scatterlink Privacy Policy — Your Data, Your Rights

1 Overview

This Privacy Policy applies to all players who register and use the scatterlink platform, including the website at scatterlink.pro and the scatterlink mobile application. It explains how scatterlink collects, stores, uses, and protects the personal information of players based in the Philippines.

By creating an account on scatterlink, you acknowledge that you have read this Privacy Policy and consent to the collection and use of your personal data as described here. This policy should be read alongside the Terms and Conditions, which govern your use of the platform overall.

scatterlink is committed to handling your personal information with care and in a manner consistent with applicable data protection principles. We only collect data that is necessary, we keep it secure, and we are transparent about how it is used.

2 What Data We Collect

The personal data scatterlink collects from you depends on how you interact with the platform. The main categories are:

scatterlink does not collect credit card numbers directly. Payment card data, where applicable, is handled entirely by the payment service provider and is not stored on scatterlink servers. We do not accept cryptocurrency as a payment method and do not collect any wallet addresses.

3 How We Use Your Data

scatterlink uses your personal data for the following purposes:

• Account management: To create and maintain your player account, authenticate your identity on login, and keep your account details current.
• Identity verification (KYC): To confirm that you meet the 21+ age requirement and to comply with our obligations under applicable anti-money laundering and know-your-customer processes.
• Payment processing: To process deposits and withdrawals in ₱ PHP via your registered Philippine bank account or e-wallet, and to maintain transaction records.
• Platform security: To detect and prevent fraud, unauthorised account access, bonus abuse, and other prohibited activity described in the Terms and Conditions.
• Customer support: To respond to your queries, resolve account issues, and process responsible gaming requests such as deposit limit changes or self-exclusion.
• Platform improvement: To analyse aggregated usage patterns — such as which game categories are most used or which deposit methods are most common — in order to improve platform features. This analysis is performed on anonymised or aggregated data where possible.
• Communications: To send you account-related notifications such as login alerts, OTP codes, deposit confirmations, and withdrawal status updates. If you have opted in to promotional communications, we may also send you information about offers available in the Promotions section.

4 Legal Basis for Processing

scatterlink processes your personal data on the following legal grounds:

• Contract performance: Processing necessary to provide you with the services you signed up for — including account operation, payment processing, and game access — is based on the contract formed when you accepted the Terms and Conditions.
• Legal obligation: Identity verification, KYC, and transaction record-keeping are required by applicable regulations governing online financial transactions and anti-money laundering obligations.
• Legitimate interests: Fraud prevention, platform security monitoring, and aggregated analytics are carried out based on scatterlink's legitimate interests in operating a secure and functional platform, balanced against your privacy rights.
• Consent: Promotional communications by email or SMS are sent only where you have explicitly opted in. You may withdraw this consent at any time by contacting support or updating your notification preferences in your account settings.

5 Data Sharing

scatterlink does not sell your personal data to third parties. We share your information only in the following limited circumstances:

• Payment providers: Your payment details are shared with the bank or e-wallet provider you use for deposits and withdrawals solely to process your transaction. These providers have their own privacy policies governing how they handle your data.
• KYC and identity verification providers: Your identity documents may be shared with a third-party identity verification service to complete the KYC process. These providers are contractually bound to handle your data confidentially and use it only for the verification purpose.
• Game providers: When you play a game on scatterlink, the game provider receives your session data (such as bet amount, game result, and session duration) to operate the game. Your full personal identity details are not shared with game providers.
• Legal authorities: scatterlink may disclose your data to law enforcement, regulatory bodies, or other government authorities where required to do so by applicable law, or in response to a lawful request.
• Business transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the successor entity. You will be notified of any such change via the email address associated with your account before your data is transferred to a new controller.

All third parties with whom scatterlink shares personal data are required to maintain appropriate technical and organisational security measures and to use your data only for the specified purpose.

6 Data Retention

scatterlink retains your personal data for as long as your account is active and for a period after account closure as required by applicable legal and regulatory obligations. In practice this means:

• Active account data — kept for the duration of your account plus a minimum period after closure to allow for dispute resolution and regulatory review.
• KYC documents — retained for the period required under applicable anti-money laundering regulations from the date of the last transaction or account closure, whichever is later.
• Transaction records — kept for a minimum of five years from the date of each transaction to comply with financial record-keeping requirements.
• Support communications — retained for a reasonable period to allow follow-up and quality assurance, after which they are deleted or anonymised.
• Technical logs — typically retained for a shorter period of up to 12 months for security monitoring purposes, unless a specific incident requires longer retention.

