sugal is committed to protecting the personal data of every member. This Privacy Policy explains in plain terms what data we collect, why we collect it, how it is stored and used, who it may be shared with, and what rights you have under Philippine law.
sugal processes all personal data in accordance with Republic Act No. 10173, the Data Privacy Act of 2012, and its implementing rules and regulations as enforced by the National Privacy Commission of the Philippines.
sugal does not sell, lease, or trade your personal data to third-party advertisers, data brokers, or any commercial entity for marketing purposes. Your data stays within the sugal platform ecosystem and its regulated service providers.
Under the Data Privacy Act, you have the right to access, correct, object to, erase, and port your personal data held by sugal. These rights can be exercised at any time by contacting sugal's Data Protection Officer through the channels listed in this policy.
All data transmitted between your device and the sugal platform is encrypted using 256-bit SSL/TLS technology. Data stored on sugal's servers is protected by industry-standard encryption and access controls.
sugal shares data with external parties only where required by PAGCOR license obligations, anti-money laundering law, court order, or lawful instruction from Philippine law enforcement. All such disclosures are documented and limited to what is strictly necessary.
sugal retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by Philippine law. Retention periods vary by data category and are explained in Section 7 of this Privacy Policy.
This Privacy Policy applies to all personal data collected and processed by sugal in connection with your use of the sugal platform, including the website at sugal.co, all associated services, account features, games, and payment functions. By registering for a sugal account or using the sugal platform, you acknowledge that you have read and understood this Privacy Policy. This document forms part of sugal's Terms & Conditions and should be read in conjunction with that document.
sugal values the privacy of every person who interacts with our platform. This Privacy Policy sets out how sugal collects, uses, discloses, stores, and protects personal data in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (hereinafter "DPA"), and its implementing rules and regulations as administered by the National Privacy Commission of the Philippines (hereinafter "NPC").
This policy applies to all personal data collected from or about sugal members and prospective members, including data gathered through the sugal website, mobile access, account registration forms, payment processing, customer support interactions, and any other touchpoint through which personal data is provided to sugal.
sugal operates under a Philippine Amusement and Gaming Corporation (PAGCOR) license and is accordingly subject to additional data collection, retention, and reporting obligations arising from that license. This policy covers both general data protection obligations under the DPA and the additional obligations arising from PAGCOR regulation. Where PAGCOR obligations require data processing that might otherwise exceed standard DPA processing, those obligations are disclosed in the relevant sections below.
For the purposes of the Data Privacy Act of 2012, sugal is the personal information controller (PIC) in respect of personal data collected and processed through the sugal platform. sugal determines the purposes and means of processing personal data collected from or about its members.
sugal has designated a Data Protection Officer (DPO) as required by the Data Privacy Act. The DPO is responsible for monitoring sugal's compliance with applicable data protection laws, advising on data protection obligations, serving as the primary point of contact with the NPC, and handling requests and complaints from data subjects. The DPO may be contacted at the email address listed above, with "Data Privacy" noted in the subject line.
sugal collects personal data in several categories depending on the nature of your interaction with the platform. The following is a comprehensive account of the categories of personal data sugal collects:
When you create a sugal account, we collect the following data that you provide directly:
As required by PAGCOR and anti-money laundering regulations, sugal collects Know Your Customer (KYC) documentation, which may include:
sugal records all financial transactions associated with your account, including:
sugal does not store full payment account credentials (such as full bank account numbers or GCash PINs). Payment authentication is handled by the respective payment provider.
sugal uses the personal data collected for the following purposes, each supported by a lawful basis described in Section 5:
Under the Data Privacy Act of 2012, sugal processes personal data on the following legal bases:
sugal does not sell, rent, lease, or trade personal data to third parties for commercial or marketing purposes. Personal data is shared only in the following circumstances and only to the extent strictly necessary for the stated purpose:
sugal engages third-party service providers who process personal data on sugal's behalf under contractual data processing agreements that require compliance with the DPA. These providers include:
sugal is required to disclose certain personal data and transaction records to PAGCOR as a condition of its operating license, including reports of suspicious transactions, records of player activity relevant to anti-money laundering compliance, and any information lawfully requested by PAGCOR in the exercise of its regulatory functions.
sugal will disclose personal data to Philippine law enforcement authorities, courts, or government agencies where required by a lawful court order, subpoena, warrant, regulatory direction, or other compulsory legal process. sugal will make reasonable efforts to notify the affected member of any such disclosure, except where doing so is prohibited by the court order or applicable law, or where notification would compromise an ongoing investigation.
