sugal99 Privacy Policy

sugal99 ("we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the sugal99 Platform. This Privacy Policy describes how sugal99 collects, uses, stores, shares, and protects your personal information when you access or use our website at sugal99.app and all associated services (collectively, the "Platform").

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. It applies to all registered users, visitors, and any other individuals whose personal data is processed by sugal99 in connection with the Platform.

By registering an account or continuing to use the sugal99 Platform, you acknowledge that you have read and understood this Privacy 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 use of the Platform and may request account closure by contacting our support team.

For the purposes of the Data Privacy Act of 2012, sugal99 acts as the Personal Information Controller in respect of the personal data it collects and processes through the Platform. sugal99 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

sugal99 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. Contact details for the DPO are provided in Section 14 of this Policy.

sugal99 collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — you must be 21 or older)
• Nationality and country of residence
• Email address and mobile number
• Residential address (barangay, city/municipality, province)

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo ID (Philippine passport, PhilSys National ID, SSS ID, UMID, driver's license, or PRC ID)
• Proof of address documents
• Selfie or liveness check images submitted during verification

3.3 Financial Data

• GCash or PayMaya account number (masked)
• Bank account details for withdrawal processing (account name and number, bank name)
• Debit card details (card number masked; only last four digits retained)
• Transaction history: deposits, withdrawals, wagers, and winnings

3.4 Gaming & Behavioral Data

• Game session logs, bet history, and game preferences
• Responsible gaming settings (deposit limits, self-exclusion status)
• Bonus and promotion participation records

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Login timestamps and access logs

sugal99 collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and device data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment confirmation data from GCash, PayMaya, and banking partners.
• Regulatory sources: Self-exclusion status from PAGCOR or other recognized gaming authority registers, where applicable.

sugal99 uses your personal data for the following purposes:

sugal99 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

sugal99 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, including the Anti-Money Laundering Act (AMLA), PAGCOR regulations, and the Data Privacy Act itself.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, freely given, and informed consent. You may withdraw consent at any time.

sugal99 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• KYC and identity verification providers: Third-party services that assist in verifying your identity and age in compliance with regulatory requirements.
• Payment processors: GCash, PayMaya, and banking partners involved in processing your deposits and withdrawals. These parties receive only the minimum data necessary to complete the transaction.
• AML and fraud screening services: Compliance technology providers that help sugal99 detect and prevent money laundering, fraud, and other financial crimes.
• Game content providers: Third-party game studios and live dealer operators whose games are hosted on the sugal99 Platform. These providers may receive anonymized session data for game integrity purposes.
• Regulatory authorities: PAGCOR and other competent Philippine government agencies, where disclosure is required by law, court order, or regulatory directive.
• Professional advisers: Legal counsel, auditors, and accountants, subject to professional confidentiality obligations.

sugal99 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC documents: Retained for the duration of your account and for five (5) years following account closure.
• Gaming and session logs: Retained for a minimum of two (2) years for dispute resolution and responsible gaming monitoring purposes.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year for compliance documentation purposes.

Upon expiry of the applicable retention period, sugal99 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

sugal99 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the sugal99 Platform.
• Encryption of sensitive data at rest, including financial records and KYC documents.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with the Data Privacy Act of 2012.

sugal99 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication tokens and security cookies. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits. Disabling these may affect Platform functionality.
• Analytics cookies: Help us understand how players use the Platform so we can improve it. Data collected is aggregated and anonymized.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your explicit consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect your ability to use some features of the sugal99 Platform.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by sugal99:

• Right to be informed: The right to know what personal data sugal99 holds about you and how it is being processed.
• Right of access: The right to request a copy of the personal data sugal99 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please contact sugal99's Data Protection Officer using the contact details in Section 14. sugal99 will respond to all verified data subject requests within thirty (30) calendar days of receipt.

The sugal99 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. sugal99 does not knowingly collect personal data from individuals under the age of 21.

If sugal99 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any winnings accrued by an underage player will be forfeited in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that your child has registered on the sugal99 Platform, please contact our support team immediately so that we can take appropriate action.

sugal99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, sugal99 will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is always displayed at the top of this page. Your continued use of the sugal99 Platform after any amendments have been posted constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the sugal99 Data Protection Officer:

If you are not satisfied with sugal99's response to your data protection concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing the Data Privacy Act of 2012.