Privacy Policy for sagilli

1 Introduction

1.1 sagilli ("we," "us," "our") respects your privacy and is committed to protecting the personal data you share with us. This Privacy Policy describes what personal data we collect from you, why we collect it, how we use it, who we may share it with, and the rights you hold over your data as a user of the sagilli platform in the Philippines.

1.2 sagilli operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the directives of the National Privacy Commission (NPC). Where our operations intersect with PAGCOR regulatory requirements, we additionally comply with all applicable gaming-sector data obligations.

1.3 This Policy should be read alongside sagilli's Terms & Conditions, which govern the overall use of our platform. In the event of any conflict between this Policy and the Terms & Conditions with respect to personal data matters, this Privacy Policy prevails.

1.4 By using sagilli, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, you must discontinue use of the sagilli platform and may request account closure at any time.

2 Personal Data We Collect

2.1 sagilli collects personal data from you in the categories set out below. The specific data collected depends on how you interact with the platform.

2.1 Registration and Identity Data

• Philippine mobile number (primary account identifier);
• Date of birth (for age verification — 21+ requirement);
• Full legal name (collected during KYC verification);
• Government-issued identification document type and number;
• Photograph or scan of identity document (where KYC is triggered);
• Proof of address (where KYC is triggered).

2.2 Financial and Transaction Data

• Deposit and withdrawal transaction records;
• GCash account reference or other e-wallet identifiers associated with transactions;
• Bank account details where provided for withdrawal processing (BPI, BDO, Metrobank, etc.);
• Transaction amounts, timestamps, and payment method used;
• Wallet balance history and bonus credit records.

2.3 Gaming and Activity Data

• Game session records — game type, duration, stakes, and outcomes;
• Bingo card purchases and draw participation records;
• Slot game history, payline results, and bonus feature activations;
• Live casino table participation records;
• Responsible gaming tool usage (deposit limits, session limits, self-exclusion).

2.4 Technical and Device Data

• IP address and approximate geographic location at time of login;
• Device type, operating system, and browser or app version;
• Device identifiers (where applicable);
• Login timestamps and session duration;
• Cookies and similar tracking technology data (see Section 7).

2.5 Communications Data

• Live chat conversation transcripts with sagilli support staff;
• Email correspondence with sagilli's support or compliance teams;
• Feedback, complaints, or dispute records submitted to sagilli.

3 How We Collect Your Data

sagilli collects your personal data through the following means:

4 How We Use Your Personal Data

4.1 sagilli uses your personal data only for specified, explicit, and legitimate purposes. The primary purposes for which we process your data are:

• Account creation and management: To register, verify, and maintain your sagilli account, including age verification (21+ requirement) and identity authentication;
• Platform operation: To deliver and operate gaming services, process bets and wagers, calculate and credit winnings, and maintain accurate gaming records;
• Financial processing: To process deposits, withdrawals, and bonus credits through your chosen payment method (GCash, Maya, bank transfer, etc.);
• Security and fraud prevention: To detect, investigate, and prevent unauthorized account access, fraudulent transactions, money laundering, and other prohibited conduct;
• Regulatory compliance: To fulfill our obligations under PAGCOR licensing guidelines, RA 10173, the Anti-Money Laundering Act (AMLA), and other applicable Philippine law;
• Responsible gaming: To monitor gaming patterns for signs of problem gambling, enforce responsible gaming tools, and comply with self-exclusion and cooling-off requests;
• Customer support: To respond to your queries, process complaints, and resolve disputes;
• Platform improvement: To analyze aggregated usage data and improve the sagilli platform, game library, and user experience;
• Communications: To send account notifications, transaction confirmations, security alerts, and — where you have consented — promotional communications relevant to sagilli.

4.2 sagilli does not use automated decision-making processes that produce legal or similarly significant effects without human review, except where required for real-time fraud prevention purposes.

