skyph Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") applies to all personal data processed by skyph in connection with the operation of the online gaming platform accessible at skyph.asia (the "Platform"). It covers data collected from registered players, visitors to the Platform, and any individual who contacts skyph for support or other purposes.

By using the skyph Platform, you acknowledge that you have read and understood this Policy. Where your use of the Platform constitutes consent to the processing of your personal data, that consent is freely given, specific, informed, and unambiguous as required under the Data Privacy Act of 2012 (RA 10173) of the Philippines.

2. Data Controller

skyph is the data controller responsible for the personal data processed under this Policy. skyph has appointed a Data Protection Officer (DPO) whose contact details are set out in Section 14 of this Policy. The DPO is registered with the National Privacy Commission (NPC) of the Philippines in accordance with NPC Circular No. 17-01.

3. Personal Data We Collect

skyph collects the following categories of personal data from users of the Platform:

• Identity Data: Full legal name, date of birth, nationality, and copies of government-issued identification documents (e.g., Philippine National ID, passport, driver's licence, SSS/UMID card, PhilSys ID) for KYC purposes.
• Contact Data: Email address, Philippine mobile number (Smart, Globe, or DITO), and mailing address.
• Financial Data: GCash wallet number, Maya account details, bank account information (BPI, BDO, Metrobank, or other Philippine banks), and transaction history on the Platform.
• Technical Data: IP address, browser type and version, device identifiers, operating system, time zone settings, and session logs.
• Usage Data: Game history, betting patterns, deposit and withdrawal records, bonus usage, session duration, and responsible gaming settings.
• Communications Data: Records of communications between you and skyph support via live chat, email, or other channels.

4. How We Collect Your Data

skyph collects personal data through the following means:

• Direct collection: When you register an account on skyph, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion.
• Automated technologies: When you access the Platform, skyph automatically collects technical and usage data through cookies, web beacons, and server logs.
• Third-party sources: skyph may receive data from payment processors (e.g., GCash, Maya), identity verification service providers, and fraud detection partners to supplement the data you provide directly.

5. Legal Basis for Processing

skyph processes personal data on the following legal bases as recognised under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and skyph — i.e., to operate your account, process deposits and withdrawals, and deliver gaming services.
• Legal obligation: Processing required to comply with applicable Philippine law, including AML obligations under RA 9160, KYC requirements under PAGCOR regulations, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improvement of skyph services, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for optional purposes such as marketing communications, where you have provided explicit, withdrawable consent.

6. How We Use Your Personal Data

skyph uses your personal data for the following purposes:

• To register and maintain your skyph account, including identity verification and ongoing KYC monitoring.
• To process deposits and withdrawals via GCash, Maya, and Philippine banking channels.
• To provide access to games, live casino, sports betting, bingo, and other Platform features.
• To administer bonus and promotional offers in accordance with applicable terms.
• To comply with PAGCOR licensing requirements, Philippine AML law, and reporting obligations.
• To detect and prevent fraud, money laundering, underage gambling, and other prohibited activities.
• To monitor and enforce responsible gaming limits and self-exclusion requests.
• To improve the Platform through analysis of usage patterns and player feedback.
• To respond to your customer support enquiries and resolve disputes.
• To send transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts).
• Where consent has been provided: to send promotional offers, newsletters, and information about new skyph features via email or SMS.

7. Sharing of Personal Data

skyph does not sell, rent, or trade personal data to third parties for their independent marketing purposes. skyph may share your personal data with the following categories of recipients, solely to the extent necessary for the stated purpose:

• Payment processors: GCash, Maya, and Philippine bank partners, for the processing of deposits and withdrawals.
• Identity verification providers: Accredited KYC and anti-fraud service providers for document verification and identity screening.
• Game content providers: Licensed game studios (e.g., Pragmatic Play, Jili Games, PG Soft) who may receive session identifiers necessary to deliver game content.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies where required by Philippine law.
• Professional advisors: Legal counsel, auditors, and compliance consultants engaged by skyph under obligations of professional confidentiality.

All third-party recipients are required by skyph to process personal data in compliance with applicable Philippine data protection law and are prohibited from using the data for any purpose other than that for which it was disclosed.

8. Cookies and Tracking Technologies

skyph uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Essential cookies: Strictly necessary for the operation of the Platform, including session management and security. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, game lobby layout) to improve your experience on skyph.
• Analytics cookies: Collect anonymised data about how players use the Platform to help skyph identify areas for improvement. No personally identifiable information is shared with analytics providers.

You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the skyph Platform.

9. Data Retention

skyph retains personal data for the following periods, or longer where required by law:

• Account data: For the duration of your active skyph account, plus five (5) years following account closure.
• Transaction records: A minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act (RA 9160, as amended).
• KYC documents: A minimum of five (5) years following the termination of the customer relationship.
• Support communications: Three (3) years from the date of the last communication, unless longer retention is required for dispute resolution.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with skyph's data disposal procedures.

10. Security Measures

skyph implements the following technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• Transport Layer Security (TLS 1.3) / 256-bit SSL encryption for all data in transit.
• AES-256 encryption for sensitive data stored at rest, including financial account details.
• Multi-factor authentication (MFA) required for all skyph employee access to production systems.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular penetration testing and vulnerability assessments by independent third-party security firms.
• A documented incident response plan in compliance with NPC Circular No. 16-03 (Personal Data Breach Management).

11. Your Rights as a Data Subject

Under RA 10173 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by skyph:

• Right to be informed: To know how your personal data is being collected and processed.
• Right of access: To obtain a copy of the personal data skyph holds about you.
• Right to rectification: To have inaccurate or incomplete personal data corrected.
• Right to erasure: To request deletion of your personal data where retention is no longer lawful or necessary, subject to overriding legal obligations.
• Right to object: To object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: To receive your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: To submit a complaint to the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact skyph's Data Protection Officer at the details provided in Section 14. skyph will respond to all data subject requests within fifteen (15) business days of receipt, as required by NPC regulations.

12. Children's Privacy

The skyph Platform is strictly for persons aged 21 years and above. skyph does not knowingly collect personal data from individuals under the age of 21. If skyph becomes aware that personal data has been collected from a person under 21 — whether through misrepresentation during registration or any other means — skyph will immediately suspend the relevant account, delete the collected data, and report the matter to the appropriate Philippine regulatory authorities where required.

13. Changes to This Privacy Policy

skyph may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via the email address on file or through a prominent notice on the Platform at least seven (7) days prior to the effective date of the change. Your continued use of the skyph Platform after the effective date constitutes your acceptance of the updated Policy.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or skyph's personal data processing practices, please contact our Data Protection Officer. The DPO can be reached by writing to skyph customer support. Email correspondence may be directed to: [email protected] — please mark your subject line "Data Privacy Request." skyph's DPO contact details are also registered with the National Privacy Commission of the Philippines.