suhagame Privacy Policy

1. Introduction

suhagame Casino ("suhagame," "we," "us," or "our") is committed to protecting the personal data of every player who uses the suhagame platform. This Privacy Policy applies to all personal data collected through the suhagame website, mobile platform, customer support channels, and any other service operated under the suhagame brand.

This policy is written in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. By registering an account or using any part of the suhagame 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.

This Privacy Policy should be read alongside our Terms & Conditions, which govern your use of the suhagame platform. Defined terms used but not defined in this policy carry the meanings given to them in the Terms & Conditions.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, suhagame Casino is the personal information controller responsible for your personal data collected through the suhagame platform.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer (DPO) at the contact details provided in Section 14 of this policy.

3. Data We Collect

suhagame collects the following categories of personal data from players and platform users:

3.1 Identity Data

• Full legal name as it appears on your government-issued identification
• Date of birth
• Gender
• Nationality
• Government-issued ID number (e.g., Philippine passport, driver's license, SSS/UMID card)
• Photograph or selfie submitted for identity verification

3.2 Contact Data

• Residential address (including barangay, city/municipality, province)
• Email address
• Philippine mobile number

3.3 Financial Data

• GCash account number or registered mobile number
• PayMaya / Maya account details
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where applicable
• Transaction history including deposits, withdrawals, and wager records

3.4 Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration and login timestamps
• Cookies and similar tracking technologies (see Section 10)

3.5 Gaming Data

• Game history, wager amounts, and outcomes
• Bonus and promotion usage
• Responsible gaming settings (deposit limits, session timers, self-exclusion status)

3.6 Communications Data

• Records of your communications with suhagame customer support via live chat, email, or other channels
• Feedback, complaints, and survey responses

4. How We Collect Your Data

suhagame collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the suhagame platform, including cookies, server logs, and analytics tools.
• Third-party sources: Data received from identity verification providers, payment processors (such as GCash and PayMaya), fraud prevention services, and regulatory authorities where permitted by law.

5. How We Use Your Data

suhagame uses your personal data for the following purposes:

suhagame 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 required by law.

6. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, KYC requirements, and responsible gaming mandates.
• Legitimate interests: Processing necessary for suhagame's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent, such as for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

suhagame 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 only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment service providers, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and comply with regulatory requirements.
• Regulatory authorities: Philippine government agencies and regulatory bodies, including but not limited to PAGCOR and the Anti-Money Laundering Council (AMLC), where disclosure is required by law.
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and platform technology vendors who process data on our behalf under strict data processing agreements.
• Professional advisers: Lawyers, auditors, and consultants bound by confidentiality obligations, where necessary for legal or compliance purposes.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of suhagame's business, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom suhagame shares personal data are required to process that data in accordance with applicable data protection laws and suhagame's data processing standards.

8. Data Retention

suhagame retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in accordance with Philippine AML regulations.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 and its amendments.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the end of the business relationship.
• Customer support communications: Retained for three (3) years from the date of the interaction, or longer if the communication relates to an unresolved dispute.
• Marketing consent records: Retained for the duration of your consent plus three (3) years to demonstrate compliance.
• Technical and log data: Retained for up to twelve (12) months, unless required for longer periods for security or fraud investigation purposes.

When personal data is no longer required, suhagame will securely delete or anonymise it in accordance with our internal data disposal procedures.

9. Data Security

suhagame implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the suhagame platform
• Encryption of sensitive data at rest, including financial records and identity documents
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular penetration testing and vulnerability assessments conducted by independent security specialists
• Multi-factor authentication (MFA) for internal systems and player account access
• Continuous monitoring of platform activity for anomalous behaviour and potential security incidents
• Staff training on data protection obligations and secure data handling practices

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, suhagame will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

10. Cookies & Tracking Technologies

suhagame uses cookies and similar tracking technologies to enhance your experience on the platform, analyse usage patterns, and support security functions. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the suhagame platform, including session management and security functions. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login state to provide a more personalised experience.
• Analytics cookies: Collect anonymised data about how players use the suhagame platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Marketing cookies: Used to deliver relevant promotional content to you based on your gaming activity and preferences, subject to your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the suhagame platform. For strictly necessary cookies, no opt-out is available as they are required for the platform to function.

11. Your Data Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by suhagame:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data suhagame holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held by suhagame.
• Right to erasure: You have 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 suhagame's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact suhagame's Data Protection Officer using the contact details in Section 14. suhagame will respond to all verified data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with prior notification to you.

12. Minors

The suhagame platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. suhagame does not knowingly collect personal data from individuals under the age of 21. If suhagame becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted immediately and the associated account will be closed.

If you are a parent or guardian and believe that your child has provided personal data to suhagame, please contact our support team immediately so that appropriate action can be taken.

13. Changes to This Privacy Policy

suhagame reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, suhagame will notify registered players via the email address or mobile number on file, or by displaying a prominent notice on the platform.

The date of the most recent revision is displayed at the top of this page. Your continued use of the suhagame platform following the posting of a revised Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this policy periodically to stay informed about how suhagame protects your data.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by suhagame, please contact our Data Protection Officer:

• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the suhagame platform
• Response Time: Data rights requests are processed within 30 days of receipt