Privacy Policy

1. Introduction

This Privacy Policy describes how Scatter Win ("scatter win", "we", "us", "our"), the operator of scatterwin.org, collects, uses, stores, and protects the personal information of Filipino players and visitors to the scatter win platform. This policy is designed to be transparent and accessible, and reflects scatter win's commitment to responsible data handling in the Philippines.

Scatter Win operates exclusively for Filipino players and processes all personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations issued by the National Privacy Commission (NPC). By registering a scatter win account or using any scatter win service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Privacy Policy should be read together with the scatter win Terms and Conditions, which govern the overall use of scatter win services. Defined terms used but not defined in this Privacy Policy have the meanings given to them in the Terms and Conditions.

2. Personal Data We Collect

Scatter Win collects personal data that is necessary for the operation of your account and the delivery of scatter win services. The categories of personal data we collect from Filipino players include:

Scatter Win does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information unless specifically required to fulfil a responsible gaming obligation, such as processing a self-exclusion request linked to a diagnosed gambling disorder where you have voluntarily provided this information.

3. How We Collect Your Data

Scatter Win collects personal data through the following means:

• Direct submission: When you register a scatter win account, complete KYC verification, make a deposit or withdrawal request, contact scatter win support, or respond to a survey or promotion.
• Automated collection: When you visit scatterwin.org or use the scatter win platform, our systems automatically collect technical and usage data through cookies, server logs, and similar tracking technologies.
• Third-party sources: Scatter Win may receive identity or fraud risk data from Philippine payment processors such as GCash and Maya in connection with deposit and withdrawal processing, or from identity verification service providers engaged to assist with KYC compliance.

Scatter Win does not purchase personal data from data brokers or marketing list providers. We do not collect data from social media platforms unless you choose to contact us through a scatter win social media channel and voluntarily provide personal information in that communication.

4. How We Use Your Personal Data

Scatter Win uses the personal data we collect for the following purposes:

• Account creation and management: To register your scatter win account, authenticate your identity at login, and manage account settings and preferences.
• KYC and age verification: To verify that you are a genuine Filipino player aged 21 years or older before allowing access to real-money gaming features on scatter win.
• Payment processing: To process PHP deposits via GCash, Maya, InstaPay, and Philippine bank transfer, and to execute verified withdrawal requests to your nominated Philippine payment account.
• Service delivery: To provide access to scatter win sports betting, basketball betting, live casino, and online slots products and to settle bets and game outcomes correctly.
• Customer support: To respond to your queries, complaints, and dispute submissions submitted to the scatter win support team.
• Responsible gaming: To monitor your gaming activity for indicators of problem gambling, administer deposit limits and self-exclusion requests, and provide responsible gaming tools and alerts.
• Fraud prevention and security: To detect and prevent fraudulent account activity, multiple account registrations, money laundering, and other prohibited conduct.
• Legal compliance: To comply with obligations under Philippine law, including the Data Privacy Act of 2012, anti-money laundering regulations, and any lawful directions from Philippine authorities.
• Platform improvement: To analyse usage patterns on scatterwin.org and improve the scatter win platform experience for Filipino players.
• Marketing communications: To send you promotional offers, bonus notifications, and scatter win news by email or SMS, where you have provided consent to receive such communications. You may withdraw consent at any time by contacting [email protected].

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to register your account, verify your identity, process payments, and deliver scatter win gaming services in accordance with our Terms and Conditions.
• Legal obligation: Processing required to comply with Philippine anti-money laundering laws, the Data Privacy Act of 2012, and any lawful direction from a competent Philippine authority including the National Privacy Commission.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and platform improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and optional analytics, where you have given your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Where scatter win relies on consent as a legal basis, we will clearly identify this at the point of data collection and provide a straightforward mechanism for withdrawing consent.

6. Sharing Your Personal Data

Scatter Win does not share your personal data with third parties except in the following circumstances:

• Payment service providers: Scatter Win shares necessary transaction data with GCash, Maya, InstaPay, and Philippine banks to process deposits and withdrawals in PHP. These providers act as data processors under agreements that require them to protect your data in accordance with applicable law.
• Identity verification providers: Scatter Win may engage third-party KYC and identity verification service providers to assist in verifying Philippine government-issued IDs. These providers process your verification data strictly on scatter win's instructions.
• IT and platform service providers: Scatter Win may share data with cloud hosting, cybersecurity, and platform infrastructure providers that support the operation of scatterwin.org. These providers are contractually bound to process data only as directed by scatter win.
• Legal and regulatory authorities: Scatter Win will disclose personal data to the National Privacy Commission, Philippine law enforcement, courts, or other competent authorities where required by law or court order, or where necessary to protect scatter win's legal rights.
• Anti-fraud and AML systems: Scatter Win may share data with anti-money laundering or fraud prevention platforms operating in the Philippines where required by law or legitimate platform security interests.

All third parties with whom scatter win shares personal data are required to maintain appropriate technical and organisational security measures and to process your data only for the purposes specified by scatter win. Scatter Win does not transfer personal data outside the Philippines except where required by the payment processing chain and subject to appropriate safeguards.

7. Payment Data and Financial Privacy

Because scatter win processes real-money deposits and withdrawals in Philippine Pesos, financial data receives a heightened level of protection within the scatter win platform. The following specific provisions apply to payment data:

• GCash account references and Maya account references provided for withdrawal purposes are stored using encryption at rest and in transit. They are never displayed in plaintext beyond the account settings screen visible only to the authenticated account holder.
• Philippine bank account names and numbers used for bank transfer withdrawals are handled under the same encryption and access-restriction standards as GCash and Maya data.
• Full payment card numbers are not stored by scatter win. Card-present payment processing, if offered, is handled entirely by the relevant payment gateway using tokenisation.
• Scatter Win's payment service providers are required to maintain their own data security standards consistent with their obligations under Philippine law and relevant payment industry standards.
• Transaction history including deposit and withdrawal amounts, dates, and references is retained as part of your scatter win account record. You may view your own transaction history within your account dashboard at any time.