5 Legal Basis for Processing

5.1 Under the Philippine Data Privacy Act of 2012 and its Implementing Rules, sagilli processes your personal data on the following lawful bases:

6 Sharing and Disclosure of Personal Data

6.1 sagilli does not sell, rent, or trade your personal data to third parties for their commercial use. We share your data only in the circumstances described below:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, InstaPay, PesoNet, GrabPay, and 7-Eleven CLiQQ receive only the transaction data necessary to process your deposit or withdrawal. These providers have their own privacy policies governing their data practices.
• Identity verification providers: Regulated third-party KYC service providers receive identity documents and biometric data solely for the purpose of verifying your identity as required by PAGCOR and AMLA.
• Game software providers: Third-party game developers and live dealer studios receive anonymized session and gameplay data as required to operate their games on the sagilli platform. Personal identification data is not shared with game providers.
• Cloud and infrastructure providers: sagilli uses reputable cloud infrastructure services to host platform data. These providers act as data processors under written agreements and are contractually prohibited from using your data for any purpose other than providing infrastructure services to sagilli.
• Regulatory and law enforcement authorities: sagilli discloses personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities when required to do so by applicable law, court order, or regulatory directive.
• Professional advisers: Legal counsel, auditors, and compliance consultants engaged by sagilli may access personal data on a confidential, need-to-know basis.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of sagilli's assets, your personal data may be transferred to the acquiring entity, subject to the acquiring entity adopting privacy protections no less stringent than those in this Policy.

7 Cookies and Tracking Technologies

7.1 sagilli uses cookies and similar tracking technologies to provide a functional, secure, and personalized platform experience.

Types of Cookies Used

7.2 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair your ability to log in to or use the sagilli platform. sagilli does not use third-party advertising cookies for targeted advertising on external platforms.

8 Data Security Measures

8.1 sagilli implements organizational and technical security measures appropriate to the nature and sensitivity of the personal data we process. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and sagilli servers;
• Encryption at rest for sensitive personal data fields including identity document data and payment credentials;
• Hashed, salted password storage — sagilli never stores passwords in readable form;
• OTP-based multi-factor authentication for new device logins;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing of sagilli platform infrastructure;
• Incident response procedures for detecting, containing, and notifying affected parties in the event of a personal data breach, in accordance with NPC notification requirements.

8.2 While sagilli takes all reasonable steps to protect your data, no internet-based system is completely immune to security risks. You are also responsible for maintaining the security of your account credentials and for notifying sagilli immediately if you suspect unauthorized access.

9 Data Retention

9.1 sagilli retains your personal data for no longer than is necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by applicable Philippine law.

9.2 Upon expiry of the applicable retention period, sagilli will securely delete or irreversibly anonymize your personal data. Where anonymous analytical data derived from your gaming activity is retained, it cannot be used to re-identify you.

10 Your Data Subject Rights

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

10.2 To exercise any of the above rights, please contact sagilli's Data Protection Officer using the contact details in Section 14. Requests will be acknowledged within three (3) business days and resolved within fifteen (15) business days, subject to complexity. Identity verification may be required before a request is processed.

11 Children's Privacy

11.1 If sagilli becomes aware that it has collected personal data from a person under 21, it will immediately suspend the account, delete the relevant personal data, and — where applicable — return any deposited funds in accordance with its terms of service.

11.2 If you believe that a minor has accessed or registered on sagilli, please contact our support team immediately via live chat or at the email address in Section 14.

12 Third-Party Links and Services

12.1 The sagilli platform may include references to or integrations with third-party services — including payment gateways such as GCash and Maya, and identity verification providers. These third parties operate under their own privacy policies, which sagilli does not control.

12.2 sagilli is not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party service you interact with in connection with your sagilli account.

12.3 sagilli does not embed third-party social media widgets, advertising networks, or tracking pixels that would allow third parties to collect your personal data without your knowledge while you use the sagilli platform.

13 Changes to This Privacy Policy

13.1 sagilli may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable law. The effective date at the top of this document will be updated whenever a material revision is made.

13.2 For material changes to this Policy, sagilli will notify registered users via SMS to the registered mobile number or via an in-platform notification at next login. Non-material clarifications or corrections will be made without separate notice.

13.3 Continued use of the sagilli platform after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must discontinue use of the platform and may request account closure.

14 Contact and Data Protection Officer

14.1 sagilli has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. The DPO may be contacted for any privacy-related enquiry, data subject rights request, or concern.

If you are not satisfied with sagilli's response to your privacy concern, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC). Information about how to contact the NPC is publicly available through official Philippine government channels.