Scattermeter Privacy Policy

1Who This Policy Applies To

This Privacy Policy applies to all individuals who access or use the Scattermeter website and mobile application, including:

• Registered account holders who have completed sign-up
• Visitors who browse the platform without registering
• Individuals who contact Scattermeter's support team by any channel

Scattermeter is a platform intended solely for Philippine residents aged 21 and above. By using the platform, you represent that you meet these requirements.

2Information We Collect

Scattermeter collects personal information in the following categories:

3How We Use Your Data

Scattermeter uses the personal data it collects for the following specific purposes:

• Account creation and management — creating your account, verifying your identity, and enabling access to the platform
• Transaction processing — processing deposits and withdrawals in Philippine Peso through your registered payment method
• Identity and age verification (KYC) — confirming that you meet the 21+ age requirement and verifying your identity before withdrawal processing
• Platform security — detecting and preventing fraud, multi-accounting, money laundering, and other prohibited conduct
• Customer support — responding to queries, resolving disputes, and providing account assistance
• Responsible gaming — monitoring gaming patterns to identify signs of problem gambling and administering self-exclusion and limit requests
• Legal and regulatory compliance — maintaining records required by applicable Philippine law and responding to lawful requests from authorities
• Platform improvement — analysing aggregate usage patterns to improve the Scattermeter experience

We do not use your personal data for unsolicited third-party marketing or profiling for commercial sale.

4Legal Basis for Processing

Scattermeter processes your personal data under the following legal bases, consistent with the Data Privacy Act of 2012 (Republic Act No. 10173):

• Contractual necessity — processing required to fulfil our obligations to you as a registered account holder, including payment processing and account management
• Legal obligation — processing required to comply with applicable Philippine law, including anti-money-laundering obligations and identity verification requirements
• Legitimate interests — processing for fraud prevention, platform security, and the safety of all users, where these interests are not overridden by your rights
• Consent — where you have expressly given consent, such as opting in to receive promotional communications

5Sharing Your Information

Scattermeter does not sell or rent your personal data. We share your information only in the following limited circumstances:

• Payment processors and banking partners — to process your deposits and withdrawals through Philippine banking and e-wallet channels. These parties are bound by confidentiality obligations.
• Identity verification providers — to complete KYC checks required before withdrawals are processed.
• Platform technology providers — third-party software and infrastructure providers who support platform operations. All are bound by data processing agreements.
• Legal and regulatory authorities — where Scattermeter is legally required to disclose information in response to a lawful request, court order, or regulatory requirement under Philippine law.
• Fraud prevention services — to detect and prevent fraud, collusion, and prohibited account activity.

Any third party receiving your data is contractually required to handle it securely and use it only for the specific purpose for which it was shared.

6Cookies & Tracking Technologies

Scattermeter uses cookies and similar technologies to operate the platform, maintain your session, and understand how users interact with the site. Categories of cookies used include:

• Essential cookies — required for core platform functionality such as login sessions and security tokens. These cannot be disabled without affecting platform usability.
• Analytics cookies — used to understand aggregate traffic patterns and platform performance. Data collected is anonymised and used internally.
• Preference cookies — used to remember settings you have applied, such as language or display preferences.

You can manage cookie preferences through your browser settings. Blocking essential cookies may affect your ability to use some features of the Scattermeter platform.

7Data Retention

Scattermeter retains your personal data for as long as your account is active and for a period thereafter as required by applicable law or legitimate business necessity. Specific retention guidelines:

• Account and identity data — retained for the duration of the account and for a minimum period after account closure as required by anti-money-laundering regulations.
• Transaction records — retained for a minimum period as required by Philippine financial regulations.
• Support communications — retained for a reasonable period after the interaction is resolved, for quality and dispute reference purposes.
• Technical and activity logs — retained for security and fraud prevention purposes for a defined period, after which they are deleted or anonymised.

When data is no longer required, it is securely deleted or anonymised in line with our internal data retention procedures.

8Your Rights Over Your Data

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by Scattermeter:

• Right to be informed — to know what data we hold about you and how we use it (this policy fulfils that obligation)
• Right to access — to request a copy of the personal data we hold on your account
• Right to correction — to request that inaccurate or outdated data be corrected
• Right to erasure — to request deletion of your personal data, subject to our legal retention obligations
• Right to object — to object to processing of your data for specific purposes, including direct marketing
• Right to data portability — to receive your personal data in a structured, commonly used format where applicable

Please note that some data cannot be deleted while your account remains active or while we are legally required to retain it for compliance purposes.

9Children and Minors

Scattermeter is strictly an adult platform. We do not knowingly collect or process personal data from individuals under the age of 21. The platform is not directed at minors and we take active steps to verify the age of users during the registration and KYC process.

If we become aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on the platform, please contact our support team immediately.

10Security Measures

Scattermeter implements a range of technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure:

• SSL/TLS encryption on all data transmitted between your device and our servers
• OTP (One-Time Password) verification for financial transactions and security-sensitive account actions
• Access controls limiting internal access to personal data to staff who require it for their role
• Secure data storage with encrypted databases and regular security reviews
• Fraud detection systems monitoring account activity for unusual patterns

While we take reasonable precautions to protect your data, no online system can guarantee absolute security. You are also responsible for keeping your login credentials secure and not sharing them with any third party. If you believe your account has been compromised, contact us immediately.

11Changes to This Privacy Policy

Scattermeter may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered users through the platform and, where appropriate, by email to your registered address.

The updated policy will be posted on this page with a revised "Last updated" date. We encourage you to review this page periodically. Continued use of the Scattermeter platform after changes are posted constitutes your acceptance of the revised Privacy Policy.

12Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact the Scattermeter Privacy and Data team:

For a full overview of your account terms, please also review our Terms & Conditions and Responsible Gaming pages.