scattergame Privacy Policy

1. Introduction

scattergame ("we," "us," "our") is committed to protecting the privacy and personal data of all players who use the scattergame online casino platform. This Privacy Policy describes how scattergame collects, uses, stores, shares, and protects your personal information when you access or use the scattergame website at scattergame.club and all associated services.

This policy is drafted in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC"). As a platform serving Filipino players, scattergame takes its obligations under Philippine data protection law seriously.

By registering an account, making a deposit, or otherwise using the scattergame platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree to this policy, you must not use the scattergame platform.

2. Data Controller

scattergame is the data controller responsible for the personal data collected through the scattergame.club platform. As data controller, scattergame determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law.

For all data privacy inquiries, requests to exercise your data rights, or concerns about how scattergame handles your personal information, you may contact our Data Protection Officer (DPO) via the email address displayed in the footer of this website.

3. Personal Data We Collect

scattergame collects the following categories of personal data from players:

3.1 Registration Data

When you create a scattergame account, we collect:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted password

3.2 Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) process, we may collect:

• Copies of government-issued photo identification (Philippine passport, driver's license, SSS ID, UMID, PhilHealth ID, or Voter's ID)
• Proof of address documents (utility bills, bank statements, or government correspondence)
• Selfie photographs with identification documents
• Proof of payment method ownership

3.3 Financial Data

• GCash account number (registered mobile number)
• Maya account details
• Bank account details (account name, account number, bank name) for bank transfer transactions
• Debit card details (card number, expiry date — stored in tokenized form only)
• Transaction history (deposits, withdrawals, and gaming activity)

3.4 Gaming Activity Data

• Game play history (games played, bets placed, outcomes, winnings)
• Session duration and frequency of play
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

3.5 Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Pages visited, links clicked, and time spent on the platform
• Referring website or source (how you arrived at scattergame.club)

3.6 Communications Data

• Customer support chat transcripts and email correspondence
• Feedback and survey responses
• Complaints and dispute records
• Marketing communication preferences

4. How We Collect Your Data

scattergame 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 respond to a survey.
• Automatically — through cookies, web beacons, and similar tracking technologies when you browse the scattergame platform. See Section 9 for more details on our cookie practices.
• From payment processors — when you make a deposit or withdrawal, our payment processing partners may share transaction confirmation data with us.
• From identity verification services — we may use third-party KYC service providers to assist with document verification and fraud detection.
• From fraud prevention services — we may receive data from fraud detection and anti-money laundering (AML) screening services to protect the integrity of the platform.

5. How We Use Your Personal Data

scattergame uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Registration data, KYC data
Age verification (21+ requirement)	Date of birth, KYC documents
Processing deposits and withdrawals	Financial data, KYC data
Fraud prevention and AML compliance	All categories, as required
Customer support	Registration data, communications data
Responsible gaming monitoring	Gaming activity data, registration data
Platform improvement and analytics	Technical data, gaming activity data
Marketing communications (with consent)	Registration data, gaming activity data
Legal and regulatory compliance	All categories, as required by law

scattergame does not use your personal data for any purpose not listed above without first obtaining your explicit consent or as otherwise required by applicable Philippine law.

6. Legal Basis for Processing

Under the Philippine Data Privacy Act, scattergame 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 delivery.
• Legal obligation — processing required to comply with applicable laws and regulations, including KYC/AML obligations, age verification requirements, and regulatory reporting to PAGCOR and other Philippine authorities.
• Legitimate interests — processing necessary for scattergame's legitimate business interests, including fraud prevention, platform security, and improving our services, where such interests are not overridden by your rights and freedoms.
• Consent — processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7. Data Sharing and Disclosure

scattergame does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this policy:

• Payment processors — GCash, Maya, and banking partners require certain personal and financial data to process your transactions securely.
• KYC and identity verification providers — third-party services that assist with document verification and age confirmation.
• Fraud prevention and AML screening services — to detect and prevent fraudulent activity and money laundering on the platform.
• Game software providers — game providers may receive anonymized or pseudonymized gaming activity data for game performance and integrity purposes.
• Regulatory authorities — PAGCOR and other Philippine government agencies as required by law, court order, or regulatory directive.
• Law enforcement — Philippine law enforcement agencies where required by law or where scattergame has a good-faith belief that disclosure is necessary to prevent illegal activity or protect the safety of players or the public.
• Professional advisors — lawyers, accountants, and auditors who are bound by professional confidentiality obligations.