When data is no longer required, scatterlink deletes or anonymises it in a secure manner. You may request early deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to any overriding legal retention obligations.

7 Data Security

scatterlink implements technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Key measures include:

• SSL/TLS encryption across all pages and transaction flows, ensuring that data transmitted between your browser or app and scatterlink servers is encrypted in transit.
• OTP verification available for login and withdrawal actions as an additional layer of account security.
• Access controls ensuring that personal data is accessible only to scatterlink staff who need it to perform their roles, and only to the extent necessary for that purpose.
• Secure storage with data held on servers protected by industry-standard physical and network security controls.
• Regular security reviews of platform infrastructure to identify and address vulnerabilities.

8 Cookies and Tracking

scatterlink uses cookies and similar technologies to operate the platform, remember your preferences, and understand how players use the site. The main categories of cookies used are:

• Strictly necessary cookies: Required for the platform to function. These include session cookies that keep you logged in while you navigate between pages, and security cookies that help protect against cross-site request forgery. You cannot opt out of these without affecting platform functionality.
• Functional cookies: Remember your preferences such as language settings and, where applicable, your last visited game category to personalise your experience.
• Analytics cookies: Used to collect aggregated information about how players navigate the platform — such as which pages are most visited and where players tend to exit. This data helps scatterlink improve the platform experience. Analytics data is processed at an aggregate level and is not used to identify individual players.

You can manage cookie preferences through your browser settings. Blocking all cookies may affect your ability to use certain features of the scatterlink platform, including staying logged in across sessions.

9 Your Rights

As a scatterlink player, you have the following rights in relation to your personal data. To exercise any of these rights, contact support at [email protected] with the subject line "Data Rights Request" and include your registered email address:

• Right to access: You may request a copy of the personal data scatterlink holds about you, along with information about how it is used.
• Right to correction: If any personal data we hold about you is inaccurate or incomplete, you have the right to have it corrected. You can update basic account details directly from your account settings, or contact support for changes to identity-verified fields.
• Right to deletion: You may request that scatterlink delete your personal data where it is no longer necessary for the purposes for which it was collected. Note that deletion requests are subject to any overriding legal obligations to retain data, such as KYC and transaction record requirements.
• Right to restrict processing: You may ask scatterlink to restrict the processing of your personal data in certain circumstances, such as while a correction request is pending.
• Right to withdraw consent: Where processing is based on your consent — specifically, promotional communications — you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used format so that it can be transferred to another service, where technically feasible.

scatterlink will respond to data rights requests within a reasonable timeframe. In complex cases we may need up to 30 days and will inform you if an extension is required.

10 Minors and Age Restrictions

scatterlink is strictly a 21+ platform. We do not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory part of the KYC process, and accounts found to belong to players under 21 are closed immediately, with any associated data handled in accordance with applicable legal requirements.

If you believe that a minor has registered on scatterlink using false information, please contact support immediately at [email protected] so that the account can be reviewed and closed. We take underage gambling seriously and cooperate fully with responsible gaming requirements applicable to the Philippines market.

11 Changes to This Policy

scatterlink may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable requirements. When material changes are made, the updated policy will be published on this page with a revised "last updated" date, and registered players will be notified via the email address associated with their account.

We encourage you to review this policy periodically. Continued use of scatterlink after an updated policy has been published constitutes your acceptance of the revised terms. If you have questions about any change, contact support before continuing to use the platform.

12 Contact Us

If you have questions or concerns about this Privacy Policy, how scatterlink handles your personal data, or if you wish to exercise any of your data rights, please get in touch with our support team. We are available around the clock and aim to respond to all privacy-related queries promptly.

Email us at [email protected] with the subject line "Privacy Query" or "Data Rights Request" so our team can route your message to the right person. Please include your registered account email address and a clear description of your request to help us respond efficiently.

For questions about responsible gaming tools such as deposit limits and self-exclusion, visit the Responsible Gaming page or include "Responsible Gaming" in your email subject line.