PH Sugar Privacy Policy – How We Handle Your Data

PH Sugar operates the online gaming platform found at phsugar.run. This Privacy Policy describes how PH Sugar collects, uses, stores, and shares personal data in connection with the registration and operation of player accounts, the processing of Philippine Peso deposits and withdrawals, the delivery of games and sports markets, and all other services offered through the platform.

This policy applies to every person who registers a PH Sugar account, visits the website, contacts the support team, or interacts with any PH Sugar service. By creating an account or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy and agree to the data practices described within it.

PH Sugar is committed to handling personal data responsibly in accordance with the principles set out under applicable data protection legislation in the Philippines, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

PH Sugar collects personal data through direct interactions, account activity, payment processing, and standard technical operations. The categories of data collected include the following.

PH Sugar does not intentionally collect sensitive personal information beyond what is required for identity verification and anti-money laundering obligations. Full payment credentials such as complete card numbers, online banking passwords, wallet passwords, or one-time PINs are never requested or stored by PH Sugar.

Data may also be received from third-party payment processors, identity verification services, and fraud prevention tools when you initiate a transaction or verification process through the PH Sugar platform.

PH Sugar uses the personal data collected for the following purposes. Each use is connected to a specific operational or legal requirement rather than general data accumulation.

• Account creation and management: Setting up and maintaining your PH Sugar profile, verifying your identity and age, and managing access to games and payment features.
• Payment processing: Accepting PHP deposits, reviewing withdrawal requests, verifying payment account ownership, and maintaining transaction records.
• Security and fraud prevention: Detecting suspicious login activity, preventing unauthorised access, investigating unusual transaction patterns, and protecting the platform from abuse.
• Legal and regulatory compliance: Fulfilling obligations under the Data Privacy Act of 2012, anti-money laundering requirements, age verification duties, and any directions from relevant regulatory authorities.
• Customer support: Responding to account enquiries, resolving disputes, and processing responsible gaming requests such as self-exclusion.
• Platform improvement: Analysing anonymised usage patterns to improve navigation, payment flows, and overall user experience on PH Sugar.
• Promotional communications: Sending relevant account notifications or optional promotional messages where you have not opted out. You may withdraw consent for marketing communications at any time by contacting PH Sugar.

PH Sugar does not use personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or fraud prevention obligations.

PH Sugar processes personal data on one or more of the following legal bases, depending on the purpose of each processing activity.

• Contractual necessity: Processing required to fulfil your PH Sugar account agreement, including registration, payment processing, and game access.
• Legal obligation: Processing required to comply with applicable Philippine law, including identity verification, anti-money laundering checks, and age confirmation.
• Legitimate interest: Processing carried out in PH Sugar's reasonable interest, such as fraud detection, platform security, and service improvement, where those interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed agreement, such as receiving optional promotional communications. Consent may be withdrawn at any time.

PH Sugar does not sell, rent, or trade your personal information. Data is shared only in the following limited circumstances and only to the extent necessary for each purpose.

• Payment service providers: E-wallet operators such as GCash, Maya, GrabPay, and Coins.ph, banks such as BDO, BPI, and UnionBank, and card networks through which PHP transactions are processed. These providers receive only the data needed to complete or verify a transaction.
• Identity verification services: Third-party tools used to confirm the identity and age of PH Sugar account holders during registration or account review. Data shared is limited to what is needed for the verification process.
• Fraud prevention and security tools: Services used to detect suspicious activity, prevent unauthorised access, and protect PH Sugar players and the platform. These providers process data under strict confidentiality obligations.
• Legal and regulatory authorities: When required by Philippine law, court order, or a direction from a relevant government body, PH Sugar may disclose personal data without prior notice to the account holder.
• Business transfers: In the event of a merger, acquisition, or transfer of PH Sugar's operations, personal data may form part of the transferred assets, subject to the continuing protection of this Privacy Policy.

All third parties with whom PH Sugar shares data are required to handle that data securely and to use it only for the specific purpose for which it was shared. PH Sugar does not authorise third-party use of your data for their own unrelated marketing or commercial activities.

PH Sugar retains personal data for as long as is necessary to fulfil the purpose for which it was collected, unless a longer retention period is required by applicable law or legitimate operational need.