Scatter Win uses financial transaction data to fulfil AML and suspicious transaction monitoring obligations under Philippine law. Where a transaction is flagged as suspicious, scatter win may be legally required to report it to the appropriate Philippine authority without notifying you of that report.

8. Cookies and Tracking Technologies

Scatter Win uses cookies and similar tracking technologies on scatterwin.org to operate the platform, remember your session, and understand how Filipino players use the site. The types of cookies used by scatter win include:

Strictly necessary cookies cannot be disabled as they are required for the scatter win platform to function. For optional and marketing cookies, scatter win will request your consent where required. You may also manage cookie preferences through your browser settings at any time. Note that disabling certain cookies may affect the functionality of scatterwin.org.

Scatter Win does not use third-party advertising cookies to track your behaviour across other websites for the purposes of building advertising profiles. Any analytics data collected on scatterwin.org is used only to improve the scatter win platform experience for Filipino players.

9. How Long We Keep Your Data

Scatter Win retains your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Philippine law. The following general retention periods apply:

• Active account data: Retained for the full duration of your scatter win account plus a minimum of 5 years after account closure, in accordance with Philippine AML and financial record-keeping requirements.
• KYC and identity verification data: Retained for a minimum of 5 years after account closure or the conclusion of any related investigation, whichever is later.
• Transaction and betting history: Retained for a minimum of 5 years after the date of the relevant transaction or bet settlement, or longer if required by applicable law or ongoing investigation.
• Support communications: Retained for a minimum of 2 years after the conclusion of the relevant support interaction, unless the communication relates to a dispute or regulatory matter, in which case longer retention may apply.
• Marketing consent records: Retained for the duration of your consent plus 1 year after withdrawal of consent, to demonstrate compliance with consent obligations.
• Technical and usage logs: Retained for up to 12 months unless required for longer periods for security or legal purposes.

At the end of the applicable retention period, scatter win will securely delete or anonymise your personal data. Where anonymisation is used, the resulting data no longer constitutes personal data and may be retained for statistical or analytical purposes without limit.

10. Data Security

Scatter Win implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security practices include:

• TLS encryption for all data transmitted between your device and scatterwin.org
• Encryption at rest for sensitive personal data including identity documents and financial account details
• Access controls limiting scatter win staff access to personal data on a strict need-to-know basis
• Regular security assessments and vulnerability testing of the scatter win platform
• Monitoring systems for detecting unauthorised access attempts and suspicious account activity
• Incident response procedures for promptly addressing and notifying affected players of any data breach in accordance with the Data Privacy Act of 2012

While scatter win takes all reasonable measures to protect your data, no internet transmission or electronic storage system can be guaranteed to be 100% secure. You are responsible for keeping your scatter win account login credentials confidential and for notifying scatter win immediately if you believe your account has been accessed without your authorisation.

11. Your Data Privacy Rights

As a Filipino player and data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by scatter win:

• Right to be informed: You have the right to be informed that scatter win is collecting and processing your personal data, and to receive a copy of this Privacy Policy before or at the time of data collection.
• Right of access: You have the right to request a copy of the personal data scatter win holds about you, along with information about how it is processed.
• Right to rectification: You have the right to request correction of inaccurate or incomplete personal data. Some data fields can be updated directly within your scatter win account settings; other corrections require a support request.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where the data has been unlawfully processed. This right is subject to scatter win's legal retention obligations under Philippine AML and financial record-keeping law.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on scatter win's legitimate interests.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format where processing is based on your consent or a contract.
• Right to lodge a complaint: If you believe scatter win has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please contact scatter win at [email protected] with your full name, account details, and a clear description of your request. Scatter win will respond within 30 calendar days. Some requests may require identity verification before they can be processed.

12. Minors and Age Restriction

Scatter Win services are strictly for Filipino players who are 21 years of age or older. Scatter Win does not knowingly collect personal data from individuals under 21 years of age.

As part of the account registration and KYC process, scatter win requires all players to verify that they meet the minimum age requirement of 21 years using a valid Philippine government-issued ID. Any account where the holder is found to be under 21 years of age will be immediately closed and any funds held in the account will be dealt with in accordance with the scatter win Terms and Conditions and applicable Philippine law.

If a parent or guardian believes that a minor has registered a scatter win account or submitted personal data to scatter win without their consent, please contact us immediately at [email protected] and scatter win will take prompt action to close the account and delete the relevant personal data.

13. Changes to This Privacy Policy

Scatter Win may update this Privacy Policy from time to time to reflect changes in our data practices, changes in Philippine law, or improvements to the scatter win platform. The date of the most recent update is always shown at the top of this page.

Where changes to this Privacy Policy are material — meaning they meaningfully affect how we use your personal data or the rights available to you — scatter win will notify registered Filipino players by email to the address associated with their account at least 7 days before the changes take effect. Non-material changes such as corrections of typographical errors or clarifications of existing provisions may take effect immediately.

If you do not agree to an updated version of this Privacy Policy, you should stop using scatter win and request account closure before the updated policy takes effect. Continued use of scatter win after the effective date of an updated Privacy Policy constitutes your acceptance of the changes.

14. How to Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way scatter win handles your personal data, please contact the scatter win data privacy team. All contacts regarding privacy matters should be submitted in writing by email to ensure a proper record is maintained.

Email addresses above are displayed as plain text only. Please copy and paste into your email application to contact us. Scatter Win does not operate telephone or SMS support lines.