessions, RTP logs | Account management, responsible gaming |
| Technical Data | IP address, device, browser | Security, fraud detection, analytics |
| Support Communications | Live chat logs, email threads | Dispute resolution, quality assurance |
How We Use Your Personal Data
sureph processes your personal data only for the purposes described in this Privacy Policy. We do not use your personal data for any purpose that is incompatible with those listed below without first obtaining your explicit consent.
- Account Registration and Management: To create and maintain your sureph account, verify your identity, process your login, and manage your account settings and preferences.
- Age Verification: To confirm that you meet the minimum age requirement of 21 years as required under applicable Philippine gaming regulations and PAGCOR guidelines.
- Payment Processing: To process your deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT TRC20, and to maintain accurate financial records of all transactions.
- Regulatory and Legal Compliance: To comply with applicable Philippine laws, including the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, PAGCOR regulations, and any other applicable legislation or regulatory directive.
- Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorised account access, and other illegal or prohibited conduct on the sureph platform.
- Responsible Gaming: To monitor your gaming activity for signs of problem gambling, to apply account restrictions where requested, and to fulfil our obligations under applicable responsible gaming frameworks.
- Customer Support: To respond to your queries, resolve disputes, and provide technical assistance through the sureph live chat support channel and email.
- Platform Improvement: To analyse aggregated usage patterns, optimise the performance and user experience of the sureph platform, and to develop new features based on player feedback and behaviour data.
- Marketing Communications: To send you promotional offers, bonus notifications, and news about new games or features on sureph, where you have opted in to receive such communications. You may opt out at any time.
- Legal Disputes: To establish, exercise, or defend legal claims in connection with your use of the sureph platform.
Legal Basis for Processing
sureph processes your personal data on the following legal bases as recognised under the Philippine Data Privacy Act of 2012:
- Contractual Necessity: Processing is necessary for the performance of the contract between you and sureph — specifically, to create and maintain your account, process transactions, and provide the gaming services you have requested.
- Legal Obligation: Processing is necessary for sureph to comply with applicable Philippine laws and regulations, including AMLA obligations, PAGCOR regulatory requirements, and NPC data privacy rules.
- Legitimate Interests: Processing is necessary for the legitimate interests of sureph, including fraud prevention, platform security, responsible gaming monitoring, and improving the platform's services, where these interests are not overridden by your data protection rights.
- Consent: For marketing communications and certain non-essential cookies, sureph relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
Data Sharing & Third Parties
sureph does not sell, rent, or trade your personal data to third-party advertisers or data brokers. We share your personal data only in the limited circumstances described below, and only to the extent necessary for the stated purpose.
6.1 Game Providers
sureph's gaming content is provided by certified third-party game studios. To enable your access to their games, certain account-level data (such as your player ID and session token) is shared with these providers. Game providers are contractually bound to process this data only for the purpose of delivering the game session and are prohibited from using it for any other purpose.
6.2 Payment Service Providers
To process your deposits and withdrawals, sureph shares the minimum necessary financial data with the relevant payment service providers (GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT TRC20 processing partners). These providers process your data under their own privacy policies and are bound by their respective regulatory obligations.
6.3 Identity Verification and KYC Providers
sureph may use accredited third-party identity verification and KYC service providers to assist in verifying your identity documents. These providers process your KYC data solely for the purpose of identity verification and are contractually prohibited from using your data for any other purpose.
6.4 Regulatory and Law Enforcement Authorities
sureph may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities where required to do so by law, court order, or regulatory directive. sureph will notify you of such disclosures where permitted by law to do so.
6.5 Analytics Providers
sureph uses anonymised and aggregated analytics data to understand how the sureph platform is used and to improve our services. Any analytics processing uses data that cannot reasonably be used to identify individual players.
No Data Sales: sureph will never sell, lease, or otherwise transfer your personal information to third parties for commercial purposes. Any data sharing described in this section is carried out solely for the operational, legal, or regulatory purposes stated above.
Cookies & Tracking Technologies
sureph uses cookies and similar tracking technologies on the sureph.bet website to provide a functional, personalised, and secure experience for Filipino players. A cookie is a small text file placed on your device by the sureph website when you visit. Cookies do not contain your full personal details but may contain a reference to your sureph session or preferences.