In the event of a merger, acquisition, sale of platform assets, or similar business transaction involving sugal, member personal data may be transferred to the acquiring entity as part of that transaction. In such an event, sugal will notify registered members of the transfer and the acquiring entity's privacy arrangements via email or in-platform notification prior to the transfer taking effect, where practicable.
sugal retains personal data for the periods specified below. Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized.
Where a legal dispute, regulatory investigation, or legal proceeding is ongoing at the time a retention period would otherwise expire, sugal will retain the relevant data until the matter is fully resolved.
sugal uses cookies and similar tracking technologies on the sugal platform for the following purposes:
Certain cookies are strictly necessary for the operation of the sugal platform and cannot be disabled. These include session authentication cookies that keep you logged in during an active session, security cookies that detect suspicious session activity, and load-balancing cookies that ensure platform performance. No consent is required for strictly necessary cookies.
Functional cookies allow the sugal platform to remember your preferences — such as your preferred language setting, last-visited game category, and responsible gaming tool configurations. These cookies improve your platform experience but are not essential to core functionality. You may opt out of functional cookies through your browser settings, though this may affect certain platform features.
sugal uses first-party analytics to understand aggregate platform usage patterns, such as which game categories are most visited, average session duration, and common navigation paths. Analytics data is aggregated and de-identified — it does not identify individual members. sugal does not use third-party advertising networks or behavioral tracking cookies that profile members across external websites.
You can manage cookie preferences through your browser's cookie settings. Most modern browsers on Android, iOS, and desktop allow you to view, block, and delete cookies from specific websites. Note that blocking all cookies from sugal.co, including essential cookies, will prevent you from logging in and using the platform. For guidance on managing cookies in your specific browser, refer to your browser's help documentation.
As a data subject under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by sugal. These rights may be exercised by contacting sugal's Data Protection Officer at the contact details provided in Section 14.
sugal implements the following technical and organizational measures to protect personal data against unauthorized access, accidental loss, destruction, or disclosure:
While sugal implements robust security measures, no platform can guarantee absolute security. Members can reduce risk by using strong, unique passwords for their sugal accounts, enabling two-factor authentication, not sharing login credentials, and logging out of sugal on shared or public devices. If you suspect your account has been compromised, contact sugal support immediately via live chat.
The sugal platform is strictly restricted to individuals aged 21 years and above, in accordance with PAGCOR's age requirement for licensed online gambling operators. sugal does not knowingly collect personal data from individuals under the age of 21.
Age verification is conducted for all new registrations using government-issued Philippine identification documents. If sugal discovers that personal data has been collected from an individual who is under 21 years of age — whether through a fraudulent registration or any other means — sugal will immediately suspend the relevant account, delete the personal data collected in connection with that registration (subject to any retention obligations arising from PAGCOR or AMLA reporting duties), and report the incident to PAGCOR.
If you are a parent or guardian and believe that a minor in your care has created a sugal account, please contact sugal support immediately via live chat or by email at [email protected] so that the account can be investigated and, if confirmed, closed promptly.
sugal's primary data storage and processing infrastructure is located within or governed by service agreements that require compliance with Philippine data protection standards. Some of sugal's third-party service providers — particularly live dealer game studio providers and certain cloud infrastructure components — may process data in servers located outside the Philippines.
Where personal data is transferred outside the Philippines, sugal ensures that such transfers are subject to appropriate safeguards as required by the DPA, including contractual clauses that require the receiving party to process the transferred data to a standard equivalent to that required under Philippine law. sugal will not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing additional safeguards.
Members who wish to know more about the specific international transfers applicable to their personal data may submit a request to sugal's Data Protection Officer.
sugal reserves the right to update this Privacy Policy at any time in response to changes in applicable law, PAGCOR regulatory requirements, changes in our data processing practices, or improvements to our platform. The updated effective date will be shown at the top of this page on publication of any revision.
Where amendments are material — meaning they significantly affect the rights or interests of members — sugal will notify registered members via their registered email address or through an in-platform notification at least 7 days before the revised policy takes effect, where practicable. Your continued use of the sugal platform after the revised policy's effective date constitutes acceptance of the updated Privacy Policy.
We encourage members to periodically review this Privacy Policy to stay informed about how sugal protects and handles personal data. The version number and last-updated date at the top of this document allow you to confirm whether you are reading the current version.
For any questions, concerns, or requests regarding this Privacy Policy or the personal data sugal holds about you, please contact sugal's Data Protection Officer through the following channels:
Your data is protected under the Philippine Data Privacy Act and handled in compliance with PAGCOR license requirements. Create your verified sugal account today and experience a platform built on security, fairness, and trust. 21+ only.