super291 Privacy Policy

Effective Date: January 1, 2026

Last Updated: January 1, 2026

This Privacy Policy (the "Policy") describes how super291 ("we," "us," "our," or the "Platform") collects, uses, discloses, and protects the personal information of users ("you," "your," or "Player") who access or use the super291 online casino platform located at https://super291.app (the "Website").

By creating an account, accessing the Website, or using any services provided by super291, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with the terms of this Policy, you must immediately cease using the Platform and refrain from creating an account.

This Privacy Policy is incorporated into and forms part of our Terms and Conditions. We are committed to protecting your privacy and handling your personal data in accordance with applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173).

super291 collects various types of information to provide, maintain, and improve our services. The information we collect falls into the following categories:

1.1 Information You Provide Directly

When you register for a super291 account or use our services, you voluntarily provide us with the following personal information:

• Account Registration Data: Full name, date of birth, email address, phone number, residential address, and username;
• Identity Verification Documents: Government-issued identification (e.g., Philippine passport, driver's license, UMID, SSS ID), proof of address (utility bills, bank statements), and selfie photographs for identity verification purposes;
• Payment Information: Payment method details (GCash account, PayMaya account, bank account information for BPI, BDO, Metrobank), transaction history, deposit and withdrawal records;
• Communications: Messages sent to customer support, feedback forms, survey responses, and any other communications you initiate with super291.

1.2 Information Collected Automatically

When you access or use the super291 Platform, we automatically collect certain technical and usage information, including:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IP address, device ID);
• Usage Data: Pages visited, games played, time spent on the Platform, clickstream data, referral sources, search queries;
• Location Data: Approximate geographic location based on IP address to verify that you are accessing the Platform from within the Philippines;
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to collect information about your browsing behavior and preferences. See Section 6 (Cookies) for more details.

1.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: Transaction confirmation, payment method verification, and fraud detection data from GCash, PayMaya, and banking partners;
• Identity Verification Services: Age verification, identity authentication, and fraud prevention data from third-party verification providers;
• Regulatory Authorities: Information required for compliance with Philippine gaming regulations and anti-money laundering laws.

super291 uses the personal information we collect for the following purposes:

2.1 Account Management and Service Provision

• Create and maintain your super291 account;
• Verify your identity and age (21+ requirement);
• Process deposits, withdrawals, and other financial transactions;
• Provide access to games, live casino tables, poker rooms, bingo halls, and other Platform features;
• Manage bonuses, promotions, and loyalty program participation;
• Respond to customer support inquiries and resolve disputes.

2.2 Security and Fraud Prevention

• Detect, prevent, and investigate fraudulent activity, money laundering, and other illegal conduct;
• Monitor for collusion, cheating, and bonus abuse;
• Enforce our Terms and Conditions and other policies;
• Protect the security and integrity of the Platform and our users.

2.3 Legal and Regulatory Compliance

• Comply with Philippine gaming regulations, including those enforced by the Philippine Amusement and Gaming Corporation (PAGCOR);
• Comply with anti-money laundering (AML) and know-your-customer (KYC) requirements;
• Respond to legal requests, court orders, and regulatory inquiries;
• Maintain records required by law.

2.4 Platform Improvement and Analytics

• Analyze usage patterns to improve Platform functionality and user experience;
• Conduct research and development for new features and games;
• Optimize Platform performance, speed, and reliability;
• Generate aggregated, anonymized statistics for internal business purposes.

2.5 Marketing and Communications

• Send promotional offers, bonuses, and updates about new games (with your consent);
• Provide personalized game recommendations based on your preferences;
• Send transactional emails (account notifications, withdrawal confirmations, password resets);
• Communicate important Platform updates, policy changes, and security alerts.

super291 does not sell your personal information to third parties. However, we may share your information with the following categories of recipients for the purposes described in this Policy:

3.1 Service Providers

We share personal information with third-party service providers who perform services on our behalf, including:

• Payment Processors: GCash, PayMaya, and banking partners (BPI, BDO, Metrobank) to process deposits and withdrawals;
• Identity Verification Services: Third-party providers that verify your age, identity, and address;
• Game Providers: Licensed software providers that supply casino games, live dealer tables, and other gaming content;
• Cloud Hosting and IT Services: Providers that host our servers, databases, and technical infrastructure;
• Customer Support Tools: Live chat platforms and ticketing systems used to provide customer support;
• Analytics and Marketing Services: Tools that help us analyze Platform usage and deliver targeted marketing (where permitted by law).

