Privacy Policy — sayaph Casino

01 Introduction

sayaph ("we," "us," "our," or "the Company") is committed to protecting the privacy and personal data of all individuals who use the sayaph platform ("Players," "Users," or "you"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data in connection with your use of the sayaph website at sayaph.app and all related services.

sayaph operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as overseen by the National Privacy Commission (NPC) of the Philippines. We take our obligations as a personal information controller seriously and have implemented appropriate technical and organizational measures to safeguard your data.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and sayaph.

02 Personal Data We Collect

sayaph collects only the personal data that is necessary to provide our services, comply with legal obligations, and maintain the security and integrity of the platform. The categories of personal data we collect include:

03 How We Collect Your Data

sayaph 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 and usage data collected automatically when you access and interact with the sayaph platform, including through cookies, log files, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; payment data from payment processors such as GCash, Maya, and banking partners; fraud prevention data from security service providers.
• Publicly available sources: In limited circumstances, sayaph may verify information against publicly available records to comply with anti-money laundering obligations.

04 How We Use Your Personal Data

sayaph uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your sayaph account, including verifying your identity and age (21+ requirement).
• Service delivery: To process deposits and withdrawals, provide access to games, and deliver the core features of the sayaph platform.
• Legal compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) regulations, KYC requirements, and PAGCOR regulatory requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: To monitor gaming behavior, identify potential problem gambling patterns, and administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing communications: To send you promotional offers, bonuses, and platform updates — but only where you have provided your consent to receive such communications. You may opt out at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features and performance of the sayaph platform.

05 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, sayaph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your account and deliver the sayaph services you have signed up for.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, tax obligations, and PAGCOR licensing requirements.
• Legitimate interests: Processing necessary for sayaph's 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. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Data Sharing & Disclosure

sayaph does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other banking partners, for the purpose of processing your financial transactions.
• KYC and identity verification providers: Third-party services that assist sayaph in verifying your identity and age in compliance with regulatory requirements.
• Game providers: Certified third-party game developers whose games are hosted on the sayaph platform. These providers may receive limited technical data necessary to deliver their games.
• Fraud prevention and security services: Providers that assist sayaph in detecting and preventing fraudulent activity and unauthorized access.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Professional advisors: Legal counsel, auditors, and other professional advisors, subject to strict confidentiality obligations.

07 Cookies & Tracking Technologies

sayaph uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and gather analytics data. The types of cookies we use include:

• Essential cookies: Strictly necessary for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Analytics cookies: Used to collect aggregated, anonymized data about how Players use the sayaph platform, helping us identify areas for improvement. These do not identify you personally.
• Preference cookies: Used to remember your settings and preferences, such as language and display options, to provide a more personalized experience.
• Marketing cookies: Used to deliver relevant promotional content. These are only activated where you have provided consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the sayaph platform. For more information on managing cookies, refer to your browser's help documentation.

08 Data Retention

sayaph 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 after account closure, in compliance with Philippine AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC documents: Retained for a minimum of five (5) years after the end of the business relationship.
• Customer support records: Retained for three (3) years from the date of the last interaction, or longer if required for dispute resolution.
• Marketing data: Retained until you withdraw your consent or for a maximum of two (2) years from your last interaction with marketing communications, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with sayaph's data disposal procedures.

09 Data Security

sayaph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your device and the sayaph platform is encrypted using industry-standard SSL/TLS protocols.
• Secure data storage: Personal and financial data is stored on secure, access-controlled servers with regular security audits.
• Access controls: Access to personal data is restricted to authorized sayaph personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-factor authentication: sayaph supports and encourages the use of two-factor authentication (2FA) to protect your account from unauthorized access.
• Regular security assessments: sayaph conducts regular vulnerability assessments and penetration testing to identify and address potential security weaknesses.

10 Your Data Rights

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

To exercise any of these rights, please contact sayaph's Data Protection Officer using the contact details in Section 14. sayaph will respond to all data rights requests within thirty (30) calendar days of receipt, in accordance with NPC guidelines.

11 Children's Privacy

If sayaph becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the sayaph platform, please contact our support team immediately at [email protected].

12 Third-Party Links

The sayaph platform may contain links to third-party websites or services, such as payment provider portals. sayaph is not responsible for the privacy practices of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to data collected by sayaph through the sayaph.app platform.

13 Updates to This Privacy Policy

sayaph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. When material changes are made, we will notify registered Players via email or a prominent notice on the sayaph platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the sayaph platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically.

14 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact sayaph's designated Data Protection Officer (DPO):

If you are not satisfied with sayaph's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the regulatory authority responsible for enforcing the Data Privacy Act of 2012.