Privacy Policy – smsm.ph Casino

1. About This Privacy Policy

1.1 This Privacy Policy ("Policy") applies to all personal data collected and processed by smsm.ph ("we," "us," "our," "smsm.ph") in connection with the operation of the smsm.ph online casino and sports betting platform accessible at smsmph.app.

1.2 This Policy applies to all users of the smsm.ph platform, including registered account holders, visitors who browse the platform without registering, and any individual whose personal data is provided to us by a third party in the course of platform operations.

1.3 By accessing the smsm.ph platform or creating an account, 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.

1.4 This Policy should be read alongside the smsm.ph Terms & Conditions and Responsible Gaming Policy.

2. Data Controller

2.1 For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), smsm.ph is the Personal Information Controller (PIC) with respect to the personal data you provide when using the platform.

2.2 As a PAGCOR-regulated online gaming operator, smsm.ph is subject to PAGCOR's data governance requirements in addition to the obligations imposed by RA 10173 and its Implementing Rules and Regulations (IRR).

2.3 Our designated Data Protection Officer (DPO) can be reached at the contact details set out in Section 14 of this Policy.

3. Categories of Personal Data We Collect

3.1 The following table summarises the categories of personal data smsm.ph collects from players:

3.2 smsm.ph does not collect sensitive personal information as defined under RA 10173 beyond what is strictly necessary for identity verification and compliance with PAGCOR regulatory requirements.

4. How We Collect Your Personal Data

4.1 Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion on smsm.ph.

4.2 Automatically: When you access the smsm.ph platform, we automatically collect technical data through cookies, web server logs, and similar tracking technologies as described in Section 9.

4.3 From third parties: We may receive data about you from payment processors (GCash, Maya, BPI, BDO, etc.) in connection with the processing of deposits and withdrawals, and from identity verification service providers engaged to assist with KYC compliance.

4.4 From PAGCOR: We may receive information from PAGCOR in connection with player exclusion lists, regulatory compliance directives, or investigations.

5. How We Use Your Personal Data

5.1 smsm.ph uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your smsm.ph player account, including login authentication and session management;
• Identity Verification: To verify your identity and age (21+) as required by PAGCOR and RA 10173;
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, and other supported payment methods;
• Legal & Regulatory Compliance: To comply with PAGCOR licensing requirements, Philippine anti-money laundering laws (AMLA), and other applicable legislation;
• Responsible Gaming: To monitor gameplay for patterns that may indicate problem gambling and to administer voluntary responsible gaming tools including deposit limits and self-exclusion;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, account abuse, and unauthorised access;
• Customer Support: To respond to your inquiries, complaints, and requests via live chat and email;
• Platform Improvement: To analyse usage patterns and improve the functionality, performance, and user experience of the smsm.ph platform;
• Marketing Communications: To send you promotional offers and updates, where you have consented to receive such communications. You may opt out at any time.

5.2 smsm.ph will not use your personal data for any purpose materially different from those listed above without first obtaining your explicit consent or as otherwise required by law.

6. Legal Basis for Processing

6.1 smsm.ph processes your personal data on the following legal grounds under RA 10173:

• Performance of a Contract: Processing necessary to provide the smsm.ph Casino services you have subscribed to, including account management, game access, and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AMLA obligations, tax reporting requirements, and other applicable Philippine law;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications;
• Legitimate Interests: Processing necessary for the legitimate interests of smsm.ph, including fraud prevention, platform security, and responsible gaming monitoring, provided such interests are not overridden by your fundamental rights and freedoms.

7. Data Sharing & Disclosure

7.1 smsm.ph does not sell, rent, or trade your personal data to third parties for commercial purposes. We share your data only in the circumstances described below.

7.2 Service Providers: We engage third-party service providers to assist with specific functions including payment processing (GCash, Maya, BPI, BDO, etc.), KYC identity verification, customer support software, and IT infrastructure. These providers are contractually bound to process your data only on our instructions and to maintain appropriate security measures.

7.3 Regulatory Authorities: We are required by law to disclose player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities upon lawful request or as mandated by our licensing conditions.

7.4 Game Providers: When you play games on smsm.ph, the relevant third-party game provider may process limited technical and gaming data necessary to deliver and maintain the game. Game providers are contractually restricted from using this data for any other purpose.

7.5 Corporate Transactions: In the event of a merger, acquisition, or other corporate restructuring, your personal data may be transferred to the relevant successor entity, subject to the same privacy protections as under this Policy.

