Snugwin Privacy Policy —
Your Data, Handled with Care

Snugwin takes the privacy of its players seriously. We know that handing over personal information to any online platform requires trust, and we don't take that lightly. This Privacy Policy is designed to give you a complete and honest picture of how Snugwin collects, processes, stores, and protects your personal data when you use our website at snugwin.net and any related services.

This policy applies to all registered Snugwin players, website visitors, and anyone who interacts with Snugwin's platform or support channels. It covers data collected through the Snugwin website, account registration forms, payment processing, customer support interactions, and any cookies or tracking technologies used on the platform.

We update this policy whenever our data practices change in a material way. The "Last Updated" date at the top of this page always reflects the most current version. If you continue using Snugwin after a policy update, you are accepting the revised terms.

For the purposes of the Data Privacy Act of 2012, Snugwin is the personal information controller — meaning we determine the purposes and means of processing your personal data. We operate under a PAGCOR licence and are legally accountable for how your information is handled.

Snugwin has appointed a designated Data Protection Officer (DPO) who is responsible for ensuring compliance with data privacy laws, handling data subject access requests, managing data breach responses, and coordinating with the National Privacy Commission as required. You can contact our DPO directly at privacy@snugwin.net.

Our DPO is registered with the National Privacy Commission of the Philippines as required by NPC Circular No. 17-01.

Snugwin collects personal data in several ways — some you provide directly, some we collect automatically as you use the platform. Here is a full breakdown:

Data you provide directly:

• Registration data: Full legal name, date of birth, Philippine mobile number, email address, and the username and password you create.
• Identity verification (KYC): Government-issued ID number and type (PhilSys, passport, driver's licence, UMID, voter's ID, PRC, SSS/GSIS ID), ID expiry date, and a photo of the ID document.
• Payment information: GCash mobile number, Maya account reference, bank account name and number (for InstaPay/PESONet transfers), and Visa/Mastercard card details (processed securely by PCI-DSS compliant payment processors — Snugwin does not store full card numbers).
• Support communications: Any information you share when contacting Snugwin via live chat, email, or other support channels.

Data collected automatically:

• Device and browser data: IP address, device type, operating system, browser type and version.
• Session data: Pages visited, time spent on each page, bet history, game activity logs, login timestamps, and session duration.
• Location data: Approximate geolocation derived from IP address, used to verify compliance with Philippine territorial access requirements.
• Cookie data: Information collected through cookies and similar tracking technologies as described in Section 7 of this policy.

Snugwin only uses your personal data for the purposes it was collected for. We do not use your data for unrelated activities without your separate consent. Here are the specific purposes for which your data is processed:

• Account operation: To create and manage your Snugwin account, process logins, maintain your balance, and record your betting and gaming activity.
• Identity verification: To confirm your age, identity, and eligibility as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Payment processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and card payment channels, and to verify that transactions originate from accounts registered in your name.
• Legal and regulatory compliance: To fulfil reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and any other Philippine regulatory body with jurisdiction over our operations.
• Fraud and security monitoring: To detect and prevent fraudulent activity, bonus abuse, multi-accounting, and any other prohibited behaviour under Snugwin's Terms and Conditions.
• Customer support: To respond to your inquiries, resolve disputes, process responsible gaming requests, and provide technical assistance.
• Platform improvement: To analyse aggregate usage patterns, identify technical issues, and improve the Snugwin user experience — using anonymised and aggregated data where possible.
• Marketing communications: To send you promotions, bonus offers, and gaming updates where you have opted in to receive these communications. You can opt out at any time.

Under the Data Privacy Act of 2012, Snugwin processes your personal data only when a valid legal basis exists. The applicable bases for Snugwin's data processing activities are:

• Contract performance: Processing necessary to fulfil the gaming services contract between you and Snugwin — account operation, bet settlement, payments.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AMLC reporting obligations, BIR requirements, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and aggregate analytics — where our legitimate interests do not override your privacy rights.
• Consent: Processing for direct marketing communications, where you have given explicit consent and which you may withdraw at any time.

Snugwin shares your personal data only in the following specific circumstances and only to the extent necessary:

• Payment processors: Your payment details are shared with licensed Philippine payment processors (GCash/GXI, Maya/PayMaya, BancNet, and card payment gateways) strictly for the purpose of processing your transactions. These processors operate under their own privacy policies and are compliant with PCI-DSS and Philippine data privacy requirements.
• PAGCOR: As our licensing authority, PAGCOR may require access to player activity data, bet records, and identity information as part of its regulatory oversight function.
• Anti-Money Laundering Council (AMLC): Snugwin is required by the Anti-Money Laundering Act of 2001 (as amended) to report suspicious transactions and maintain records for AMLC reporting purposes.
• Bureau of Internal Revenue (BIR): Player winnings above reportable thresholds may be reported to the BIR in compliance with Philippine tax law.
• KYC verification partners: Third-party identity verification services may process your ID documents to assist with KYC compliance. These partners are contractually bound to process your data only for verification purposes.
• Technical infrastructure providers: Cloud hosting, platform maintenance, and security monitoring providers who process data on Snugwin's behalf under data processing agreements that require them to maintain confidentiality and security standards equivalent to this policy.

Snugwin does not share your personal data with any other third party outside of these categories. We do not sell, rent, or trade your personal information to advertisers, data brokers, or marketing companies.

Snugwin uses cookies and similar tracking technologies on the platform. A cookie is a small text file stored in your browser that helps us recognise you when you return, remember your preferences, and understand how you use the platform.