• Active account data: Retained for the duration of your PH Sugar account and for a reasonable period after closure to allow for dispute resolution, regulatory review, or account reinstatement requests.
• Transaction records: Payment history, deposits, and withdrawals may be retained for a period consistent with Philippine anti-money laundering regulations, which may extend several years after the transaction date.
• Identity verification documents: Retained for the period required by applicable verification and compliance obligations, even after account closure.
• Support and communication records: Kept for a reasonable period after resolution of the matter to which they relate, in case the issue is raised again or escalated.

When data is no longer needed and no legal obligation requires its continued retention, PH Sugar will take reasonable steps to securely delete or anonymise that data.

PH Sugar implements technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. Measures in place include access controls limiting data visibility to authorised personnel, encryption or secure transmission protocols for sensitive data in transit, regular internal security reviews, and monitoring for unusual account activity.

While PH Sugar works to maintain strong data security, no digital platform can guarantee absolute protection against all threats. Players have an important role in their own account security. Practical steps you should take include the following.

• Use a strong, unique password for your PH Sugar account and do not reuse it elsewhere.
• Never share your password, one-time PIN, or security answers with anyone.
• Log out after every PH Sugar session, especially on shared or public devices.
• Contact PH Sugar immediately if you suspect your account has been accessed without your permission.

PH Sugar uses cookies and similar technical tools to support the operation of the platform. Cookies are small text files stored on your device when you visit the website. They help PH Sugar keep you signed in during a session, remember platform preferences, and understand broadly how pages are used.

The main types of cookies used by PH Sugar include the following.

• Strictly necessary cookies: Required for the website to function. These enable secure login, session management, and basic navigation. They cannot be disabled without affecting platform access.
• Functional cookies: Remember your preferences within the PH Sugar platform, such as displayed settings and navigation state, to make repeated visits more convenient.
• Analytics cookies: Collect anonymised information about how pages are accessed and used. This data helps PH Sugar identify areas for improvement. Individual users are not identified through analytics data.

Most browsers allow you to review and control cookies through their settings. Disabling cookies that are not strictly necessary should not affect access to the core PH Sugar account features, but some convenience functions may be reduced.

PH Sugar is strictly intended for adults aged 21 years and above. The platform does not knowingly collect personal data from individuals below this age. If PH Sugar becomes aware that personal data has been collected from a minor, that data will be deleted and the associated account will be closed.

Parents, guardians, and other responsible adults should monitor device access to prevent minors from visiting or registering on gaming platforms. If you believe a minor has created a PH Sugar account using false age information, please contact PH Sugar using the details in Section 13 of this policy so that the matter can be reviewed promptly.

As a data subject under the Philippines Data Privacy Act of 2012, you have specific rights regarding your personal information held by PH Sugar. These rights apply subject to applicable legal obligations and legitimate operational requirements.

To exercise any of the rights above, contact PH Sugar using the details provided in Section 13. Requests will be reviewed and responded to within the timeframe required by applicable law. Identity verification may be required before certain requests are processed.

PH Sugar primarily serves players in the Philippines and stores data in accordance with local obligations. However, some third-party service providers engaged by PH Sugar may operate servers or processing infrastructure outside the Philippines, including payment gateway partners, verification tools, and platform technology providers.

When personal data is transferred outside the Philippines, PH Sugar takes reasonable steps to ensure that an adequate level of data protection is maintained, including contractual obligations on the receiving party consistent with the standards required under the Data Privacy Act of 2012.

Players who have questions about specific cross-border data flows related to their personal data may contact PH Sugar using the details in Section 13.

PH Sugar may update this Privacy Policy from time to time to reflect changes in services, applicable law, payment methods, or data handling practices. When updates are made, the effective date at the top of this page will be revised accordingly.

For material changes that significantly affect how personal data is used, PH Sugar may send a notification to the email address or mobile number registered on your account. However, it remains each player's responsibility to review this policy periodically. Continued use of PH Sugar after a revised policy has been published constitutes acceptance of the updated terms.

If you have a question about this Privacy Policy, would like to exercise a data right, want to report a suspected privacy concern, or need to raise a data-related complaint, please contact the PH Sugar team.

Email: support@phsugar.run

When writing about a privacy matter, please include your registered account name, a brief description of your concern, and the type of request you are making. This helps PH Sugar direct your message to the right team and respond within the applicable timeframe.

For responsible gaming requests, including self-exclusion or deposit limits, please visit the Responsible Gaming page or indicate "Responsible Gaming" in the subject line of your email.