Six core commitments that define how we handle your personal information
All personal data stored by sugal is protected using industry-standard AES-256 encryption at rest. Your account credentials, payment details, and identity documents are never stored in plain text. Access is restricted to authorized personnel only.
sugal processes personal data in accordance with Republic Act No. 10173, the Data Privacy Act of 2012, and the regulations issued by the National Privacy Commission (NPC) of the Philippines. Your rights as a data subject are fully recognized and upheld.
sugal does not sell, rent, or trade your personal information to third-party marketers or data brokers. Your data is used solely for the purposes described in this Privacy Policy and for no other commercial purpose without your explicit consent.
As a sugal player, you have the right to access, correct, delete, and port your personal data at any time. You can also object to certain types of processing. sugal will respond to all data subject requests within thirty (30) days of receipt.
sugal uses cookies and similar tracking technologies only for essential platform functionality, security, and improving your gaming experience. We do not use third-party advertising cookies. You can manage your cookie preferences at any time through your browser settings.
sugal will notify you promptly in the event of any data breach that may affect your personal information, in accordance with NPC notification requirements. We maintain a dedicated Data Protection Officer to oversee all privacy matters on the platform.
Important: This Privacy Policy applies to all personal data collected by sugal in connection with your use of the sugal platform at sugal.app, including all associated services, games, promotions, and customer support interactions. By registering a sugal account or using the platform, you acknowledge that you have read and understood this Privacy Policy.
sugal ("we," "us," "our," or "the Company") is committed to protecting the privacy and personal data of every player who uses the sugal platform. We understand that trust is the foundation of any good relationship, and that trust starts with being completely transparent about how we handle your information.
This Privacy Policy describes the types of personal data we collect, the purposes for which we process it, the parties with whom we may share it, and the measures we take to keep it secure. It also explains the rights you have as a data subject under Philippine law and how you can exercise those rights.
This Policy should be read alongside our Terms and Conditions, which govern your use of the sugal platform. In the event of any conflict between this Privacy Policy and the Terms and Conditions on matters of data privacy, this Privacy Policy shall prevail.
sugal is the data controller responsible for the personal data collected through the sugal platform. As data controller, sugal determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.
sugal 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.
Regulatory Framework: sugal operates within the regulatory framework established by PAGCOR and complies with the data protection requirements applicable to licensed gaming operators in the Philippines. Our data processing practices are subject to periodic review by the National Privacy Commission.
sugal collects the following categories of personal data from players and platform users:
| Category | Examples | Purpose |
|---|---|---|
| Identity Data | Full name, date of birth, government-issued ID number, nationality | Account registration, KYC verification, age verification (21+) |
| Contact Data | Email address, Philippine mobile number, residential address | Account communication, support, regulatory notifications |
| Financial Data | GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), transaction history | Processing deposits and withdrawals, AML compliance |
| Gaming Data | Game history, wager amounts, win/loss records, session duration, bonus usage | Platform operation, responsible gaming monitoring, dispute resolution |
| Technical Data | IP address, device type, browser type, operating system, login timestamps | Security, fraud prevention, platform optimization |
| Communications Data | Live chat transcripts, support emails, feedback submissions | Customer support, quality assurance, dispute resolution |
| Preference Data | Responsible gaming settings, notification preferences, language settings | Personalizing your sugal experience |
sugal does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive data is collected (such as government ID documents), it is handled with heightened security measures and access controls.
The majority of personal data sugal holds about you is provided directly by you during the registration process, KYC verification, payment transactions, customer support interactions, and when you update your account profile or responsible gaming settings.