8. Data Retention

scattergame retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and registration data — retained for the duration of your account and for a minimum of five (5) years after account closure, as required by Philippine AML regulations.
• KYC and identity verification documents — retained for a minimum of five (5) years after the end of the business relationship, in compliance with anti-money laundering laws.
• Transaction and financial records — retained for a minimum of five (5) years from the date of the transaction.
• Gaming activity data — retained for a minimum of three (3) years from the date of the activity.
• Customer support communications — retained for a minimum of two (2) years from the date of the last communication.
• Technical and cookie data — retained for up to thirteen (13) months from collection, unless a shorter period applies.

After the applicable retention period expires, scattergame will securely delete or anonymize your personal data in accordance with our data disposal procedures. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for statistical and analytical purposes.

9. Cookies and Tracking Technologies

scattergame uses cookies and similar tracking technologies on the scattergame.club website. Cookies are small text files placed on your device that help us recognize you, remember your preferences, and understand how you use our platform.

9.1 Types of Cookies We Use

• Strictly necessary cookies — essential for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies — remember your preferences such as language settings, preferred game categories, and responsible gaming tool configurations.
• Analytics cookies — help us understand how players use the platform, which pages are most visited, and where technical issues occur. This data is aggregated and anonymized.
• Marketing cookies — used to deliver relevant promotional content to you based on your interests and gaming activity. These are only set with your consent.

9.2 Managing Cookies

You can manage your cookie preferences through the cookie consent banner displayed when you first visit scattergame.club. You may also configure your browser to block or delete cookies, though doing so may affect the functionality of the platform. Note that strictly necessary cookies cannot be disabled as they are essential for the platform to operate.

10. Your Data Rights

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

• Right to be informed — the right to know what personal data scattergame collects about you and how it is processed. This Privacy Policy fulfills that obligation.
• Right of access — the right to request a copy of the personal data scattergame holds about you, along with information about how it is being used.
• Right to rectification — the right to request correction of inaccurate or incomplete personal data. You can update most account information directly through your scattergame account settings.
• Right to erasure — 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 our legal retention obligations.
• 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, and machine-readable format.
• Right to lodge a complaint — the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe scattergame has violated your data privacy rights.

To exercise any of the above rights, please contact scattergame's Data Protection Officer using the email address displayed in the footer of this website. We will respond to all data rights requests within fifteen (15) business days of receipt, as required by the Data Privacy Act. We may need to verify your identity before processing your request.

11. Data Security

scattergame implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the scattergame platform
• AES-256 encryption for personal data stored at rest on our servers
• Tokenization of payment card details — we never store full card numbers in plain text
• Multi-factor authentication options for player accounts
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Regular security audits and penetration testing by independent security professionals
• Intrusion detection and monitoring systems operating 24 hours a day, 7 days a week
• Staff training on data protection and information security best practices

While scattergame takes all reasonable steps to protect your personal data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the security of your account credentials and for notifying scattergame immediately if you suspect unauthorized access to your account.

12. Children's Privacy and Age Restriction

The scattergame platform is strictly intended for persons aged 21 years and above, in accordance with Philippine gaming regulations. scattergame does not knowingly collect personal data from individuals under the age of 21.

If scattergame discovers or has reason to believe that a registered player is under 21 years of age, the account will be immediately suspended, all personal data associated with the account will be reviewed, and the account will be closed in accordance with our Terms & Conditions. Any funds in the account will be handled in accordance with applicable regulations.

If you are a parent or guardian and believe that your child under the age of 21 has registered an account with scattergame, please contact our support team immediately using the contact details in the footer of this website.

13. Changes to This Privacy Policy

scattergame 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, scattergame will notify registered players by email or through a prominent notice on the platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how scattergame protects your personal data. Your continued use of the scattergame platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way scattergame handles your personal data, please contact our Data Protection Officer. Our DPO is responsible for overseeing compliance with the Philippine Data Privacy Act and for handling all data rights requests from players.

You may reach our Data Protection Officer by email — the contact address is displayed in the footer of every page on this website. We aim to acknowledge all privacy-related inquiries within two (2) business days and to provide a full response within fifteen (15) business days.

If you are not satisfied with scattergame's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC), which is the supervisory authority responsible for enforcing the Data Privacy Act.