Privacy Policy for Scarabph
Philippine Players

1. Who We Are

Scarabph ("we," "us," "our") is a licensed online gaming and sports betting platform operating at scarabph.app, serving players in the Philippines. We act as the data controller for all personal information collected through the platform, including account data, transaction records, gameplay history, and communications.

Scarabph is committed to protecting the personal data of our players in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations (IRR). Our designated Data Protection Officer (DPO) can be reached at dpo@scarabph.app.

This Privacy Policy applies to all players who register, access, or use the Scarabph platform in any capacity, including visitors who browse the site without registering.

2. Personal Data We Collect

Scarabph collects personal data only to the extent necessary for the legitimate operation of the platform and compliance with applicable laws. The categories of data we collect include the following:

We do not intentionally collect sensitive personal information such as racial or ethnic origin, religious beliefs, political affiliations, or health data, unless specifically required by applicable law or responsible gaming obligations.

3. How We Collect Your Data

Scarabph collects personal data through the following channels:

• Direct submission: When you register an account, complete identity verification, make deposits or withdrawals, update your profile, or contact our support team.
• Automated collection: As you use the platform, we automatically collect technical and usage data through cookies, server logs, and analytics tools. This includes your IP address, device identifiers, session data, and browsing behaviour within the platform.
• Third-party sources: We may receive data from payment processors (e.g., GCash, Maya) to verify transactions, from identity verification providers during KYC checks, and from fraud prevention services to protect the security of the platform.
• Publicly available sources: In limited circumstances related to fraud prevention or regulatory compliance, we may cross-reference information against publicly available databases.

4. How We Use Your Personal Data

Scarabph uses your personal data for the following purposes. We only ever process data for a purpose that is compatible with the reason it was originally collected.

• Account management: Creating and maintaining your player account, processing registrations, managing login authentication, and providing access to platform features.
• Transaction processing: Handling deposits, withdrawals, bonus credits, and all financial activity associated with your Scarabph account. This requires sharing relevant data with our licensed payment processing partners.
• Identity and age verification (KYC): Confirming that you are who you say you are, that you meet the minimum age requirement of 18 years, and that your payment methods are legitimately yours.
• Regulatory compliance and Anti-Money Laundering (AML): Scarabph is required by its gaming licence and applicable laws to monitor transactions for suspicious activity, maintain records, and report to regulatory authorities where required.
• Customer support: Responding to your queries, resolving disputes, and handling complaints through our support channels.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviour and offering appropriate interventions such as deposit limits and self-exclusion tools.
• Platform security and fraud prevention: Detecting and preventing unauthorised account access, bonus abuse, collusion, and other security threats.
• Platform improvement: Analysing aggregated usage data to improve the platform's performance, design, and game offering. This analysis is done on anonymised or aggregated data wherever possible.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates — but only if you have opted in to receive them. You can opt out at any time via your account settings or by emailing support.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its IRR, Scarabph processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to fulfil our contract with you — running your account, processing bets and transactions, and providing platform access.
• Legal obligation: Processing required to comply with KYC, AML, and gaming licence requirements imposed by applicable regulatory authorities.
• Legitimate interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and analytics — where our legitimate interests are balanced against your privacy rights.
• Consent: Marketing communications are sent only on the basis of your explicit opt-in consent. You may withdraw consent at any time with no effect on your account or service access.

6. Who We Share Your Data With

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

6.1 Service Providers and Processors

We work with third-party service providers who process data on our behalf under binding data processing agreements. These include payment processors (GCash, Maya, BDO, BPI, UnionBank, Visa/Mastercard partners), KYC and identity verification providers, cloud hosting infrastructure providers, customer support software platforms, and fraud prevention services. All processors are required to maintain confidentiality and process data only as instructed by Scarabph.

6.2 Regulatory and Law Enforcement Authorities

We will disclose personal data to regulators, tax authorities, law enforcement agencies, or courts where required by applicable law or a valid legal order. We aim to notify affected players of such disclosures where we are legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of Scarabph's business, player data may be transferred to the acquiring entity. We will notify active players of any such transfer in advance and ensure the receiving entity is bound by equivalent privacy obligations.

6.4 Responsible Gaming Partners

With your consent or where required by regulation, we may share relevant data with approved responsible gaming support organisations to facilitate self-exclusion or intervention services.

