ScatterWin Privacy Policy – Your Data, Handled with Care

Privacy Policy

1. About This Policy

This Privacy Policy explains how ScatterWin ("we", "us", "the platform") collects, stores, uses, and protects personal information when you register and use the ScatterWin platform at scatterwin.vu. It applies to all registered players and to anyone who accesses the platform, regardless of whether they have an active account.

This policy is part of the broader set of terms governing your use of ScatterWin, alongside the Terms & Conditions and the Responsible Gaming guidelines. By registering or using the platform, you acknowledge that you have read and understood this policy.

2. What Data We Collect

ScatterWin collects personal data in the following categories:

We do not collect data that isn't necessary for the purposes listed below. We do not collect sensitive personal data such as biometric information or health data.

3. How We Use Your Data

ScatterWin uses the personal data we hold for the following purposes:

• Account operation — Creating and managing your player account, processing logins, and authenticating your identity via OTP.
• Transaction processing — Handling deposits and withdrawals in Philippine Peso through your registered payment method (GCash, Maya, bank transfer).
• Identity verification (KYC) — Confirming that you meet the eligibility requirements for playing on ScatterWin, including the 21-years-of-age requirement.
• Fraud and security monitoring — Detecting unusual account activity, preventing unauthorized access, and protecting both you and the platform from fraudulent use.
• Legal compliance — Meeting obligations under applicable Philippine laws, including anti-money laundering requirements where relevant.
• Customer support — Responding to your queries and resolving account issues.
• Platform improvement — Analysing aggregated usage patterns to improve the ScatterWin experience. This is done using anonymised or aggregated data where possible.
• Responsible gaming — Monitoring account activity to identify potential problem gaming behaviour and applying account limits where appropriate.

We do not use your data for automated decision-making that produces legal or similarly significant effects without a review process. We do not sell your personal data to third parties for marketing purposes.

4. Data Sharing & Disclosure

ScatterWin does not sell, rent, or trade your personal data. We share data only in the following limited circumstances:

• Payment processors — To process your deposits and withdrawals, relevant transaction data is shared with your chosen payment channel (e.g., GCash or Maya infrastructure, local banking partners). These third parties are required to handle your data securely and are bound by their own privacy obligations.
• Identity verification services — KYC processes may involve third-party verification services that check your identity documents against relevant records. These services are used solely for verification and do not have access to your gaming activity.
• Legal authorities — ScatterWin may disclose personal data to law enforcement or regulatory bodies where legally required to do so, for example in response to a lawful investigation or court order.
• Platform service providers — Technical service providers who support the operation of the platform (e.g., hosting infrastructure, security monitoring tools) may have limited access to data as necessary to perform their role. They are contractually bound not to use this data for their own purposes.

We do not share your data with advertisers or unrelated third parties.

5. Data Security

ScatterWin applies multiple layers of technical and operational security to protect your personal data:

• SSL encryption — All data transmitted between your device and the ScatterWin platform is encrypted using SSL (Secure Sockets Layer). This applies whether you are using the Android app or accessing the platform through a mobile browser.
• OTP verification — Logins can be secured with one-time password (OTP) authentication, which adds a second factor beyond your password and significantly reduces the risk of unauthorized access.
• Access controls — Internal access to player data is limited to staff and systems that require it to perform their functions. Access is logged and reviewed.
• Secure storage — Sensitive account data, including payment details and identity documents, is stored using appropriate encryption and access controls.

No system is entirely without risk. We encourage you to protect your account by enabling OTP verification, using a strong and unique password, locking your device when not in use, and avoiding access from unsecured public Wi-Fi networks when making deposits or withdrawals.

6. Cookies & Tracking

ScatterWin uses cookies and similar technologies to support the operation of the platform. These fall into the following categories:

• Essential cookies — Required for the platform to function. These include session cookies that keep you logged in during a session and security cookies used for fraud prevention. These cannot be disabled without affecting your ability to use the platform.
• Functional cookies — Remember your preferences, such as language settings, to make your experience consistent across sessions.
• Analytics cookies — Used to understand how players interact with the platform in aggregate, helping us identify areas for improvement. These use anonymised data and do not track individual behaviour across unrelated websites.

ScatterWin does not use third-party advertising cookies or cross-site tracking technologies to profile you for marketing purposes.

7. Your Rights

As a ScatterWin player based in the Philippines, you have the following rights in relation to your personal data:

• Right to access — You may request a copy of the personal data we hold about you. We will provide this in a readable format within a reasonable timeframe.
• Right to correction — If any of your personal data is inaccurate or out of date, you have the right to ask us to correct it. Some corrections may require supporting documentation.
• Right to deletion — You may request the deletion of personal data that we no longer have a legal or operational basis to hold. Note that certain data — such as transaction records — may need to be retained for legal compliance reasons even after account closure.
• Right to data portability — You may request a copy of your personal data in a structured, commonly used format to transfer to another service where technically feasible.
• Right to object — You may object to certain types of data processing, for example where processing is based on legitimate interest rather than a legal obligation or contractual necessity.

To exercise any of these rights, contact ScatterWin support at [email protected] with your request. We will verify your identity before processing the request and respond within a reasonable period.

8. Data Retention

ScatterWin retains personal data for as long as your account is active and for a reasonable period following account closure, as required by applicable legal and operational obligations. The typical retention principles we apply are:

• Account and identity data is retained for the duration of your account and for a period after closure to meet legal obligations, including anti-money laundering record-keeping requirements.
• Transaction records are retained in line with applicable financial record-keeping requirements under Philippine law.
• Support communications are retained for a reasonable period to allow for follow-up queries and quality review.
• Technical logs (e.g., login records) are retained for security monitoring purposes and then deleted on a rolling schedule.

When data is no longer needed for any applicable purpose, it is deleted or anonymised.

9. Changes to This Policy

ScatterWin may update this Privacy Policy from time to time to reflect changes in platform operations, technology, or applicable law. When material changes are made, we will revise the "Last updated" date at the top of this page and, where appropriate, notify registered players via email or an in-platform notice.

Continued use of the platform after an updated Privacy Policy is published constitutes your acceptance of the revised terms. If you have questions about any changes, contact us before continuing to use the platform.

10. Contact Us

For any privacy-related queries, requests to exercise your data rights, or concerns about how your personal information is being handled, please reach out to the ScatterWin team directly: