sky235 Privacy Policy

01 About This Policy

This Privacy Policy ("Policy") describes how sky235 ("sky235", "we", "us", "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you", "Player", "User") who access or use the sky235 online gaming platform, accessible at sky235.net and all associated interfaces (collectively, the "Platform").

sky235 is the personal information controller responsible for your data as defined under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations. sky235 is registered with the National Privacy Commission (NPC) as required under Philippine law.

This Policy applies to all personal data collected through your use of the sky235 Platform, whether via desktop browser, mobile browser, or any sky235 application. It does not apply to third-party websites or services that may be linked from sky235 — those third parties maintain their own separate privacy policies.

sky235 may update this Policy from time to time to reflect changes in our data practices, legal obligations, or regulatory guidance from the NPC or PAGCOR. The most current version of this Policy is always available on this page. The "Last Updated" date at the top reflects when the current version took effect.

02 Personal Data We Collect

sky235 collects the following categories of personal data from players and prospective players:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification details (e.g., PhilSys National ID number, UMID, Passport, or Driver's License number).
• Contact Data: Email address, mobile phone number, and residential address (city, province, ZIP code).
• Financial Data: GCash account number, PayMaya account number, bank account details (BPI, BDO, Metrobank), card details (Visa / Mastercard — stored only in tokenised form), and transaction records.
• Gaming Activity Data: Bet history, game session logs, win and loss records, bonus claims, promotional participation records, and responsible gaming tool usage.
• Technical Data: IP address, device identifier, browser type and version, operating system, screen resolution, and session log timestamps.
• Usage Data: Anonymised clickstream data, feature engagement metrics, and platform navigation patterns.
• Communications Data: Records of your interactions with the sky235 Support team, including live chat transcripts and email correspondence.
• Verification Data: Photographs or scans of government-issued ID documents and selfie verification images submitted as part of the KYC process.

sky235 does not collect sensitive personal information (as defined in the DPA) such as health records, biometric data (beyond identity verification photographs where required by KYC), religious affiliation, or political views. Where sensitive personal information is incidentally disclosed during a support interaction, sky235 will handle it with heightened care and process it only to the extent strictly necessary to resolve your query.

03 How We Collect Your Data

sky235 collects your personal data through the following channels and mechanisms:

• Direct collection: Data you provide when registering a sky235 account, completing the KYC verification process, making a deposit or withdrawal, contacting the Support team, participating in a promotion, or updating your account profile.
• Automated collection: Technical and usage data collected automatically when you access the sky235 Platform, via server logs, session tracking systems, and cookies. See Section 6 for full details on cookies.
• Third-party sources: Identity verification data from PAGCOR-approved KYC service providers, fraud intelligence data from anti-fraud screening services, and transaction data from payment processors (e.g., GCash, PayMaya, BPI, BDO, Metrobank) used to confirm successful deposits and withdrawals.

sky235 will always inform you at the point of collection whether the provision of certain personal data is mandatory (e.g., identity data for KYC) or optional. Where data is mandatory and you decline to provide it, sky235 may be unable to open or maintain your account or process certain transactions.

04 How We Use Your Data

sky235 uses your personal data only for specified, legitimate purposes. The table in the overview section above summarises the key processing activities. In full, sky235 uses personal data for the following purposes:

1. To create, verify, and maintain your sky235 player account, including age verification (players must be 21 years or older) and identity authentication.
2. To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, Visa, and Mastercard in Philippine Peso (PHP).
3. To deliver the sky235 Platform, including all game content, live casino, sports betting, bingo, sabong, and slot services.
4. To fulfil sky235's legal and regulatory obligations, including KYC verification, Anti-Money Laundering (AML) reporting to PAGCOR, and compliance with NPC data protection requirements.
5. To detect, prevent, and investigate fraud, unauthorised account access, bonus abuse, money laundering, and other prohibited conduct as defined in the sky235 Terms & Conditions.
6. To provide customer support and resolve disputes through the sky235 Support team.
7. To administer sky235 promotions, bonuses, and the VIP loyalty programme, including tracking wagering requirements and reward point balances.
8. To monitor responsible gaming indicators, apply player protection tools (deposit limits, self-exclusion), and comply with PAGCOR responsible gaming requirements. See the sky235 Responsible Gaming page for full details.
9. To send transactional communications (account notifications, deposit confirmations, withdrawal updates, and security alerts) by email or SMS.
10. To send promotional communications about sky235 offers and new features, where you have given consent or where permitted by applicable law. You may opt out of promotional communications at any time via your account settings or by contacting Support.
11. To conduct anonymised analytics and improve the sky235 Platform's performance, features, and user experience.

