Privacy Policy

1. About This Privacy Policy

This Privacy Policy ("Policy") describes how smsm.ph, operating the smsmph.club platform ("smsm.ph", "we", "us", "our"), collects, processes, stores, and protects personal data relating to users ("you", "Player", "Data Subject") of the smsm.ph Casino platform and associated services.

This Policy applies to all personal data collected via the smsmph.club website and mobile-browser platform, including data submitted during account registration, identity verification, deposit and withdrawal processing, customer support interactions, and platform usage generally. By registering an account on smsm.ph or continuing to use the platform, you acknowledge that you have read and understood this Policy.

This Policy should be read alongside our Terms and Conditions and Responsible Gaming Policy, both of which contain additional provisions relevant to your use of the smsm.ph platform.

2. Data Controller

smsm.ph is the Data Controller responsible for your personal data as collected and processed through the smsmph.club platform. As Data Controller, smsm.ph determines the purposes and means of processing your personal data in accordance with the Data Privacy Act of 2012 (Republic Act 10173), its Implementing Rules and Regulations, and applicable National Privacy Commission (NPC) issuances.

A designated Data Privacy Officer (DPO) is responsible for overseeing smsm.ph's data protection obligations. You may contact the DPO for any privacy-related requests or concerns via: [email protected].

3. Personal Data We Collect

smsm.ph collects the following categories of personal data in the course of providing the platform and related services:

3.1 Registration and Identity Data

• Full legal name;
• Date of birth (for age verification, minimum 21 years);
• Philippine mobile number (used as primary account identifier and OTP channel);
• Username and encrypted account password;
• Email address (where provided).

3.2 Identity Verification (KYC) Data

• Government-issued Philippine identification document type and number (e.g., PhilSys national ID, UMID, driver's licence, passport);
• Photograph or scan of the identity document;
• Selfie or facial verification image (where required for enhanced KYC);
• Proof of address documentation (where requested).

3.3 Financial and Transaction Data

• GCash account reference (tokenised — full account credentials are not retained);
• Bank account name and number (for bank transfer withdrawals, verified against the account holder's identity);
• Deposit and withdrawal transaction records, amounts, timestamps, and reference numbers;
• Betting history, game session logs, and account balance records.

3.4 Technical and Usage Data

• IP address and approximate geolocation (country and region level);
• Device type, operating system, and browser type;
• Session timestamps and login history;
• Pages visited, games accessed, and interaction patterns within the platform;
• Cookie identifiers and similar tracking technologies (see Section 7).

3.5 Communications Data

• Records of live chat conversations with smsm.ph support staff;
• Email correspondence with smsm.ph;
• Responses to surveys or feedback forms (where participated in voluntarily).

4. How We Collect Your Personal Data

smsm.ph collects personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal request, contact support, or participate in promotions;
• Automatically — through cookies, server logs, and analytics tools as you navigate and interact with the smsmph.club platform;
• From third-party payment processors — transaction confirmation data from GCash, PayMaya, and banking payment gateways used to process your deposits and withdrawals;
• From identity verification providers — where a third-party KYC service is used to validate the authenticity of identity documents, the results of that verification are shared with smsm.ph;
• From fraud prevention and AML screening services — where applicable, as part of our legal compliance obligations.

5. Purposes of Processing Your Personal Data

smsm.ph processes your personal data for the following purposes:

6. Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173), smsm.ph relies on the following legal bases for processing your personal data:

• Contractual necessity — processing required to register your account, process transactions, and provide the services you have requested;
• Legal obligation — processing required to comply with applicable Philippine laws and regulations, including anti-money laundering (AMLA) obligations, PAGCOR compliance requirements, and the Data Privacy Act itself;
• Legitimate interests — processing for fraud prevention, platform security, and responsible gaming monitoring, where our legitimate interests in protecting the platform and other users are not overridden by your privacy rights;
• Consent — for optional processing such as direct marketing communications, where we have obtained your prior explicit consent.

7. Cookies & Tracking Technologies

7.1 What We Use

The smsmph.club platform uses cookies and similar tracking technologies to operate core platform functions, maintain your login session, and analyse platform usage. Cookies are small text files stored on your device when you visit the platform.

7.2 Types of Cookies

• Strictly Necessary Cookies — required for the platform to function, including session management and security tokens. These cannot be disabled without affecting platform functionality;
• Functional Cookies — store your preferences such as language settings and remembered login details (where "Keep me signed in" is enabled);
• Analytics Cookies — collect aggregated, anonymised data about how users interact with the platform to help us improve performance and user experience;
• Security Cookies — support fraud detection and abuse prevention systems.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the smsm.ph platform. smsm.ph does not use third-party advertising or behavioural tracking cookies.