7.1 Essential Cookies
These cookies are strictly necessary for the sureph platform to function. They enable core features such as your login session, your account balance display, and the shopping cart in the sureph cashier. Essential cookies cannot be disabled without significantly degrading the functionality of sureph.
7.2 Functional Cookies
Functional cookies remember your preferences on sureph — such as your preferred language, display settings, and responsible gaming tool configurations — so that you do not need to reset them on each visit.
7.3 Analytics Cookies
With your consent, sureph uses analytics cookies to collect anonymised, aggregated data about how players navigate and interact with the sureph platform. This data helps sureph improve the platform's performance, content relevance, and user experience. You may opt out of analytics cookies at any time through the cookie preference centre on sureph.bet.
7.4 Marketing Cookies
With your consent, sureph may use marketing cookies to personalise the promotional content shown to you on the sureph platform — for example, displaying bonus offers relevant to the games you most frequently play. You may withdraw consent for marketing cookies at any time without affecting your access to sureph.
You may manage your cookie preferences at any time by accessing the cookie preference settings on the sureph website. Please note that disabling essential cookies may prevent certain features of sureph from operating correctly.
Data Retention
sureph retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The specific retention periods applied by sureph are as follows:
| Data Category | Retention Period | Basis |
|---|---|---|
| Registration & Account Data | Duration of account + 5 years after closure | AMLA & regulatory compliance |
| KYC / Identity Documents | Duration of account + 5 years after closure | PAGCOR & AMLC requirements |
| Financial Transaction Records | 10 years from transaction date | Anti-Money Laundering Act (AMLA) |
| Gaming Activity Logs | 5 years from account closure | Regulatory compliance & dispute resolution |
| Customer Support Records | 3 years from last interaction | Quality assurance & dispute resolution |
| Marketing Preferences | Until withdrawn or account closure | Consent-based |
| Analytics Data (anonymised) | 26 months rolling | Platform improvement (legitimate interest) |
Upon expiry of the applicable retention period, sureph will securely delete or anonymise your personal data in accordance with its data disposal procedures. Data that has been anonymised in a manner that can no longer be attributed to any individual player may be retained indefinitely for statistical purposes.
Data Security
sureph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, destruction, or accidental loss. These measures include, but are not limited to:
- SSL/TLS Encryption: All data transmitted between your device and the sureph platform is encrypted using industry-standard TLS protocols, ensuring that your personal and financial data cannot be intercepted in transit.
- At-Rest Encryption: Sensitive personal data stored in sureph's databases — including identity documents, financial records, and password hashes — is encrypted at rest using AES-256 encryption.
- Access Controls: Access to personal data within sureph's systems is restricted on a strict need-to-know basis. Only authorised personnel with a legitimate operational need may access player data, and all such access is logged and audited.
- Two-Factor Authentication: sureph encourages all players to enable two-factor authentication (2FA) on their sureph accounts to provide an additional layer of protection against unauthorised access.
- Regular Security Audits: sureph conducts regular security assessments and penetration testing of the sureph platform to identify and remediate potential vulnerabilities before they can be exploited.
- Data Breach Response: In the event of a personal data breach affecting sureph players, sureph will notify affected individuals and the National Privacy Commission within the timeframes prescribed by the Data Privacy Act and NPC Circular No. 16-03.
Your Responsibility: While sureph takes all reasonable steps to secure your personal data, no online platform can guarantee absolute security. You play an important role in protecting your sureph account by keeping your password confidential, enabling 2FA, and reporting any suspected unauthorised access to sureph support immediately.
Your Data Subject Rights
Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to the personal data sureph holds about you. To exercise any of these rights, please contact the sureph Data Protection Officer via live chat or at [email protected] with the subject line "Data Privacy Request".
- Right to be Informed: You have the right to be informed about the personal data sureph collects, the purposes for its processing, and the parties to whom it may be disclosed — all of which are set out in this Privacy Policy.
- Right of Access: You have the right to request a copy of the personal data sureph holds about you, as well as information about how that data is processed.
- Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data sureph holds about you. You may update certain account details directly through your sureph account settings.
- Right to Erasure: You have the right to request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected. Please note that this right is subject to sureph's legal retention obligations under Philippine AML and gaming regulations.
- Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on sureph's legitimate interests. Where you object to marketing, sureph will cease marketing communications immediately.
