sog138 Privacy Policy

In this Privacy Policy, the following terms carry the meanings set out below:

• "sog138," "Platform," "we," "us," "our" — the sog138 online gaming platform accessible at sog138.cam and all services provided thereunder.
• "Player," "you," "your," "data subject" — any individual who registers an account on, visits, or interacts with the sog138 platform.
• "Personal Data" — any information relating to an identified or identifiable natural person, as defined under Republic Act 10173 (Data Privacy Act of 2012).
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, erasure, or destruction.
• "Personal Information Controller (PIC)" — sog138, as the entity that determines the purposes and means of processing Personal Data.
• "Personal Information Processor (PIP)" — any third party that processes Personal Data on behalf of sog138 under a data processing agreement.
• "Sensitive Personal Information" — as defined in RA 10173, including but not limited to government-issued identification numbers, financial account details, and information relating to health or legal proceedings.
• "NPC" — the National Privacy Commission of the Philippines, the regulatory body responsible for administering RA 10173.

sog138 is an online casino and sports betting platform operated for the Philippines market, accessible at sog138.cam. As the operator of this platform, sog138 acts as the Personal Information Controller for all Personal Data collected from Players and visitors in connection with the use of its services.

sog138 is committed to processing all Personal Data in full compliance with Republic Act 10173 (the Data Privacy Act of 2012), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission. Where data is processed in connection with financial transactions, sog138 also adheres to applicable Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations as they apply to the Philippine online gaming sector.

sog138 collects the following categories of Personal Data from Players and platform visitors. Collection is limited to what is necessary for the specific purposes outlined in Section 5.

sog138 does not intentionally collect Special Categories of Sensitive Personal Information beyond what is listed above and what is strictly necessary for identity verification and regulatory compliance. Where such data is incidentally disclosed during verification procedures, it is processed solely for the stated KYC purpose and is not used for any other purpose.

sog138 collects Personal Data through the following channels and methods:

• Direct collection at registration: When you create a sog138 account, you provide Identity Data and Contact Data directly through the registration form.
• Deposits and withdrawals: When you transact through the sog138 cashier using GCash, Maya, or bank transfer, Financial Data is collected directly and from the relevant payment service provider.
• KYC verification submissions: When prompted to verify your identity before withdrawals, you upload Verification Documents directly through the sog138 platform.
• Platform usage: Technical Data and Usage Data are automatically collected as you navigate and interact with the sog138 platform through standard server logs and session tracking.
• Customer support interactions: Communications Data is collected when you contact sog138 through live chat, email, or other support channels.
• Cookies and similar technologies: As described in Section 10, certain data is collected automatically through cookies placed on your device during your visit to sog138.cam.
• Third-party sources: sog138 may receive identity and fraud screening data from licensed KYC verification providers and payment processors as part of the account verification and transaction monitoring process.

sog138 processes Personal Data only where a valid legal basis exists under Republic Act 10173. The following table sets out the primary purposes for which sog138 processes Personal Data and the applicable legal basis for each:

• Account creation and management: Processing is necessary for the performance of the contract between sog138 and the Player (i.e., the Terms & Conditions). Without this processing, sog138 cannot provide its gaming services to you.
• Identity and age verification (KYC): Processing is required to comply with sog138's legal obligations under applicable gaming regulations and anti-money laundering legislation. The 21+ age verification requirement is a non-negotiable legal obligation.
• Payment processing: Processing is necessary for the performance of the contract and for compliance with applicable financial regulations governing deposits and withdrawals on gaming platforms.
• Fraud prevention and security: Processing is necessary for the purposes of the legitimate interests pursued by sog138 in maintaining a secure platform and protecting its Players and business from fraudulent activity, where such interests are not overridden by the Player's privacy rights.
• Responsible gaming monitoring: Processing is carried out on the basis of sog138's legal and regulatory obligations to monitor for problematic gambling patterns and enforce responsible gaming controls, including age verification and self-exclusion compliance.
• Customer support: Processing is necessary for the performance of the contract and for the pursuit of sog138's legitimate interest in resolving customer queries and maintaining service quality.
• Marketing communications: Where you have provided explicit consent, sog138 may use your Contact Data to send promotional communications about bonuses, new games, and platform updates. You may withdraw this consent at any time through your account settings or by contacting support.
• Legal and regulatory compliance: Processing may be required to satisfy obligations to regulatory authorities, including law enforcement agencies, anti-money laundering authorities, and the NPC in accordance with applicable Philippine law.

