Privacy Policy – Sugal99

1 Introduction

Sugal99 ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all users who access or register on our online gaming platform at sugal99.net. This Privacy Policy ("Policy") sets out in detail the types of personal information we collect, the purposes for which we use it, the conditions under which we may share it, and the rights available to you as a data subject.

This Policy applies to all personal data collected through the Sugal99 website, mobile application, customer support channels, and any other touchpoints through which you interact with us. It should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

We take our obligations under applicable Philippine data protection legislation seriously. Our practices are designed to ensure that your personal data is handled with the care, transparency, and respect it deserves. If you do not agree with this Policy, please do not use the Sugal99 platform.

2 Data Controller

For the purposes of applicable data protection law, Sugal99 is the data controller responsible for your personal information. As data controller, we determine the purposes and means by which your personal data is processed.

If you have any questions about how your personal data is handled, or wish to exercise any of your data subject rights, you may contact our Data Protection team directly. Contact details are provided in Section 14 of this Policy.

3 Personal Data We Collect

Sugal99 collects personal data that is necessary, adequate, and relevant to the purposes for which it is processed. The categories of personal data we collect include:

3.1 Identity & Contact Data

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Gender
• Nationality and country of residence
• Residential address
• Email address
• Mobile phone number

3.2 Account & Verification Data

• Username and encrypted password
• Government-issued identification documents (e.g., Philippine passport, SSS ID, driver's licence, PhilSys national ID) submitted for KYC verification
• Proof of address documents
• Selfie or facial image submitted for identity verification purposes

3.3 Financial Data

• Payment method details (e.g., GCash account number, PayMaya account, BPI, BDO, or Metrobank account details)
• Transaction history, including deposits, withdrawals, and wager records
• Source of funds information where required for AML compliance

3.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session data, login timestamps, and activity logs
• Game history and betting patterns
• Cookie identifiers and similar tracking data (see Section 10)

3.5 Communications Data

• Records of communications between you and our customer support team
• Feedback, survey responses, and complaints submitted to Sugal99
• Marketing preferences and opt-in/opt-out records

4 How We Collect Your Data

Sugal99 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the platform, including through cookies, log files, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from risk management partners; payment data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank.
• Regulatory sources: Information received from regulatory authorities or law enforcement agencies in connection with legal obligations or investigations.

5 How We Use Your Personal Data

Sugal99 uses your personal data for the following purposes:

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

Sugal99 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations, KYC requirements, and regulatory reporting duties.
• Legitimate interests: Processing necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Sharing Your Personal Data

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:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your financial transactions.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and comply with regulatory requirements.
• Regulatory authorities: Philippine gaming regulators, the Anti-Money Laundering Council (AMLC), and other government bodies where disclosure is required by law.
• Law enforcement: Police, courts, or other authorities where we are legally required or permitted to disclose information.
• Technology service providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Professional advisers: Lawyers, auditors, and consultants bound by confidentiality obligations.

8 Data Retention

Sugal99 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and regulatory requirements.
• Transaction 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 a minimum of five (5) years following the end of the business relationship.
• Customer support records: Retained for up to three (3) years from the date of the interaction.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.
• Technical and usage logs: Retained for up to twelve (12) months for security and analytics purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

9 Security Measures

Sugal99 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Multi-factor authentication for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

10 Cookies & Tracking Technologies

Sugal99 uses cookies and similar tracking technologies to enhance your experience on our platform. A cookie is a small text file placed on your device when you visit a website. We use the following types of cookies:

• Essential cookies: Strictly necessary for the platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Analytics cookies: Used to collect anonymised information about how users interact with the platform, helping us improve performance and user experience.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalise your experience.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content and track the effectiveness of our marketing campaigns.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Sugal99 platform. For detailed instructions on managing cookies in your browser, please refer to your browser's help documentation.

11 Your Data Subject Rights

Under applicable Philippine data protection law, you have the following rights in relation to your personal data held by Sugal99:

• Right to be informed: The right to be told how your personal data is being used, as set out in this Policy.
• Right of access: The right to request a copy of the personal data we hold 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, subject to our legal retention obligations.
• Right to object: The right to object to 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 format and to transmit it to another controller where technically feasible.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our support team using the details in Section 14. We will respond to all valid requests within thirty (30) days. In some cases, we may need to verify your identity before processing your request.

12 Minors & Age Restriction

Sugal99 is strictly an adult platform. We do not knowingly collect personal data from individuals under the age of 21 years. The minimum age to register and use Sugal99 is 21 years, in accordance with Philippine law applicable to casino-style gaming.

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 believe a minor has registered on Sugal99, please contact our support team immediately.

Parents and guardians are encouraged to use parental control tools and to monitor their children's online activity to prevent access to age-restricted platforms such as Sugal99.

13 Changes to This Privacy Policy

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, we will notify registered users by email or through a prominent notice on the platform prior to the changes taking effect, where reasonably practicable.

The most current version of this Policy will always be available on this page, identified by the "Last Updated" date at the top. We encourage you to review this Policy periodically. Your continued use of Sugal99 following the posting of any changes constitutes your acceptance of the updated Policy.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way Sugal99 handles your personal data, please contact our Data Protection team. We are committed to addressing all privacy-related enquiries promptly and transparently.

You can reach us by email at: privacy@sugal99.net

For general support enquiries, including account management and responsible gaming requests, please contact: support@sugal99.net

Our support team is available 24 hours a day, 7 days a week. We aim to respond to all privacy-related requests within 30 days of receipt. For complex requests, we will acknowledge receipt within 72 hours and provide a full response as soon as practicable.