7. Cookies and Tracking Technologies

Scarabph uses cookies and similar technologies to operate the platform, improve user experience, and analyse usage patterns. The types of cookies we use include:

• Essential cookies: Required for platform functionality — login sessions, security tokens, and core navigation. These cannot be disabled without affecting your ability to use the platform.
• Analytics cookies: Used to understand how players interact with the platform, which pages are visited most often, and where errors occur. This data is aggregated and anonymised.
• Preference cookies: Store your settings such as language preference and notification choices so you don't have to re-enter them on each visit.
• Marketing cookies: Used only if you have opted in to receive promotional communications. These help us show you relevant offers based on your activity on the platform.

You can manage your cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to place bets, make deposits, or access your account on Scarabph.

8. How Long We Keep Your Data

Scarabph retains personal data for as long as necessary to fulfil the purposes outlined in this policy, subject to the following general retention guidelines:

• Active account data: Retained for the duration of your account membership plus an additional 5 years following closure, in line with regulatory record-keeping requirements.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, as required by AML and gaming licence regulations.
• KYC and identity documents: Retained for 5 years following account closure or the last transaction, whichever is later.
• Support communications: Retained for 3 years from the date of the interaction.
• Marketing consent records: Retained for 3 years from the date consent was given or last renewed.
• Technical and usage logs: Typically retained for 12 to 24 months before being anonymised or deleted.

When data is no longer required, it is securely deleted or anonymised in accordance with our data disposal procedures. You may request earlier deletion of non-regulatory data by contacting us — see Section 9 for details.

9. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by Scarabph. We will respond to all verified requests within 30 calendar days.

• Right to be Informed: You have the right to know what personal data we hold about you, why we hold it, and how we use it. This Privacy Policy fulfils that right.
• Right to Access: You may request a copy of the personal data Scarabph holds about you.
• Right to Rectification: If any of your personal data is inaccurate or incomplete, you have the right to have it corrected. You can update most account details directly through your profile settings.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected. Note that certain data must be retained for regulatory compliance and cannot be deleted at your request.
• Right to Data Portability: You may request a copy of your personal data in a structured, machine-readable format to transfer to another service.
• Right to Object: You may object to processing based on legitimate interest, including profiling for direct marketing. Marketing opt-outs take effect within 48 hours.
• Right to Restrict Processing: In certain circumstances, you may request that we temporarily pause processing of your data while a dispute is resolved.
• Right to Lodge a Complaint: If you believe Scarabph has handled your data in breach of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

10. How We Protect Your Data

Scarabph takes the security of your personal data seriously. We maintain a range of technical and organisational security measures designed to protect your information against unauthorised access, disclosure, loss, or destruction.

11. Children's Privacy

The Scarabph platform is strictly for adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If we discover that a minor has registered an account or submitted personal data to the platform, we will immediately close the account, delete all associated data, and refund any balance to the depositing payment method.

If you believe a minor has registered on Scarabph, please notify us immediately at support@scarabph.app. We will investigate and act promptly.

12. International Data Transfers

Some of Scarabph's third-party service providers — including cloud infrastructure providers and KYC verification services — may process data in countries outside the Philippines. Where personal data is transferred internationally, Scarabph ensures that appropriate safeguards are in place, including data processing agreements that require the receiving party to provide equivalent levels of data protection to those required under Philippine law.

We do not transfer your data to countries that do not offer adequate data protection standards without implementing appropriate contractual protections. For more information about specific international transfer arrangements, contact our DPO at dpo@scarabph.app.

13. Changes to This Privacy Policy

Scarabph may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable legal requirements. When we make material changes, we will notify active players by email and display a notice within the platform at least 14 days before the changes take effect.

The "Last Updated" date at the top of this page always reflects the most recent version. We encourage you to review this policy periodically. Continued use of the Scarabph platform after the effective date of any update constitutes your acknowledgement of the revised policy. Previous versions are available upon request by emailing our DPO.

14. Contact Us and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or how Scarabph handles your personal data, please reach out through the following channels:

• Data Protection Officer: dpo@scarabph.app
• General Support: support@scarabph.app
• Live Chat: Available 24/7 when logged in to your Scarabph account
• Response time: DPO enquiries — within 5 business days; General support — within 24 hours

If you are not satisfied with our response to a privacy-related complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines, which oversees enforcement of the Data Privacy Act of 2012.