sog138 does not sell, rent, or commercially transfer your Personal Data to any third party. Personal Data is shared only in the following limited and controlled circumstances:

• Payment processors: GCash (GXI), Maya (Voyager Innovations), and partner banks (BPI, BDO, Metrobank) receive the financial and identity data necessary to process your deposits and withdrawals. These processors are bound by their own privacy frameworks and applicable Philippine financial regulations.
• Identity verification providers: Licensed KYC and AML screening providers may receive Identity Data and Verification Documents to perform identity checks and sanctions screening as required prior to processing withdrawals.
• Game software providers: Game studios whose titles are hosted on sog138 (such as Pragmatic Play, PG Soft, and Jili) may receive limited Technical Data and Usage Data necessary for game session management and RTP certification. These providers do not receive Identity Data or Financial Data.
• Regulatory and law enforcement authorities: sog138 will disclose Personal Data to the NPC, the Anti-Money Laundering Council (AMLC), law enforcement agencies, and other competent Philippine authorities where required or permitted by law, including in connection with investigation of suspected criminal offences.
• Professional advisers: Legal, accounting, and compliance advisers engaged by sog138 may access Personal Data to the extent necessary to provide professional services, subject to appropriate confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or restructuring of the sog138 business, Personal Data may be transferred to the relevant successor entity, subject to equivalent privacy protections.

Certain service providers engaged by sog138 — including game platform infrastructure providers and cloud hosting services — may store or process Personal Data on servers located outside the Philippines. Where such transfers occur, sog138 ensures that appropriate safeguards are in place to protect your Personal Data to a standard at least equivalent to that required under RA 10173.

Safeguards for international transfers include contractual clauses that impose binding data protection obligations on the receiving entity, as well as assessments to confirm that the destination jurisdiction provides an adequate level of data protection for the categories of data being transferred.

Players who wish to obtain further information about the specific safeguards in place for any international data transfer may submit a written request to the sog138 Data Protection Officer using the contact details in Section 14.

sog138 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required to comply with applicable legal and regulatory obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of the account relationship and for a period of five (5) years following permanent account closure, in compliance with AML record-keeping obligations.
• Financial and Transaction Data: Retained for a minimum of five (5) years following each transaction, in accordance with the requirements of the Anti-Money Laundering Act and related AMLC regulations.
• KYC and Verification Documents: Retained for five (5) years following account closure or the completion of the transaction for which verification was required, whichever is later.
• Technical and Usage Data: Retained for up to twenty-four (24) months from the date of collection, after which it is anonymised or deleted.
• Customer Support Communications: Retained for two (2) years following the resolution of the relevant support interaction, except where the communication is relevant to an unresolved legal dispute.
• Self-Exclusion Records: Retained permanently to prevent re-registration of excluded Players, in accordance with responsible gaming obligations.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with sog138's data disposal procedures.

sog138 implements a comprehensive set of technical and organisational security measures designed to protect Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption in transit: All data transmitted between your device and sog138 servers is encrypted using TLS 1.3 with 256-bit encryption.
• Encryption at rest: Personal Data stored on sog138 servers is encrypted using AES-256 encryption.
• Access controls: Access to systems containing Personal Data is restricted to authorised personnel only, on a strict need-to-know basis, and is secured by multi-factor authentication.
• Security monitoring: sog138 operates continuous monitoring of its systems for suspicious activity, with automated alerts for anomalous access patterns.
• Penetration testing: sog138's platform infrastructure undergoes regular third-party penetration testing to identify and remediate vulnerabilities.
• Incident response: sog138 maintains a documented data breach response procedure. In the event of a personal data breach, sog138 will notify the NPC and affected data subjects within the timeframes required by RA 10173 and its IRR.
• Staff training: All sog138 personnel with access to Personal Data undergo mandatory data privacy training and are bound by confidentiality obligations.