- Right to Data Portability: You have the right to receive a copy of the personal data you have provided to sureph in a structured, commonly used, and machine-readable format, and to transmit that data to another organisation where technically feasible.
- Right to Lodge a Complaint: If you believe sureph has processed your personal data in violation of the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at www.privacy.gov.ph.
sureph will respond to all data subject rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with prior written notice to you.
Children's Privacy
The sureph platform is strictly intended for adults aged 21 years and above in accordance with applicable Philippine gaming regulations. sureph does not knowingly collect, process, or retain personal data from individuals under the age of 21. The minimum age requirement of 21 years is verified during the account registration process and through KYC identity verification procedures.
If sureph becomes aware that personal data has been collected from an individual under the age of 21, sureph will immediately suspend the relevant account, delete the associated personal data, and reverse any financial transactions in accordance with applicable regulations.
If you are a parent or guardian and you believe your child under the age of 21 has registered an account on sureph, please contact the sureph support team immediately via live chat so that appropriate action can be taken without delay.
21+ Age Restriction: Registration and play on sureph is strictly limited to individuals who are 21 years of age or older. This requirement is enforced in compliance with applicable Philippine gaming laws and PAGCOR regulations.
Cross-Border Data Transfers
The sureph platform serves Filipino players primarily from infrastructure located in or near the Philippines. However, certain third-party service providers used by sureph — including game studios, KYC verification providers, and cloud infrastructure partners — may process or store data in jurisdictions outside the Philippines.
Where personal data is transferred outside the Philippines, sureph ensures that such transfers comply with the requirements of the Data Privacy Act of 2012 and applicable NPC regulations. Specifically, sureph will only transfer personal data to recipients in countries that provide an adequate level of protection for personal data, or where appropriate contractual safeguards (such as standard contractual clauses) are in place to protect your data.
sureph will not transfer your personal data to any third party outside the Philippines for the purpose of commercial exploitation, resale, or use in a manner inconsistent with this Privacy Policy.
Marketing Communications
sureph may send you promotional emails, SMS messages, or in-platform notifications about new games, bonus offers, tournaments, and platform updates. sureph will only send you marketing communications where you have provided your consent to receive them during the account registration process or through your account notification settings.
You may opt out of marketing communications from sureph at any time by:
- Clicking the "Unsubscribe" link in any marketing email received from sureph
- Updating your notification preferences in your sureph account settings
- Contacting the sureph support team via live chat and requesting removal from marketing lists
Please note that even if you opt out of marketing communications, sureph will continue to send you transactional and account-related communications — such as deposit confirmations, withdrawal notifications, security alerts, and important updates to this Privacy Policy — as these are necessary for the operation of your sureph account and cannot be opted out of while your account remains active.
No Spam Policy: sureph is committed to responsible marketing practices. We will never send unsolicited bulk marketing messages. All marketing communications from sureph are permission-based and include a clear, easy opt-out mechanism.
Updates to This Privacy Policy
sureph reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC regulations, PAGCOR requirements, or sureph's data processing practices. When sureph makes material changes to this Privacy Policy, we will notify you by posting a prominent notice on the sureph platform and, where appropriate, by sending an email notification to the address associated with your sureph account.
The "Last Updated" date at the top of this Privacy Policy reflects the most recent date on which material changes were made. Your continued use of the sureph platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms.
sureph encourages you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information. If you disagree with any changes to this Privacy Policy, you must stop using the sureph platform and may request closure of your account by contacting sureph support.
Contact & Complaints
If you have any questions, concerns, or requests relating to this Privacy Policy or to the way sureph processes your personal data, please contact us through the following channels:
sureph Data Protection Officer
Email: [email protected] (subject line: "Data Privacy Request")
Live Chat: Available 24/7 on sureph.bet — average response under 2 minutes
If you are not satisfied with sureph's response to your privacy concern, or if you believe that sureph has violated the Data Privacy Act of 2012, you have the right to file a complaint with the National Privacy Commission of the Philippines. Information about how to file a complaint with the NPC is available on the NPC's official website.
sureph takes all privacy complaints seriously and will investigate every complaint received. We are committed to resolving privacy concerns promptly, fairly, and in full compliance with the Data Privacy Act of 2012 and applicable NPC regulations.
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