Skinape Privacy Policy

1 Who We Are

Skinape is the operator of the online gaming platform accessible at skinape.net (the "Platform"). In this Privacy Policy, references to "Skinape," "we," "us," or "our" refer to the Skinape platform operator.

Skinape operates under a PAGCOR licence and is subject to the regulatory oversight of the Philippine Amusement and Gaming Corporation. As a data controller under the Philippine Data Privacy Act of 2012, Skinape is responsible for determining the purposes and means of processing personal data collected through the Platform.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and with applicable data protection legislation. You may contact our DPO using the details provided in Section 15 of this Policy.

2 Data We Collect

Skinape collects the following categories of personal data from registered players and platform visitors:

3 How We Collect Your Data

Skinape collects personal data through the following means:

• Direct interactions: Data you provide when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, server logs, and similar tracking technologies described in Section 8.
• Third-party sources: Identity verification data received from KYC service providers; fraud screening data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank; and regulatory data from PAGCOR where required for compliance purposes.
• Publicly available sources: Information from public registers or databases where necessary for fraud prevention or regulatory compliance.

4 Why We Use Your Data

Skinape uses your personal data for the following purposes:

• To create and manage your Skinape account and verify your identity and age (21+ requirement).
• To process deposits and withdrawals in Philippine Peso (₱) via your chosen payment method.
• To deliver the games, features, and services available on the Skinape Platform.
• To comply with our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited conduct as described in our Terms & Conditions.
• To monitor gaming activity for responsible gaming purposes and to apply player protection tools where appropriate.
• To send you transactional communications such as deposit confirmations, withdrawal notifications, and account security alerts.
• To send you promotional communications about Skinape offers and games, where you have provided consent or where we have a legitimate interest in doing so.
• To improve the Platform through analysis of usage patterns and player feedback.
• To resolve disputes and enforce our Terms & Conditions.

5 Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, tax reporting requirements, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where our interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Data Sharing & Disclosure

Skinape does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only where necessary and in accordance with applicable law:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist Skinape in verifying your identity and age as required by PAGCOR regulations.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or regulation.
• IT and platform service providers: Cloud hosting, cybersecurity, and software providers who process data on our behalf under strict data processing agreements that prohibit them from using your data for their own purposes.
• Professional advisers: Lawyers, auditors, and accountants where necessary for the conduct of Skinape's business, subject to professional confidentiality obligations.
• Law enforcement: Philippine law enforcement agencies where disclosure is required by a valid legal order or where Skinape reasonably believes disclosure is necessary to prevent or investigate a crime.

All third parties with whom Skinape shares personal data are required to handle that data in accordance with applicable data protection law and Skinape's data protection standards.

7 Data Retention

Skinape retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account data: Retained for the duration of your account and for a period of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements.
• Transaction and financial records: Retained for a minimum of five (5) years following the date of the transaction, in accordance with AMLA obligations.
• KYC documents: Retained for five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Technical and usage data: Retained for up to 24 months from the date of collection, unless a longer retention period is required for security or legal purposes.
• Marketing consent records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, as evidence of compliance.

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

8 Cookies & Tracking Technologies

Skinape uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform.

We use the following types of cookies:

• Strictly necessary cookies: Essential 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.
• Functional cookies: Remember your preferences such as language settings and game display options to provide a more personalised experience.
• Analytics cookies: Collect anonymised data about how players use the Platform, which pages are visited most frequently, and where errors occur. This data helps us improve the Platform. Analytics cookies are only set with your consent.
• Session cookies: Temporary cookies that expire when you close your browser, used to maintain your session state during a gaming session.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Skinape Platform. For detailed instructions on managing cookies in your browser, refer to your browser's help documentation.

9 Your Data Subject Rights

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

• Right to be informed: The right to be told what personal data Skinape holds about you and how it is being used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data Skinape 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 where it is no longer necessary for the purposes for which it was collected, subject to Skinape's legal retention obligations.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. Skinape will respond to all data subject requests within 15 business days of receipt. We may need to verify your identity before processing your request.

10 Children's Privacy

The Skinape Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing casino-style gaming in the Philippines. Skinape does not knowingly collect personal data from individuals under the age of 21.

If Skinape becomes aware that personal data has been collected from an individual under the age of 21, that account will be immediately suspended, all data will be deleted in accordance with our data disposal procedures, and any deposits will be returned to the payment source used at registration.

11 Data Security

Skinape implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Skinape Platform.
• Encryption of sensitive data at rest, including financial data and KYC documents.
• Role-based access controls ensuring that only authorised Skinape personnel can access personal data, and only to the extent necessary for their role.
• Regular security audits, vulnerability assessments, and penetration testing conducted by independent cybersecurity specialists.
• Multi-factor authentication for access to systems that process personal data.
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Skinape will notify the National Privacy Commission within 72 hours of becoming aware of the breach and will notify affected data subjects without undue delay, in accordance with the Data Privacy Act of 2012.

12 Cross-Border Data Transfers

Where Skinape transfers personal data outside the Philippines — for example, to cloud service providers or technology partners located in other countries — we ensure that such transfers are carried out in accordance with the Data Privacy Act of 2012 and the regulations of the National Privacy Commission.

Cross-border transfers are only made where the recipient country provides an adequate level of data protection, or where appropriate safeguards are in place such as contractual clauses approved by the NPC. Skinape will not transfer your personal data to a jurisdiction that does not provide adequate protection without your explicit consent or a valid legal basis.

13 Third-Party Services & Links

The Skinape Platform may contain references to third-party services such as payment providers. These third parties operate their own privacy policies, which are independent of this Privacy Policy. Skinape is not responsible for the privacy practices of third-party services.

When you use a third-party payment service such as GCash, PayMaya, BPI, BDO, or Metrobank to fund your Skinape account, your use of that service is governed by the privacy policy of the relevant payment provider. We encourage you to review the privacy policies of any third-party services you use in connection with the Skinape Platform.

Skinape does not embed third-party advertising networks or social media tracking pixels on the Platform. We do not share your gaming activity data with social media platforms.

14 Changes to This Privacy Policy

Skinape 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. Where changes are material, we will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect.

The date at the top of this Privacy Policy indicates when it was last updated. We encourage you to review this Policy periodically to stay informed about how Skinape protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgement of the updated Policy.

15 Contact Us & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or want to raise a concern about how Skinape handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]

Email addresses above are displayed as plain text only and are not clickable links. Please copy the address into your email client to get in touch.

Our DPO will acknowledge your request within 3 business days and provide a full response within 15 business days. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).

You may also reach our customer support team 24/7 through the live chat function available within the Skinape Platform when you are logged in to your account.