Notwithstanding these measures, no online platform can guarantee absolute security against all possible threats. Players are responsible for maintaining the security of their own sog138 account credentials and for notifying sog138 immediately upon discovering any suspected unauthorised access to their account.

sog138 uses cookies and similar browser-based technologies to support the operation of the platform, maintain session security, and analyse platform usage patterns. The following types of cookies are used:

• Strictly Necessary Cookies: These cookies are required for the sog138 platform to function correctly. They maintain your login session, remember your language and currency preference, and support security features such as CSRF protection. These cookies cannot be disabled without impairing core platform functionality.
• Analytical / Performance Cookies: sog138 uses first-party analytics cookies to understand how Players interact with the platform — which sections are most visited, where sessions typically end, and how platform performance can be improved. This data is aggregated and does not identify individual Players.
• Functional Cookies: These cookies remember your preferences such as game lobby view settings, notification preferences, and cashier settings to provide a more personalised experience on repeat visits.

sog138 does not deploy third-party advertising or behavioural targeting cookies on its platform. No cookie data from sog138 is shared with advertising networks or used to build advertising profiles.

You may manage cookie preferences through your browser settings. Note that disabling Strictly Necessary Cookies may prevent the sog138 platform from functioning as intended, including preventing you from maintaining a logged-in session.

Under Republic Act 10173 (Data Privacy Act of 2012), you have the following rights with respect to your Personal Data held by sog138. These rights may be exercised by submitting a written request to the sog138 Data Protection Officer using the contact details in Section 14.

• Right to be Informed: You have the right to be informed of how your Personal Data is being processed. This Privacy Policy is sog138's primary mechanism for fulfilling this obligation.
• Right of Access: You may request a copy of the Personal Data that sog138 holds about you, together with information about how it is processed. sog138 will provide a response within thirty (30) calendar days of receiving a valid request.
• Right to Rectification: If any Personal Data held by sog138 is inaccurate or incomplete, you may request that it be corrected. Minor corrections (e.g., email address updates) may be made directly through your account settings.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where consent has been withdrawn, or where processing is unlawful. This right is subject to sog138's legal retention obligations — data required for AML compliance, active dispute resolution, or regulatory audit cannot be deleted before the applicable statutory retention period expires.
• Right to Object: You may object to the processing of your Personal Data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where you believe your rights and interests override sog138's.
• Right to Data Portability: Where processing is carried out by automated means, you may request that sog138 provide your Personal Data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: If you believe that sog138 has processed your Personal Data in violation of RA 10173, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

The sog138 platform is strictly limited to individuals who are 21 years of age or older. sog138 does not knowingly collect Personal Data from individuals under the age of 21. The registration process includes an age declaration and is subject to KYC verification to confirm that each Player meets this minimum age requirement.

If sog138 discovers that it has inadvertently collected Personal Data from an individual who is under 21, that account will be immediately suspended, all associated data will be securely deleted, and any deposits will be returned to the payment source after verification. Any winnings accrued by an underage Player will be voided.

Individuals under 21, or parents and guardians who believe a minor has registered on sog138, should contact sog138 support immediately so that appropriate action can be taken without delay.

sog138 reviews this Privacy Policy periodically and updates it as required to reflect changes in applicable law, regulatory guidance, or platform operations. Where a revision is material — meaning it changes the basis on which we process your Personal Data or affects your rights as a data subject — sog138 will notify registered Players via email to their registered address and/or through a notification displayed on login.

The effective date at the top of this document indicates when the current version came into force. Your continued use of the sog138 platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the revised document.

The current version of this Privacy Policy is always accessible at sog138.cam/privacy-policy. If you have questions about any change to this Policy, please contact our Data Protection Officer before continuing to use the platform.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by sog138, please contact the sog138 Data Protection Officer through the following channels:

• Live Chat: Available 24/7 directly on the sog138 platform — select "Privacy / Data Request" from the support menu. Average response time under two (2) minutes.
• Email: [email protected] — please include "Privacy Policy Request" in your subject line. Responses within six (6) hours during standard business hours.

When submitting a data subject rights request, please include your registered email address, the nature of your request, and sufficient information to allow us to verify your identity. Requests that cannot be verified may not be actioned for security reasons.

If you are not satisfied with sog138's response to your privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines through their official complaints process.