Types of cookies Snugwin uses:

• Essential cookies: Required for the platform to function. These include session authentication cookies that keep you logged in, betslip cookies that preserve your current selections, and security tokens. You cannot opt out of these without affecting platform functionality.
• Analytics cookies: Used to understand aggregate platform usage — which pages are visited most, where players encounter technical issues, and how the overall platform is performing. Snugwin uses anonymised, aggregated analytics data only.
• Preference cookies: Store your platform settings such as language preference and notification preferences so you don't have to reset them each session.
• Marketing cookies: Used to measure the effectiveness of promotional campaigns. These are only set where you have accepted marketing communications. You can opt out via account settings.

You can manage or delete cookies through your browser settings. Disabling essential cookies will affect your ability to use core Snugwin features including logging in and placing bets.

Snugwin implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• TLS encryption: All data transmitted between your device and the Snugwin platform is encrypted using Transport Layer Security (TLS 1.3). The padlock icon in your browser confirms this when visiting snugwin.net.
• Data encryption at rest: Sensitive personal data, including identity documents and payment references, is encrypted in our databases using industry-standard encryption algorithms.
• Access controls: Snugwin employee access to player personal data is strictly role-based. Only staff who need specific data to perform their job function can access it, and all access is logged and audited.
• Two-factor authentication (2FA): Available for all Snugwin player accounts. We strongly recommend enabling 2FA via your account security settings.
• Regular security audits: Snugwin commissions independent security assessments and penetration testing on a regular basis to identify and remediate vulnerabilities before they can be exploited.
• Incident response: In the event of a personal data breach, Snugwin will notify affected players and the National Privacy Commission within 72 hours of becoming aware of the breach, as required by NPC Circular No. 16-03.

Snugwin retains your personal data for as long as necessary to fulfil the purposes for which it was collected, and for as long as required by Philippine law. Specific retention periods include:

• Account data: Retained for the duration of your active Snugwin account, and for a minimum of five years after account closure as required by PAGCOR licensing and AMLC regulations.
• Transaction records: Deposit, withdrawal, and bet records are retained for a minimum of five years under AMLC and BIR reporting requirements.
• KYC documents: Identity verification documents are retained for five years after the relationship with the player ends, as required by the Anti-Money Laundering Act.
• Support communications: Customer support chat logs and email correspondence are retained for two years to assist with dispute resolution.
• Marketing data: Retained only while your marketing consent is active. Once you withdraw consent, your marketing profile is deactivated and scheduled for deletion within 30 days, subject to the minimum retention periods above.

When personal data is no longer required for any lawful purpose, it is securely deleted or anonymised in accordance with Snugwin's data disposal procedures.

To exercise any of your rights under the Data Privacy Act of 2012 — including access, correction, erasure, or objection — please submit a request to our Data Protection Officer at privacy@snugwin.net. Please include:

• Your full name as registered on your Snugwin account.
• Your registered Snugwin email address or mobile number.
• A description of the specific right you are exercising and the information the request relates to.
• A copy of a valid Philippine government-issued ID to verify your identity (required for access and erasure requests).

Snugwin will acknowledge your request within three business days and fulfil it within fifteen business days of identity verification. If your request is complex or involves a large volume of data, we may extend this period by a further fifteen days — we will notify you if this extension is required.

If you are unsatisfied with Snugwin's response to a data rights request, you may escalate the matter to the National Privacy Commission of the Philippines at complaints.npc.gov.ph.

The Snugwin platform is strictly for individuals who are 21 years of age and above. Snugwin does not knowingly collect personal data from anyone under the age of 21. All registration attempts are subject to age verification, and KYC identity checks are used to confirm the age of players requesting withdrawals.

If Snugwin becomes aware that personal data has been collected from an individual under the legal age, we will immediately deactivate the relevant account, delete all associated data to the extent permissible by law, and report the matter to PAGCOR as required.

If you are a parent or guardian and believe a minor has created a Snugwin account using false information, please contact us immediately at privacy@snugwin.net so we can investigate and act quickly.

Snugwin sends promotional communications — including bonus offers, free bet announcements, game updates, and special events — only to players who have explicitly opted in to receive them. Marketing consent is requested during account registration and can be managed at any time from your account settings under "Communication Preferences."

To stop receiving marketing communications from Snugwin:

• Click the "Unsubscribe" link in any marketing email — you will be unsubscribed within 24 hours.
• Update your communication preferences directly in your Snugwin account settings — effective immediately.
• Contact support via live chat and request removal from all marketing lists — processed within 3 business days.

Please note that even if you opt out of marketing communications, Snugwin will still send you service and account communications — including deposit confirmations, withdrawal notifications, security alerts, and important policy updates. These are not marketing messages and cannot be opted out of while you hold an active Snugwin account.

Snugwin may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. When material changes are made, we will notify registered players by email or via an in-platform notification at least 7 days before the changes take effect.

The updated policy will be published on this page with a revised "Last Updated" date. If the changes are significant — for example, a new type of data collection or a new category of data sharing — we may ask for your renewed consent before the changes take effect.

Continuing to use the Snugwin platform after a policy update constitutes your acceptance of the revised Privacy Policy. If you do not accept the updated policy, please contact us to close your account.

For any question, concern, or request relating to your personal data and this Privacy Policy, please contact the Snugwin Data Protection Officer:

• Email: privacy@snugwin.net
• Response time: Within 3 business days for general inquiries; within 15 business days for formal data subject requests.
• For general support: support@snugwin.net or via live chat in your Snugwin account.

If you believe Snugwin has violated your rights under the Data Privacy Act of 2012, you may file a complaint with the National Privacy Commission of the Philippines. For information about Snugwin's full terms of service, see our Terms and Conditions page. For responsible gaming tools and resources, visit our Responsible Gaming page.