nustagame Privacy Policy

1 Introduction

nustagame ("nustagame," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the nustagame platform located at nustagame.org (the "Platform"). This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you access or use our services.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Republic of the Philippines, and its Implementing Rules and Regulations, as well as the guidelines issued by the National Privacy Commission (NPC). By registering an account or using the nustagame 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 Personal Data We Collect

nustagame collects personal data that you provide directly to us, as well as data collected automatically when you use the Platform. The categories of personal data we collect include:

Data You Provide Directly:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification numbers (e.g., passport number, driver's license number, PhilSys ID number, SSS number, UMID number).
• Contact Data: Philippine mobile number, email address, and residential address (including city, province, and postal code).
• Account Data: Username, password (stored in hashed form), security questions and answers, and account preferences.
• Financial Data: GCash mobile number, PayMaya account details, bank account information (BPI, BDO, Metrobank, UnionBank), and partial payment card details as required for transaction processing. Full card numbers are never stored by nustagame.
• Verification Documents: Copies of government-issued IDs, selfies, and proof of address documents submitted during the Know Your Customer (KYC) verification process.
• Communications Data: Records of your communications with nustagame's customer support team, including live chat transcripts and support ticket content.

Data Collected Automatically:

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, session duration, betting history, deposit and withdrawal history, and clickstream data.
• Location Data: General geographic location derived from your IP address. nustagame does not collect precise GPS location data.
• Cookie Data: Data collected through cookies and similar tracking technologies as described in Section 6 of this Policy.

3 How We Use Your Personal Data

nustagame uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your nustagame player account, including processing your registration, verifying your identity, and enabling you to log in securely.
• Service Delivery: To provide you with access to nustagame's games, sports betting, live casino, bingo, and all other Platform features.
• Transaction Processing: To process deposits, withdrawals, and other financial transactions via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Identity Verification (KYC): To verify your identity and age (21+) in compliance with Philippine gaming regulations and anti-money laundering requirements.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support team.
• Legal and Regulatory Compliance: To comply with applicable Philippine laws, including the Data Privacy Act, anti-money laundering regulations, and PAGCOR requirements.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible Gaming: To monitor gaming activity and enforce responsible gaming tools such as deposit limits, session reminders, and self-exclusion requests.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the nustagame Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may opt out at any time.

4 Legal Basis for Processing

nustagame processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and nustagame (i.e., the Terms & Conditions), including account creation, game access, and payment processing.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including KYC obligations, anti-money laundering reporting requirements, and regulatory directives.
• Legitimate Interests: Processing is necessary for nustagame's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities, such as marketing communications and the use of non-essential cookies, nustagame relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 Data Sharing and Disclosure

nustagame does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, Visa, Mastercard, and other payment processors, solely for the purpose of processing your financial transactions.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to assist with identity verification and fraud prevention.
• Game Software Providers: Licensed game developers and content providers whose games are available on the nustagame Platform, to the extent necessary for game functionality and fairness auditing.
• IT and Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers engaged to support the operation and security of the Platform.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulatory directive.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a valid legal process, court order, or to protect the rights, property, or safety of nustagame, its players, or the public.

All third-party service providers engaged by nustagame are contractually required to process personal data only in accordance with nustagame's instructions and to implement appropriate technical and organizational security measures.

6 Cookies and Tracking Technologies

nustagame uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that help detect fraudulent activity. These cookies cannot be disabled.
• Performance and Analytics Cookies: Used to collect anonymized data about how players use the Platform, which pages are visited most frequently, and where errors occur. This data helps nustagame improve the Platform.
• Functionality Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Marketing Cookies: Used to deliver relevant promotional content and to measure the effectiveness of nustagame's marketing campaigns. These cookies are only placed with your consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the nustagame Platform.

7 Data Retention

nustagame retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account data and transaction records are retained for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering regulations.
• KYC verification documents are retained for a minimum of five (5) years following the end of the business relationship, as required by the Anti-Money Laundering Act.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Marketing consent records are retained for the duration of your account and for two (2) years following account closure.
• Cookie and analytics data is retained for a maximum of thirteen (13) months from the date of collection.

When personal data is no longer required for any lawful purpose, nustagame will securely delete or anonymize it in accordance with our data disposal procedures.

8 Data Security

nustagame implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the nustagame Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Strict access controls ensuring that only authorized nustagame personnel can access personal data, on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform's infrastructure.
• Multi-factor authentication options for player accounts to reduce the risk of unauthorized access.
• A documented data breach response procedure, including notification to the National Privacy Commission and affected players within the timeframes required by Philippine law.

9 Your Rights as a Data Subject

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

• Right to Be Informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data nustagame holds about you, along with information about how it is being used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have 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 nustagame's legal retention obligations.
• Right to Object: You have the right to 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, subject to applicable legal exceptions.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that nustagame has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact the nustagame Data Protection Officer using the contact details provided in Section 12 of this Policy. nustagame will respond to all verified requests within thirty (30) days, as required by Philippine law.

10 Children's Privacy

The nustagame Platform is strictly intended for individuals who are at least 21 years of age, as required under Philippine law governing online casino-style gaming. nustagame does not knowingly collect personal data from individuals under the age of 21.

If nustagame becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the nustagame Platform, please contact our support team immediately.

11 Updates to This Privacy Policy

nustagame 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. When material changes are made, nustagame will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. Your continued use of the nustagame Platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy.

12 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or nustagame's data processing practices, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with nustagame's response to your privacy concern.