7.6 Legal Protection: We may disclose your data where necessary to enforce our Terms & Conditions, to protect the rights and safety of smsm.ph, its staff, or other players, or to respond to a lawful court order or legal process.

8. Data Retention

8.1 smsm.ph retains your personal data for as long as necessary to fulfil the purposes set out in this Policy, including the duration of your account registration and for the minimum periods required by applicable law thereafter.

8.2 Specifically, transaction records and KYC documentation are retained for a minimum of five (5) years following the date of the last transaction, as required by the AMLA and PAGCOR regulatory framework. This retention period may be extended where your account is subject to an ongoing investigation or legal dispute.

8.3 Marketing consent records are retained until you withdraw consent, after which your data will be removed from marketing distribution lists within thirty (30) days.

8.4 Upon expiry of the applicable retention period, smsm.ph will securely delete or anonymise your personal data in accordance with our internal data lifecycle management procedures.

9. Cookies & Tracking Technologies

9.1 smsm.ph uses cookies and similar tracking technologies (including web beacons and pixel tags) on the platform. Cookies are small text files stored on your device that help us provide a better user experience.

9.2 We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function — these include session authentication cookies required to keep you logged in to your smsm.ph account. These cannot be disabled.
• Functional Cookies: Remember your preferences (e.g., language, game lobby view) to personalise your smsm.ph experience.
• Analytics Cookies: Help us understand how players use the platform by collecting aggregated, anonymised usage data.
• Security Cookies: Used for fraud detection and account security purposes, including identifying unusual login patterns.

9.3 You may control non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the smsm.ph platform. Strictly necessary cookies cannot be disabled without preventing you from logging in and using the service.

10. Data Security

10.1 smsm.ph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the smsm.ph platform;
• Encryption of sensitive data fields (including passwords and financial data) at rest using industry-standard algorithms;
• Access controls limiting internal staff access to personal data on a need-to-know basis;
• Regular security audits and penetration testing by qualified information security professionals;
• Multi-factor authentication for internal system access by smsm.ph staff.

10.2 While smsm.ph takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are also responsible for maintaining the confidentiality of your account credentials as set out in the smsm.ph Terms & Conditions.

10.3 In the event of a personal data breach that is likely to result in harm to affected players, smsm.ph will notify the National Privacy Commission (NPC) and affected data subjects within the timeframes prescribed by RA 10173.

11. Your Data Privacy Rights

11.1 Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by smsm.ph:

• Right to be Informed: The right to be notified of how your personal data is being processed — which this Privacy Policy fulfils;
• Right of Access: The right to obtain a copy of the personal data smsm.ph holds about you;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected;
• Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations;
• Right to Object: The right to object to specific processing activities, including direct marketing communications;
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

11.2 To exercise any of these rights, please contact smsm.ph's Data Protection Officer as described in Section 14. We will respond to verified requests within fifteen (15) business days.

11.3 Note that certain rights (particularly the right to erasure) are subject to limitations where data retention is required by PAGCOR licensing conditions, AMLA obligations, or other applicable Philippine law.

12. Children's Privacy

12.1 smsm.ph Casino is strictly for adults aged twenty-one (21) years and above, as mandated by PAGCOR. The platform is not directed at children or minors, and we do not knowingly collect personal data from any person under the age of 21.

12.2 If smsm.ph becomes aware that personal data has been collected from a minor without verifiable parental consent and without passing age verification, we will take immediate steps to delete that data and close the associated account.

12.3 If you believe a minor has registered on smsm.ph, please contact support immediately so we can investigate and take appropriate action in line with PAGCOR requirements.

13. Changes to This Privacy Policy

13.1 smsm.ph may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. The "Last Updated" date at the top of this page reflects the date of the most recent revision.

13.2 Material changes to this Policy — particularly those that affect how we use your personal data or expand your rights — will be communicated to registered players via email notification or a prominent in-platform notice prior to the change taking effect.

13.3 Continued use of the smsm.ph platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to a material change, you may close your account in accordance with the smsm.ph Terms & Conditions.

14. Contact Our Data Protection Officer

14.1 For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by smsm.ph, please contact our Data Protection Officer:

14.2 If your concern relates to a potential violation of the Philippine Data Privacy Act, you also have the right to file a complaint directly with the National Privacy Commission (NPC) of the Philippines, which serves as the supervisory authority for data protection matters in the country.