When you access and use the sugal platform, certain technical data is collected automatically through cookies, log files, and similar tracking technologies. This includes your IP address, device identifiers, browser information, and session activity data. This data is used primarily for security monitoring, fraud detection, and improving platform performance.
sugal may receive personal data about you from third-party sources in limited circumstances, including:
sugal uses your personal data for the following purposes:
sugal processes your personal data on the following legal bases under the Data Privacy Act of 2012:
sugal does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:
sugal engages trusted third-party service providers to assist in operating the platform, including KYC verification providers, payment processors, cloud hosting providers, and customer support technology vendors. All service providers are contractually bound to process your data only on sugal's instructions and in accordance with applicable data protection law.
sugal may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other government authorities where required by law, court order, or regulatory directive. Such disclosures are made only to the extent required and in accordance with applicable legal procedures.
In the event of a merger, acquisition, or sale of all or part of sugal's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.
No Third-Party Marketing: sugal will never share your personal data with third-party advertisers, data brokers, or marketing companies. Your information is used exclusively for the purposes set out in this Privacy Policy.
sugal retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:
| Data Category | Retention Period | Reason |
|---|---|---|
| Account and identity data | 5 years after account closure | PAGCOR regulatory requirement, AML compliance |
| Financial transaction records | 5 years from transaction date | AMLC reporting obligations, tax compliance |
| Gaming history | 3 years after account closure | Dispute resolution, responsible gaming monitoring |
| Customer support records | 2 years from last interaction | Quality assurance, dispute resolution |
| Technical and log data | 12 months from collection | Security monitoring, fraud detection |
| Marketing consent records | Until consent is withdrawn + 1 year | Demonstrating lawful basis for marketing |
After the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with any individual player.
sugal implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:
Data Breach Notification: In the event of a personal data breach that poses a risk to your rights and freedoms, sugal will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with NPC Circular No. 16-03.
Cookies are small text files placed on your device when you visit the sugal platform. They help the platform remember your preferences, maintain your session, and collect analytical data about how the platform is used.
You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a cookie is set. Please note that disabling essential cookies may affect the functionality of the sugal platform and your ability to access certain features.
No Advertising Cookies: sugal does not use third-party advertising or retargeting cookies. We do not allow external advertising networks to place cookies on the sugal platform or track your activity across other websites.
Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by sugal:
To exercise any of the rights listed above, please contact sugal's Data Protection Officer using the contact details provided in Section 14. We will respond to all data subject requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified of any such extension.
To protect your privacy and prevent unauthorized access to your data, sugal may require you to verify your identity before processing a data subject request. This is to ensure that personal data is only disclosed to or modified by the individual to whom it belongs.
If you are not satisfied with sugal's response to your data subject request, or if you believe that sugal has processed your personal data in violation of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.
The sugal platform is strictly intended for individuals who are twenty-one (21) years of age or older. sugal does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the registration and KYC process, and accounts found to belong to individuals under 21 will be immediately suspended and all associated data will be handled in accordance with applicable law.
If you are a parent or guardian and believe that a minor has registered a sugal account or provided personal data to sugal without your consent, please contact our support team immediately. sugal will take prompt action to investigate and, where confirmed, delete the minor's data and close the account.
21+ Only: sugal takes the protection of minors extremely seriously. We employ technical age-gating measures, document-based age verification, and ongoing account monitoring to prevent underage access to the platform. If you have minors in your household, we recommend using parental control software to restrict access to gaming platforms.
sugal 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 we make material changes to this Policy, we will notify registered players via email and/or a prominent notice on the sugal platform at least fourteen (14) days before the changes take effect.
The date of the most recent revision is displayed at the top of this Privacy Policy. We encourage you to review this Policy periodically to stay informed about how sugal protects your personal data. Your continued use of the sugal platform following notification of changes constitutes your acceptance of the revised Privacy Policy.
The current version of this Privacy Policy is always available at sugal.app/privacy-policy.
For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by sugal, please contact our Data Protection Officer:
For matters relating to responsible gaming, please visit our Responsible Gaming page. For the full terms governing your use of the sugal platform, please review our Terms and Conditions.
Policy Last Updated: This Privacy Policy was last reviewed and updated in January 2026. sugal is committed to maintaining a current and accurate Privacy Policy that reflects our data processing practices and your rights as a Filipino player on the sugal platform.