Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to sky235 and governs the collection, processing, storage, and disclosure of personal data obtained through your use of the sky235 website at sky235.cam, any associated mobile applications, live chat services, and all related online gaming products offered under the sky235 brand. This policy covers all registered players, prospective players who have initiated the registration process, and visitors who access the platform without registering an account.

sky235 operates as a data controller with respect to personal data collected through the platform. As a PAGCOR-regulated entity, sky235 processes personal data in strict compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations, as enforced by the National Privacy Commission (NPC). Where applicable, sky235 also adheres to international data protection standards for cross-border data transfers.

By creating an account on sky235 or otherwise using the platform, you expressly consent to the collection, processing, and use of your personal data as described in this Privacy Policy. If you do not agree with the terms of this policy, please discontinue use of the platform immediately and contact our Data Protection Officer to request deletion of any information you may have already provided.

2. Personal Data We Collect

sky235 collects personal data through multiple touchpoints during your interaction with the platform. The categories of personal data collected, and the primary purpose for collection of each, are described below.

2.1 Registration and Identity Data

When you register an account on sky235, we collect the information necessary to create and verify your account and to comply with our legal obligations under PAGCOR's Know Your Customer (KYC) requirements and Philippine anti-money laundering law:

• Full legal name as it appears on your government-issued identification document
• Date of birth (for the purpose of verifying you are at least 21 years of age)
• Residential address, including barangay, city or municipality, province, and postal code
• Valid email address and active Philippine mobile number
• Copies of government-issued identification documents, such as a Philippine passport, UMID, SSS ID, PhilHealth ID, driver's license, or any other valid ID accepted by PAGCOR KYC guidelines
• A selfie or live photograph for facial verification purposes, where required during the enhanced KYC process

2.2 Financial and Payment Data

To process deposits and withdrawals in Philippine Pesos (PHP), sky235 collects payment-related information. This may include the name registered to your GCash or PayMaya wallet, the last four digits of bank account numbers associated with BPI, BDO, or Metrobank accounts linked to your sky235 profile, and transaction reference numbers for deposits made through retail channels such as 7-Eleven, Cebuana Lhuillier, or M Lhuillier. sky235 does not store full bank account numbers or card numbers. Complete financial credentials are handled exclusively by our certified payment processing partners.

2.3 Gaming Activity Data

sky235 maintains a detailed record of all gaming activity conducted through your account. This includes games played, bet amounts, game outcomes, session duration, bonus utilization, and jackpot winnings. This data is used for account management, dispute resolution, responsible gaming monitoring, regulatory reporting to PAGCOR, and the detection of fraudulent or collusive behavior.

2.4 Technical and Device Data

When you access sky235 through any device, we automatically collect technical information about that device and your interaction with the platform:

3. How sky235 Uses Your Personal Data

sky235 uses the personal data we collect only for legitimate purposes directly related to the operation of the platform and our regulatory obligations. We do not sell personal data to third parties for marketing or commercial purposes. The primary uses of your personal data are as follows:

• Account Management: Creating and maintaining your sky235 account, verifying your identity and age, processing deposits and withdrawals, and providing access to gaming products.
• Regulatory Compliance: Meeting our KYC obligations under PAGCOR's licensing requirements, complying with the Anti-Money Laundering Act (AMLA) of the Philippines, and making disclosures required by law enforcement or regulatory authorities where legally compelled.
• Fraud Prevention and Security: Monitoring account activity to detect and prevent unauthorized access, fraudulent transactions, money laundering, collusion, and the use of automated tools or bots.
• Responsible Gaming: Monitoring gaming patterns to identify signs of problem gambling, implementing deposit limits and self-exclusion tools, and contacting players proactively where our monitoring systems indicate potential gambling harm.
• Customer Support: Responding to inquiries, resolving disputes, and providing technical assistance through our 24/7 support channels.
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve the sky235 platform, optimize game performance, and develop new features for Filipino players.
• Communications: Sending transaction confirmations, security alerts, responsible gaming notifications, and account-related service messages. Where you have provided explicit consent, we may also send promotional communications, which you may opt out of at any time.

4. Legal Bases for Processing

Under the Data Privacy Act of 2012, sky235 relies on the following lawful bases for processing your personal data:

• Contractual Necessity: Processing required to fulfill the agreement between you and sky235, including account management, payment processing, and the provision of gaming services.
• Legal Obligation: Processing necessary to comply with PAGCOR's regulatory requirements, AMLA reporting obligations, court orders, and other applicable Philippine laws.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregated analytics, where such interests are not overridden by your privacy rights.
• Consent: Where we send promotional communications or process data for purposes beyond those listed above, we will obtain your explicit and freely given consent in advance.