05 Sharing Your Data

sky235 does not sell, rent, or trade your personal data. We share personal data only in the following circumstances, and only to the minimum extent required for each purpose:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, and card network processors receive the financial data strictly necessary to execute your deposit and withdrawal transactions.
• KYC & Identity Verification Providers: PAGCOR-approved third-party KYC providers receive identity documents and verification data to complete mandatory player verification. These providers are contractually bound to use your data solely for verification purposes.
• AML & Fraud Screening Services: Transaction data and risk indicators may be shared with anti-fraud and AML compliance service providers to fulfil sky235's obligations under Philippine financial regulations and PAGCOR requirements.
• PAGCOR & Regulatory Authorities: sky235 may be required by law or regulatory direction to disclose player data to PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), or other Philippine government authorities. Such disclosures are made only to the extent legally required.
• Law Enforcement: Where required by a valid court order, subpoena, or other lawful demand from Philippine law enforcement authorities, sky235 will disclose the requested information.
• Service Providers: Hosting providers, cloud infrastructure providers, and other technical service providers who process data on sky235's behalf under data processing agreements that impose obligations equivalent to those in this Policy.
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all of sky235's assets, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments. You will be notified of any such transfer in advance.

All third parties who receive personal data from sky235 are required to maintain appropriate technical and organisational security measures and to use the data only for the specific purpose for which it was shared.

06 Cookies & Tracking Technologies

The sky235 Platform uses cookies and similar technologies (such as local storage and session storage) to provide a functional, secure, and personalised experience. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Required for the sky235 Platform to function. These include session authentication cookies that keep you logged in during your gaming session, CSRF protection tokens, and load balancing cookies. These cannot be disabled without breaking the Platform.
• Functional Cookies: Remember your preferences such as preferred language, interface settings, and responsible gaming tool configurations, so you don't need to re-enter them on each visit.
• Analytics Cookies: Collect anonymised data about how players use the sky235 Platform — which pages are most visited, where users navigate from, and session duration. This data is aggregated and cannot be used to identify individual players. sky235 uses this data solely to improve the platform experience.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and account takeover attempts. These are essential for maintaining the integrity of the sky235 Platform.

sky235 does not use third-party advertising cookies or cross-site tracking technologies that profile your browsing activity outside the sky235 Platform. You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to log in and use sky235.

07 Data Retention

sky235 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The key retention periods applied by sky235 are as follows:

• Active account data (identity, contact, financial, gaming activity) is retained for the lifetime of your sky235 account.
• KYC verification documents are retained for a minimum of five (5) years following account closure, as required under Philippine AML regulations and PAGCOR operational standards.
• Transaction records (deposits, withdrawals, bet history) are retained for a minimum of five (5) years following the transaction date for AML and financial audit purposes.
• Support communications are retained for two (2) years following resolution of the relevant support interaction.
• Technical and security logs are retained for twelve (12) months from the date of collection, after which they are purged or anonymised.
• Marketing consent records are retained for the duration of your consent, plus three (3) years to evidence compliance with consent requirements.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original personal information. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

08 Data Security

sky235 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• AES-256 encryption for all personal data stored in sky235 databases and backup systems.
• TLS 1.3 encryption for all data transmitted between your device and the sky235 Platform.
• Card payment data (Visa / Mastercard) is handled exclusively via PCI-DSS compliant payment processors — sky235 never stores raw card numbers.
• Role-based access control (RBAC) and the principle of least privilege applied to all internal systems that handle personal data.
• Full audit logging of all internal access to personal data, reviewed regularly by the sky235 security team.
• Mandatory two-factor authentication (2FA) for all sky235 staff who access systems containing personal data.
• Regular penetration testing and vulnerability assessments of the sky235 Platform and supporting infrastructure.
• A documented Data Breach Response Plan, aligned with NPC notification requirements under the Data Privacy Act.