8. Sharing Your Personal Data with Third Parties

smsm.ph does not sell, rent, or trade your personal data to third parties for their independent marketing or commercial purposes. We share personal data only in the following circumstances:

• Payment processors — GCash, PayMaya, and banking payment gateways receive necessary transaction data to process your deposits and withdrawals;
• Identity verification providers — KYC and document verification service providers receive identity document data to authenticate your identity for regulatory compliance;
• Fraud and AML screening services — data may be shared with anti-money laundering screening tools as required under AMLA obligations;
• Technology and hosting providers — cloud hosting, data storage, and platform infrastructure providers access data only as necessary to deliver their services under binding data processing agreements;
• Regulatory and law enforcement authorities — where required by applicable Philippine law, court order, or regulatory directive, smsm.ph will disclose personal data to competent authorities;
• Game content providers — game studios and live dealer providers receive only the minimum data necessary to operate their games within the smsm.ph platform (typically a session token and anonymised player identifier, not your full personal details).

9. Data Retention

smsm.ph retains your personal data for as long as is necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by applicable law.

In general, smsm.ph applies the following retention guidelines:

• Active account data — retained for the duration of your account's existence on the smsm.ph platform;
• Transaction records and financial data — retained for a minimum of five (5) years following the transaction, as required under applicable Philippine anti-money laundering regulations (AMLA, RA 9160 as amended);
• KYC and identity verification documents — retained for a minimum of five (5) years from the date of verification or account closure, whichever is later;
• Customer support communications — retained for three (3) years for quality assurance and dispute resolution purposes;
• Marketing consent records — retained until consent is withdrawn plus one (1) year for compliance evidence purposes.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

10. Data Security

smsm.ph implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and the smsm.ph platform;
• Encrypted storage for sensitive personal data including passwords (hashed and salted) and KYC document data at rest;
• Access controls — staff access to personal data is restricted on a need-to-know basis with role-based permissions and access logging;
• OTP-based authentication for account login and sensitive account changes, reducing the risk of unauthorised account access;
• Regular security assessments of the platform infrastructure.

Notwithstanding the above, no data transmission or storage system can be guaranteed to be completely secure. You play an important role in your own data security by keeping your smsm.ph account credentials confidential and notifying us immediately of any suspected unauthorised access.

11. Your Rights Under RA 10173

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

To exercise any of the above rights, submit a written request to the smsm.ph Data Privacy Officer at [email protected]. smsm.ph will respond to all valid data subject requests within thirty (30) days of receipt. Identity verification may be required before processing certain requests.

12. Children and Minors

The smsm.ph platform is strictly intended for adults aged 21+ only, as required by PAGCOR's minimum age for online gambling in the Philippines. smsm.ph does not knowingly collect personal data from individuals under 21 years of age.

If we become aware that personal data has been collected from an individual under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you have reason to believe that a minor has registered an account on smsm.ph, please notify us immediately at [email protected] or via our live chat support.

13. Marketing Communications

smsm.ph may send you promotional communications about bonuses, new games, seasonal offers, and platform updates via SMS to your registered Philippine mobile number or email address (where provided), subject to your consent.

You may withdraw your consent to receive marketing communications at any time by: (a) updating your notification preferences in the smsm.ph account settings; (b) replying STOP to any SMS marketing message; or (c) contacting the support team via live chat. Withdrawal of marketing consent does not affect the lawfulness of any processing carried out prior to withdrawal.

Withdrawal of marketing consent will not affect your ability to receive transactional communications — including deposit and withdrawal confirmation messages, OTP codes, and account security alerts — which are sent regardless of marketing preferences as they are necessary for the operation of your account.

14. Changes to This Privacy Policy

smsm.ph reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or platform services. The date of the most recent revision is displayed at the top of this document.

Where changes are material — meaning they significantly affect the way your personal data is processed or your rights as a Data Subject — smsm.ph will provide advance notice to registered account holders via the mobile number or email address on record, or by displaying a prominent notice on the platform.

Your continued use of the smsm.ph platform following the effective date of any revised Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must cease using the platform and may request account closure as described in the Terms and Conditions.

15. Contact Us & Data Privacy Officer

For all privacy-related enquiries, data subject access requests, complaints, or to exercise any of your rights under RA 10173, please contact smsm.ph's designated Data Privacy Officer:

• Data Privacy Officer Email: [email protected] — responses within 30 business days
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the support widget within the smsm.ph platform at smsmph.club

If you are not satisfied with smsm.ph's response to your privacy concern, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC). Information about the NPC's complaint process is available through the NPC's official government channels.