smvip Privacy Policy

This Privacy Policy ("Policy") describes how smvip ("the Platform," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "the Member," or "the User") who access or use the smvip platform, including the website at smvip.ws and any associated applications or services operated under the smvip brand.

This Policy is issued in accordance with applicable Philippine data protection legislation, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, and forms part of the smvip Terms and Conditions, which are available at smvip.ws/terms-conditions.

By registering a smvip account or by continuing to use the smvip platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue your use of the smvip platform and close your account by contacting customer support.

For the purposes of applicable data protection law, smvip is the data controller responsible for the personal data collected through the smvip platform. As data controller, smvip determines the purposes and means by which your personal data is processed.

smvip has designated a Data Protection Officer (DPO) to oversee the Platform's compliance with data protection obligations. You may contact the smvip DPO at any time using the contact details provided in Section 13 of this Policy.

3.1 Data You Provide Directly

When you register a smvip account, make transactions, contact support, or participate in promotions, you may provide us with the following categories of personal data:

3.2 Data Collected Automatically

When you access the smvip platform, certain technical and usage data is collected automatically through the operation of the platform and through cookies and similar tracking technologies:

• Device & Technical Data: IP address, browser type and version, operating system, device identifiers, screen resolution, and language settings;
• Usage Data: Pages visited, games played, session duration, wager amounts, win/loss history, bonus usage, and feature interactions;
• Location Data: Approximate geographic location derived from IP address, used for jurisdiction verification and fraud prevention;
• Cookie Data: Session tokens, preference cookies, and analytics identifiers as described in Section 7.

3.3 Data From Third Parties

smvip may receive personal data about you from third-party sources in the following circumstances: identity verification agencies engaged for KYC purposes; payment service providers processing your deposits and withdrawals; fraud detection and anti-money laundering screening services; and publicly available sources where permitted by applicable law for identity verification purposes.

smvip uses your personal data for the following purposes, each of which has a corresponding legal basis as set out in Section 5:

• Account Creation & Management: To register your smvip account, verify your identity, maintain your account, and provide you with access to platform services;
• Transaction Processing: To process deposits, withdrawals, and game wagers, and to maintain accurate transaction records;
• Identity & Age Verification: To verify that you meet the minimum age requirement of 21 years and to confirm the accuracy of the personal information you have provided;
• Regulatory Compliance: To meet anti-money laundering (AML), counter-terrorism financing (CTF), Know Your Customer (KYC), and other legal obligations applicable to smvip's operations;
• Fraud & Security: To detect, investigate, and prevent fraudulent activity, account abuse, collusion, money laundering, and unauthorized access;
• Responsible Gaming: To administer responsible gaming tools including deposit limits, self-exclusion, and player protection interventions in accordance with our Responsible Gaming Policy;
• Customer Support: To respond to your enquiries, resolve disputes, and improve the quality of our support services;
• Platform Improvement: To analyse usage patterns, identify technical issues, develop new features, and optimise the smvip platform experience;
• Promotional Communications: To send you information about smvip promotions, bonuses, and VIP programme updates where you have consented to receive such communications or where we have a legitimate interest in doing so.

smvip processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual Necessity: Processing that is necessary to perform the smvip Terms and Conditions — including account registration, game provision, and transaction processing;
• Legal Obligation: Processing required for smvip to comply with applicable laws and regulations, including AML, KYC, and gaming regulatory requirements;
• Legitimate Interests: Processing carried out for smvip's legitimate business interests where those interests are not overridden by your data protection rights — including fraud prevention, platform security, and service improvement;
• Consent: Where processing is based on your freely given, specific, and informed consent — including the sending of promotional marketing communications. You may withdraw consent at any time by updating your communication preferences in your smvip account settings.

smvip does not sell or rent your personal data to any third party. We may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

6.1 Service Providers

smvip engages trusted third-party service providers who process personal data on our behalf under written data processing agreements. These include: identity verification and KYC providers; payment processing and anti-fraud service providers; cloud hosting and data storage providers; customer support platform providers; and analytics and platform monitoring services. All service providers are contractually required to process your data only on smvip's instructions and in accordance with applicable data protection law.