In the event of a personal data breach that poses a real risk to affected individuals, sky235 will notify the NPC within 72 hours of becoming aware of the breach and will notify affected players without undue delay, as required under the DPA.

09 Your Rights Under Philippine Law

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:

To exercise any of the above rights, contact the sky235 Data Protection Officer through the Support page. sky235 will respond to all verified data subject requests within fifteen (15) business days of receipt, as required under the DPA. In complex cases, this period may be extended by a further fifteen (15) business days with written notice to you explaining the reason for the extension.

To protect the security of your account, sky235 may require identity verification before processing a data subject request. This ensures that personal data is disclosed only to the rightful account holder.

10 Children & Minors

The sky235 Platform is strictly intended for adults aged 21 years or older, in compliance with PAGCOR regulations governing online gaming in the Philippines. sky235 does not knowingly collect personal data from individuals under the age of 21.

All player accounts are subject to mandatory age and identity verification as part of the KYC process before any gaming activity or financial transactions are permitted. Any account found to belong to a person under 21 years of age will be immediately suspended and all funds held in the account will be returned to the source of deposit, net of any gaming losses, in accordance with PAGCOR guidelines.

If you are a parent or guardian and believe that a minor has registered a sky235 account or provided personal data to sky235 without your consent, please contact the sky235 Support team immediately through the Support page. sky235 will investigate the matter promptly and delete any personal data collected from a verified minor.

11 International Data Transfers

sky235 primarily processes personal data within the Philippines. Where personal data is transferred to or accessed from outside the Philippines — for example, by cloud infrastructure providers or KYC verification partners operating internationally — sky235 ensures that adequate safeguards are in place to protect such transfers, in accordance with the DPA and NPC regulations.

Adequate safeguards for international transfers include:

• Data processing agreements that impose DPA-equivalent obligations on the receiving party.
• Standard contractual clauses approved by the NPC or an equivalent supervisory authority.
• Transfers only to jurisdictions that the NPC has recognised as providing an adequate level of data protection.

You may request further information about the safeguards applied to specific international data transfers by contacting the sky235 Data Protection Officer via the Support page.

12 Changes to This Policy

sky235 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory guidance from the NPC or PAGCOR, or changes to the sky235 Platform.

When material changes are made to this Policy, sky235 will:

• Update the "Last Updated" date at the top of this page.
• Display a prominent notice on the sky235 Platform homepage for a period of at least 14 days following the update.
• Send an email notification to all registered sky235 players summarising the key changes.

Your continued use of the sky235 Platform after the effective date of a revised Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with any updated terms, you should stop using the Platform and may request account closure by contacting the sky235 Support team.

13 Contact & DPO Details

sky235 has appointed a Data Protection Officer (DPO) to oversee compliance with the Philippine Data Privacy Act and to handle all data subject requests and privacy-related enquiries.

To contact the sky235 DPO or to exercise any of your data subject rights, please use any of the following channels:

• Support Portal: Submit a data subject request via the sky235 Support page — select "Privacy & Data Request" as the enquiry category.
• Email: Send your request to [email protected] with the subject line "Data Subject Request – [Your Full Name]".
• Registered Address: sky235 Operations, Metro Manila, Philippines.

If you are not satisfied with sky235's response to your data subject request or believe sky235 has not handled your personal data in accordance with the DPA, you have the right to lodge a complaint with the National Privacy Commission (NPC). The NPC can be contacted through the official NPC website at privacy.gov.ph (external government website — sky235 does not control its content).