skinape Privacy Policy

1. Introduction

skinape ("we," "us," or "our") is committed to protecting the privacy and personal data of every individual who uses the skinape Casino platform accessible at skinape.org (the "Platform"). This Privacy Policy describes how skinape collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform.

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC"). It should be read together with the skinape Terms & Conditions, which are incorporated herein by reference.

By registering an Account on skinape or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2. Data Controller

skinape is the data controller responsible for the personal data collected through the Platform. As data controller, skinape determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data privacy laws.

If you have any questions or concerns about how skinape handles your personal data, or if you wish to exercise any of your data subject rights, please contact our Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

skinape collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Registration & Identity Data

• Full legal name
• Date of birth (for age verification — must be 21 years or older)
• Email address and mobile number
• Username and encrypted password
• Nationality and country of residence

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine passport, PhilSys ID, SSS ID, driver's licence)
• Proof of address (e.g., utility bill, bank statement)
• Proof of payment method ownership
• Selfie or live photo for biometric verification where required

3.3 Financial & Transaction Data

• Deposit and withdrawal amounts and dates
• Payment method details (GCash number, Maya account, bank account details)
• Transaction history and account balance records

3.4 Gaming Activity Data

• Games played, wager amounts, and game outcomes
• Session duration and login timestamps
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, self-exclusion status)

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Cookie identifiers and session tokens
• Platform interaction logs and error reports

3.6 Communications Data

• Records of communications with skinape customer support
• Feedback, survey responses, and complaint records
• Marketing communication preferences

4. How We Collect Your Data

skinape collects personal data through the following means:

• Directly from you — when you register an Account, complete KYC verification, make a deposit or withdrawal, contact support, or respond to a survey.
• Automatically — through cookies, web beacons, and server logs when you access and interact with the Platform.
• From third parties — including identity verification providers, payment processors, fraud prevention services, and PAGCOR where required for regulatory compliance.

5. How We Use Your Personal Data

skinape processes your personal data for the following purposes:

6. Legal Basis for Processing

skinape processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity — processing required to perform our obligations under the skinape Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation — processing required to comply with applicable Philippine laws and PAGCOR regulations, including KYC verification, AML reporting, and responsible gaming obligations.
• Legitimate interests — processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent — processing for optional purposes such as marketing communications, where you have provided explicit opt-in consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. 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 to the extent necessary for the stated purpose:

• Identity verification providers — to conduct KYC checks and age verification as required by PAGCOR regulations.
• Payment processors — including GCash, Maya, and Philippine banking partners, to process deposits and withdrawals.
• Fraud prevention and security services — to detect and prevent fraudulent activity, money laundering, and account abuse.
• Regulatory authorities — including PAGCOR and the Anti-Money Laundering Council (AMLC), where disclosure is required by law or regulatory order.
• IT and platform service providers — including cloud hosting, analytics, and customer support software providers, who process data on our behalf under strict data processing agreements.
• Professional advisers — including lawyers, auditors, and insurers, where necessary for the conduct of skinape's business.

All third-party service providers engaged by skinape are required to implement appropriate technical and organisational measures to protect your personal data and are prohibited from using your data for any purpose other than the specific service they provide to skinape.

8. Data Retention

skinape retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC data — retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and applicable AML laws.
• Transaction records — retained for a minimum of five (5) years from the date of each transaction.
• Gaming activity logs — retained for a minimum of three (3) years.
• Customer support records — retained for three (3) years from the date of the last interaction.
• Marketing consent records — retained until consent is withdrawn, plus one (1) year thereafter as evidence of consent.

Upon expiry of the applicable retention period, skinape will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9. Cookies & Tracking Technologies

skinape uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies may be set when you visit skinape.org:

• Strictly necessary cookies — essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Performance cookies — used to collect anonymised data about how visitors use the Platform, helping us identify and fix issues and improve user experience.
• Functional cookies — used to remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies — used to understand aggregate usage patterns on the Platform. Data collected is anonymised and not linked to individual accounts.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the skinape Platform.

10. Data Security

skinape implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the skinape Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Two-factor authentication options for player accounts;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

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 NPC and affected data subjects in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular 16-03.

While skinape takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your skinape Account credentials.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by skinape:

• Right to be informed — the right to know how your personal data is being collected and processed, as set out in 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, subject to skinape's legal retention obligations.
• Right to object — the right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability — the right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint — the right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact skinape's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." skinape will respond to all verified requests within thirty (30) days in accordance with NPC guidelines.

12. Children's Privacy

The skinape Platform is strictly intended for individuals who are at least twenty-one (21) years of age. skinape does not knowingly collect personal data from persons under 21 years of age. If skinape becomes aware that personal data has been collected from a person under 21, that data will be immediately deleted and the associated Account closed.

If you believe that a minor has registered an Account on skinape, please contact us immediately at [email protected] so that we can take appropriate action.

13. Third-Party Links

The skinape Platform may contain links to third-party websites or services for informational purposes. skinape is not responsible for the privacy practices or content of any third-party website. We encourage you to review the privacy policy of any third-party site you visit. This Privacy Policy applies solely to data collected through the skinape Platform.

14. Updates 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. The date of the most recent revision is displayed at the top of this document.

Where changes are material, skinape will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect. Your continued use of the skinape Platform following notification of any amendment constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how skinape protects your personal data.

15. Contact Us & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way skinape handles your personal data, please contact our Data Protection Officer:

Email: [email protected] (subject line: "Data Privacy Request")

Live Chat: Available through the skinape Platform after logging in to your Account.

If you are not satisfied with skinape's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about how to file a complaint with the NPC is available through official NPC channels.