3.2 Legal and Regulatory Authorities

We may disclose your personal information to government authorities, law enforcement agencies, and regulatory bodies when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations, court orders, or regulatory requests;
• Enforce our Terms and Conditions or other policies;
• Protect the rights, property, or safety of super291, our users, or the public;
• Investigate suspected fraud, money laundering, or other illegal activity.

3.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you of any such change in ownership or control of your personal information.

3.4 With Your Consent

We may share your personal information with third parties when you have given us explicit consent to do so.

super291 retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Specifically, we retain:

• Account Information: For the duration of your account plus seven (7) years after account closure, as required by Philippine gaming and financial regulations;
• Transaction Records: For seven (7) years after the transaction date, as required by anti-money laundering laws;
• Identity Verification Documents: For seven (7) years after account closure, as required by KYC regulations;
• Marketing Communications: Until you opt out or withdraw consent, after which we will retain only the minimum information necessary to honor your opt-out request;
• Technical and Usage Data: For up to two (2) years, or as necessary for analytics and Platform improvement purposes.

After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with our data retention and deletion policies.

super291 takes the security of your personal information seriously and implements a range of technical and organizational measures to protect your data from unauthorized access, disclosure, alteration, or destruction.

5.1 Security Measures

Our security measures include:

• Encryption: All data transmitted between your device and our servers is protected using 256-bit SSL/TLS encryption;
• Secure Storage: Personal information is stored on secure servers with restricted access controls;
• Access Controls: Only authorized personnel with a legitimate business need can access your personal information;
• Regular Security Audits: We conduct regular security assessments and vulnerability testing;
• Fraud Detection Systems: Automated systems monitor for suspicious activity and potential security threats;
• Employee Training: All staff members receive training on data protection and security best practices.

5.2 Your Responsibility

While we implement robust security measures, you also play a critical role in protecting your account. You are responsible for:

• Keeping your password confidential and not sharing it with others;
• Using a strong, unique password for your super291 account;
• Logging out of your account when using shared or public devices;
• Notifying us immediately if you suspect unauthorized access to your account.

5.3 Limitations

No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. You acknowledge and accept the inherent risks of transmitting information over the internet.

super291 uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content.

6.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They allow the website to recognize your device and remember information about your visit, such as your preferences and login status.

6.2 Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function properly. These cookies enable core functionality such as account login, session management, and security features. You cannot opt out of essential cookies.
• Performance Cookies: Collect information about how you use the Platform, such as which pages you visit and any errors you encounter. This data helps us improve Platform performance.
• Functionality Cookies: Remember your preferences (e.g., language settings, game favorites) to provide a more personalized experience.
• Marketing Cookies: Track your browsing activity to deliver targeted advertisements and promotional offers based on your interests.

6.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can choose to block or delete cookies, but doing so may affect your ability to use certain features of the Platform. To learn more about managing cookies, visit your browser's help section.

Under the Philippine Data Privacy Act of 2012, you have certain rights regarding your personal information. super291 respects these rights and provides mechanisms for you to exercise them.

7.1 Right to Access

You have the right to request access to the personal information we hold about you. You can view and update most of your account information by logging into your super291 account.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update your account details directly through your account settings or by contacting customer support.

7.3 Right to Erasure

You have the right to request deletion of your personal information, subject to certain legal exceptions (e.g., regulatory retention requirements, ongoing investigations). To request account deletion, contact customer support.

7.4 Right to Object

You have the right to object to the processing of your personal information for direct marketing purposes. You can opt out of marketing communications at any time.

7.5 Right to Data Portability

You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format.

7.6 Right to Withdraw Consent

Where we process your personal information based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

7.7 How to Exercise Your Rights

To exercise any of these rights, please contact us using the contact information provided in Section 10 (Contact Us). We will respond to your request within thirty (30) days, as required by Philippine law.

The super291 Platform is strictly intended for users aged twenty-one (21) years and above. We do not knowingly collect personal information from individuals under the age of 21.

If we become aware that we have inadvertently collected personal information from a person under 21 years of age, we will take immediate steps to delete that information and terminate the associated account.

If you believe that we have collected information from a minor, please contact us immediately using the contact information provided in Section 10 (Contact Us).

super291 reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform features. When we make material changes, we will notify you by:

• Posting a notice on the Platform homepage;
• Updating the "Last Updated" date at the top of this Policy;
• Sending an email notification to your registered email address (for significant changes).

Your continued use of the super291 Platform after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised Policy, you must stop using the Platform and close your account.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information. The most current version of this Policy will always be available on the Platform.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

super291 Data Protection Officer
Email: [email protected]
Customer Support: Available 24/7 via live chat on the Platform

We will respond to all inquiries within thirty (30) days, as required by Philippine data protection law.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.