sayagame Privacy Policy

1 Introduction

sayagame ("sayagame," "we," "us," or "our") operates the online gaming platform accessible at sayagame.club. We are committed to protecting the privacy and personal information of all users ("Player," "User," or "you") in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA) of the Philippines, and its Implementing Rules and Regulations.

This Privacy Policy describes how sayagame collects, processes, stores, shares, and protects your personal data when you access or use the sayagame platform. It also describes the rights you have over your personal data and how you can exercise those rights.

By registering for a sayagame account or using any part of the sayagame platform, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy.

2 Personal Data We Collect

sayagame collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Registration and Identity Data

• Full legal name
• Date of birth (for age verification — players must be 21 or older)
• Email address
• Mobile phone number
• Residential address (including city, province, and postal code)
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine Passport, UMID, Driver's License, PhilSys National ID)
• Proof of address documents
• Selfie or liveness verification images where required

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash account reference, PayMaya / Maya account reference, bank account details for transfer purposes)
• Transaction amounts, dates, and statuses

2.4 Gaming Activity Data

• Game history, bet amounts, and outcomes
• Bonus and promotion usage records
• Session duration and login timestamps
• Responsible gaming tool settings (deposit limits, self-exclusion status)

2.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Platform interaction logs and error reports

2.6 Communications Data

• Customer support chat transcripts and email correspondence
• Survey responses and feedback submissions
• Marketing preference settings

3 How We Use Your Personal Data

sayagame uses your personal data only for legitimate, specified purposes. The table below summarizes our primary data processing activities:

sayagame does not use your personal data for automated decision-making that produces significant legal effects without human review, except where required by law or with your explicit consent.

4 Legal Basis for Processing

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

• Contractual Necessity: Processing required to fulfill our obligations under the sayagame Terms & Conditions, including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including AML regulations, PAGCOR requirements, and tax obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and optional analytics features, where you have provided explicit, informed consent. You may withdraw consent at any time.

5 Data Sharing and Disclosure

sayagame does not sell your personal data to third parties. 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:

5.1 Service Providers

Third-party vendors who assist sayagame in operating the platform, including KYC verification providers, payment processors (GCash, PayMaya / Maya, Philippine banks), game software providers, cloud hosting providers, and customer support platforms. All service providers are contractually bound to process your data only as instructed by sayagame and in compliance with applicable privacy laws.

5.2 Regulatory and Law Enforcement Authorities

sayagame may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other competent Philippine authorities where required by law, court order, or regulatory directive.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of sayagame's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

5.4 With Your Consent

sayagame may share your data with other third parties where you have provided explicit consent for such sharing.

6 Cookies and Tracking Technologies

sayagame uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device that help us recognize you, maintain your session, and understand how you use sayagame.

Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function. These cannot be disabled without affecting core functionality such as login sessions and security features.
• Functional Cookies: Remember your preferences such as language settings and responsible gaming tool configurations.
• Analytics Cookies: Help us understand how players use sayagame so we can improve the platform. Data collected is aggregated and anonymized where possible.
• Marketing Cookies: Used to deliver relevant promotional content to you, subject to your marketing consent preferences.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the sayagame platform.

7 Data Retention

sayagame retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. The following general retention periods apply:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Gaming activity logs: Retained for a minimum of two (2) years.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Marketing data: Retained until you withdraw consent or request deletion, subject to legal retention requirements.

Upon expiry of the applicable retention period, sayagame will securely delete or anonymize your personal data.

8 Data Security

sayagame implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the sayagame platform
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and financial information
• Multi-factor authentication options for player accounts
• Regular security audits and penetration testing by independent third parties
• Strict access controls limiting employee access to personal data on a need-to-know basis
• Incident response procedures for detecting, reporting, and managing personal data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, sayagame 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.

9 Your Privacy Rights

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

• Right to be Informed: The right to know what personal data sayagame collects about you and how it is processed.
• Right of Access: The right to request a copy of the personal data sayagame holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to sayagame's legal retention obligations.
• Right to Object: The right 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: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact sayagame's Data Protection Officer at support@sayagame.club. sayagame will respond to all verified data subject requests within thirty (30) days, in accordance with the DPA.

10 Children's Privacy

The sayagame platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. sayagame does not knowingly collect personal data from persons under the age of 21.

If sayagame becomes aware that personal data has been collected from a person under the age of 21, the account will be immediately suspended, all associated data will be deleted, and any deposits will be returned. If you believe that a minor has registered on the sayagame platform, please contact us immediately at support@sayagame.club so we can take immediate action.

11 International Data Transfers

sayagame primarily processes and stores your personal data within the Philippines. Where it is necessary to transfer your personal data to service providers or partners located outside the Philippines (for example, cloud infrastructure or game software providers), sayagame ensures that such transfers are subject to appropriate safeguards, including contractual data protection clauses that provide a level of protection equivalent to that required under the Data Privacy Act of 2012.

sayagame will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your explicit consent or without implementing appropriate protective measures.

12 Changes to This Privacy Policy

sayagame reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes to this Policy will be communicated to registered players via email or prominent notice on the sayagame platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the sayagame platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

13 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or sayagame's data processing practices, please contact our Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.