6.2 Game Content Providers

Where technically necessary for the provision of specific games, limited data such as your account identifier and wager information may be shared with licensed game content providers whose titles are available on the smvip platform. These providers are prohibited from using such data for any purpose other than game delivery.

6.3 Regulatory & Law Enforcement Authorities

smvip may disclose personal data to relevant regulatory bodies, law enforcement agencies, or other government authorities where required to do so by applicable law, court order, or regulatory direction. smvip will notify affected Members of such disclosures where permitted by law to do so.

6.4 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of all or part of smvip's business, your personal data may be transferred to the relevant successor entity as part of that transaction, subject to equivalent data protection commitments being maintained by the acquiring party.

smvip uses cookies and similar technologies to operate the platform, remember your preferences, analyse usage, and support security functions. The following categories of cookies are used:

You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the smvip platform. smvip does not use cookies to serve third-party advertising or track your activity across unaffiliated websites.

smvip retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting obligations. In determining the appropriate retention period, smvip considers the nature and sensitivity of the data, the purposes for which it is processed, and applicable legal retention requirements.

As a general guide, smvip applies the following retention periods:

• Active account data: Retained for the duration of your account relationship with smvip;
• Transaction and financial records: Retained for a minimum of five (5) years following the relevant transaction, in accordance with AML regulatory requirements;
• KYC and identity documents: Retained for a minimum of five (5) years following account closure or the last transaction, whichever is later;
• Customer support records: Retained for two (2) years following resolution of the relevant support matter;
• Marketing data: Retained until you withdraw consent or opt out of marketing communications, after which it is deleted within 30 days.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with smvip's data destruction procedures.

Under the Data Privacy Act of 2012 and applicable regulations, smvip Members have the following rights with respect to their personal data. To exercise any of these rights, contact the smvip Data Protection Officer using the details in Section 13.

smvip will respond to all data rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further two months, in which case smvip will inform you of the extension and the reasons for it. smvip will not charge a fee for exercising your data rights unless requests are manifestly unfounded or excessive.

smvip implements a comprehensive set of technical and organisational security 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 transmitted between your device and the smvip platform;
• Encryption of sensitive data at rest, including payment details and identity documents;
• Role-based access controls limiting personnel access to personal data to those with a legitimate business need;
• Multi-factor authentication requirements for smvip administrative systems;
• Regular penetration testing and security audits conducted by independent third parties;
• Intrusion detection and prevention systems monitoring the smvip infrastructure;
• Formal data breach response procedures, including notification obligations to affected Members and relevant authorities where required by law.

While smvip takes all reasonable steps to protect your personal data, no transmission of data over the internet or electronic storage system is completely secure. smvip cannot guarantee absolute security, and you use the platform at your own risk in this regard. You are responsible for maintaining the security of your own account credentials and for notifying smvip immediately if you suspect any unauthorised use of your account.

smvip services are strictly intended for individuals who are 21 years of age or older, in accordance with applicable Philippine gaming regulations. smvip does not knowingly collect personal data from any individual under the age of 21. If smvip becomes aware that personal data has been collected from an individual under 21 years of age, that data will be deleted immediately and the associated account will be closed.

If you are a parent or guardian and believe that a minor may have registered a smvip account or provided personal information to smvip, please contact our customer support team immediately so that appropriate action can be taken.

smvip reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, new regulatory requirements, or platform developments. When material changes are made to this Policy, smvip will notify registered Members by email to the address on file and by posting a prominent notice on the smvip platform prior to the changes taking effect.

The updated Policy will be published at smvip.ws/privacy-policy with the revised effective date clearly indicated. Your continued use of the smvip platform following notification of changes to this Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you should close your account and cease using the platform.

For any questions, concerns, or requests relating to this Privacy Policy or smvip's data processing practices, or to exercise any of your data rights under Section 9, please contact the smvip Data Protection Officer through the following channels:

• Live Chat: Available 24/7 at smvip.ws — the fastest way to reach our team for urgent privacy matters
• Email: [email protected] — for formal data subject requests and written privacy enquiries
• Languages: Our support team handles privacy matters in both English and Tagalog

smvip commits to acknowledging all data rights requests within five (5) business days of receipt and to providing a substantive response within the timeframes set out in Section 9. For formal complaints that cannot be resolved through our internal process, you may escalate to the National Privacy Commission of the Philippines.