5. Data Sharing and Third-Party Disclosure

5.1 Service Providers

sky235 shares personal data with carefully vetted third-party service providers who assist in operating the platform. These include payment processing partners (such as operators of GCash, PayMaya, and banking transfer infrastructure), identity verification providers, game software suppliers, customer support technology platforms, and cloud hosting providers. All third-party service providers are contractually bound to process personal data only on sky235's instructions and to implement appropriate security measures.

5.2 Regulatory Authorities

sky235 is obligated to disclose personal data to PAGCOR and other Philippine regulatory bodies, including the Anti-Money Laundering Council (AMLC) and the National Privacy Commission (NPC), when required by law or regulation. We may also disclose personal data to law enforcement agencies in response to valid legal process. sky235 will notify affected players of such disclosures where legally permissible and practically possible.

5.3 Cross-Border Transfers

Some of sky235's service providers are located outside of the Philippines. Where personal data is transferred to recipients in other countries, sky235 ensures that appropriate safeguards are in place — including standard contractual clauses, adequacy determinations, or other transfer mechanisms recognized under the Data Privacy Act — to ensure your data receives equivalent protection.

6. Data Retention

sky235 retains personal data for as long as your account remains active and for a minimum period of five (5) years following account closure, as required by PAGCOR's record-keeping regulations and AMLA obligations. Certain categories of data — particularly financial transaction records and KYC documentation — may be retained for longer periods where required by applicable law.

Technical and session data is typically retained for twelve (12) months from collection. Communication records, including live chat transcripts and support ticket correspondence, are retained for three (3) years. Following the applicable retention period, data is securely deleted or anonymized in a manner that prevents re-identification.

7. Cookies and Tracking Technologies

sky235 uses cookies and similar tracking technologies to maintain platform functionality, remember your preferences, and analyze how the platform is used. Strictly necessary cookies — those required for the platform to function, such as session authentication tokens — are always active and cannot be disabled. Preference, analytics, and performance cookies may be managed through your browser settings or by contacting our support team.

sky235 does not use third-party advertising cookies or tracking technologies that would share your browsing data with external advertising networks. All analytics data collected through cookies is processed in anonymized or pseudonymized form.

8. Data Security

sky235 implements industry-standard technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These measures include Transport Layer Security (TLS) encryption for all data in transit, encryption at rest for sensitive personal data fields, strict role-based access controls limiting employee access to personal data on a need-to-know basis, regular security audits and penetration testing conducted by independent third parties, and multi-factor authentication requirements for administrative account access.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, sky235 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with the requirements of the Data Privacy Act.

9. Your Rights as a Data Subject

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by sky235:

• Right to Be Informed: You have the right to be informed of how your personal data is being collected, processed, and used by sky235.
• Right to Access: You may request a copy of the personal data sky235 holds about you, including a summary of how it is being processed.
• Right to Correction: If any personal data we hold about you is inaccurate, incomplete, or outdated, you have the right to request correction.
• Right to Erasure or Blocking: You may request the deletion or blocking of personal data where it is no longer necessary for the purposes for which it was collected, provided that retention is not required by applicable law.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where processing is based on legitimate interests, including profiling for direct marketing purposes.
• Right to Complain: If you believe sky235 has failed to handle your personal data in accordance with this policy or applicable law, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please contact sky235's Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days. In complex cases, this period may be extended by a further fifteen (15) days, with prior notice to you.

10. Minors and Age Verification

sky235 does not knowingly collect personal data from individuals under the age of 21. The platform is strictly for adults aged 21 years and above, in accordance with PAGCOR's minimum age requirements for online gaming in the Philippines. Age verification is conducted as part of the mandatory KYC process before any real-money gaming activity is permitted. If sky235 becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted immediately and the associated account closed.

11. Changes to This Privacy Policy

sky235 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes will be communicated to registered players via email and through a prominent notice on the platform prior to the changes taking effect. The effective date at the top of this document will always reflect when the current version came into force. Continued use of the sky235 platform after any amendment constitutes your acceptance of the revised policy.

12. Contact and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by sky235, please contact us:

• Data Protection Officer (DPO): sky235 Data Protection Office
• Email: [email protected]
• Support Hours: 24/7 (Philippine Standard Time)

If you are not satisfied with our response, you may escalate your complaint to the National Privacy Commission of the Philippines at [email protected] or through the NPC's official online complaint portal.