nunstargame Privacy Policy

1. Who We Are

nunstargame is an online gaming platform operating under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR). nunstargame is the data controller responsible for the personal information of its registered Players and website visitors. nunstargame has appointed a Data Protection Officer (DPO) in compliance with the requirements of the National Privacy Commission (NPC) of the Philippines.

All data processing activities conducted by nunstargame are subject to Republic Act No. 10173, known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as well as relevant PAGCOR licensing conditions relating to player data protection.

2. Personal Data We Collect

nunstargame collects the following categories of personal data from Players:

2.1 Identity and Contact Data

• Full legal name as it appears on a valid Philippine government-issued ID
• Date of birth (for 21+ age verification purposes)
• Registered Philippine mobile number
• Email address
• Residential address in the Philippines

2.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine ID (PhilSys National ID, Passport, Driver's License, Voter's ID, UMID, etc.)
• Selfie photographs submitted for facial verification
• Source of funds declarations where required by PAGCOR AML rules

2.3 Financial Data

• GCash or Maya mobile wallet numbers (tokenized — full credentials are never stored by nunstargame)
• Philippine bank account details (BPI, BDO, Metrobank, etc.) where provided for withdrawal purposes
• Transaction history including deposits, withdrawals, and betting records in Philippine Peso (PHP)

2.4 Gaming and Usage Data

• Game session records including bets placed, outcomes, and session durations
• Login history including timestamps and IP addresses
• Device type, operating system, browser, and screen resolution
• Geolocation data (city-level) used to verify your access from the Philippines

2.5 Communications Data

• Support chat transcripts and email correspondence
• Responses to responsible gaming surveys or self-assessment tools
• Bonus opt-in preferences and marketing consent records

nunstargame does not collect sensitive personal information beyond what is strictly required for KYC compliance — specifically, we do not collect religious beliefs, political opinions, or health data outside of responsible gaming self-assessment contexts.

3. How We Collect Your Data

nunstargame collects personal data through the following channels:

• Registration: When you create a nunstargame account, you provide identity and contact data directly.
• KYC Verification: Documents and selfie photographs submitted during the identity verification process.
• Deposits and Withdrawals: Financial data is collected when you link a GCash, Maya, or bank account for payment purposes.
• Platform Usage: Technical and usage data is collected automatically while you browse and play on nunstargame.
• Support Interactions: Data you share when contacting nunstargame's support team via live chat or email.
• Third-Party Payment Providers: Payment confirmation data shared by GCash, Maya, and partner banks to verify transactions.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, nunstargame processes your personal data on the following lawful bases:

5. How We Use Your Personal Data

nunstargame uses the personal data collected for the following purposes:

• To verify your identity and age (21+) as required by PAGCOR before activating your account.
• To process your deposits and withdrawals in Philippine Peso via GCash, Maya, BPI, BDO, and other supported payment channels.
• To operate and maintain your nunstargame account, including balance management and transaction records.
• To detect and prevent fraud, account sharing, multiple account registration, and bonus abuse.
• To comply with PAGCOR's AML obligations and report suspicious transactions to the Anti-Money Laundering Council (AMLC) where legally required.
• To monitor gameplay patterns for responsible gaming indicators and intervene in accordance with PAGCOR's player protection framework.
• To send account-related notifications including deposit confirmations, withdrawal updates, and security alerts.
• To send promotional communications and bonus offers, where you have given consent. You may opt out at any time.
• To improve the Platform based on aggregated, anonymised usage analytics.
• To respond to and resolve your support queries.

6. Data Sharing & Disclosure

nunstargame does not sell, rent, or trade your personal data to any third party for commercial purposes. Your data may be shared in the following limited circumstances:

6.1 Regulatory and Legal Disclosure

nunstargame is legally required to share certain player data with PAGCOR as part of its licensing obligations, and with the Anti-Money Laundering Council (AMLC) when reporting suspicious transactions under Republic Act No. 9160. nunstargame will comply with valid court orders and lawful requests from Philippine law enforcement authorities.

6.2 Payment Service Providers

Transaction data is shared with GCash (G-Xchange Inc.), Maya (Voyager Innovations), and partner Philippine banks solely to facilitate the processing of deposits and withdrawals. These providers are bound by their own privacy policies and are regulated by the Bangko Sentral ng Pilipinas (BSP).

6.3 Game Software Providers

Game session data (anonymised player IDs, bet amounts, outcomes) may be shared with nunstargame's game software providers for RTP certification, fairness auditing, and technical support purposes. Providers are contractually prohibited from using this data for any independent marketing or commercial purpose.

6.4 Service Providers

nunstargame may engage third-party technology service providers (e.g., cloud hosting, fraud detection, email delivery) who process data on nunstargame's behalf under binding data processing agreements that require compliance with the Data Privacy Act.

7. Cookies & Tracking Technologies

nunstargame uses cookies and similar technologies on its website and platform for the following purposes:

• Essential Cookies: Required for core platform functionality — login session management, account authentication, and security tokens. These cannot be disabled without preventing use of the platform.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users navigate nunstargame, which pages are visited most, and where Players encounter issues. This data informs platform improvements.
• Preference Cookies: Store your language and display preferences to personalise your experience.

nunstargame does not use third-party advertising cookies or cross-site tracking cookies. You may manage cookie preferences through your browser settings, noting that disabling essential cookies will impact platform functionality.

8. Data Retention

nunstargame retains personal data for as long as necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods required by Philippine law and PAGCOR regulations:

• KYC and Identity Documents: Minimum 5 years from account closure, as required by PAGCOR and AMLC regulations.
• Transaction Records: Minimum 5 years from the date of the transaction, in accordance with the Anti-Money Laundering Act.
• Gaming Session Logs: Minimum 3 years from the session date, for dispute resolution and regulatory audit purposes.
• Support Communications: 2 years from the date of last interaction, unless retained longer in connection with a legal dispute.
• Marketing Consent Records: Until consent is withdrawn, plus a reasonable period thereafter for compliance documentation.

Upon expiry of applicable retention periods, nunstargame will securely delete or anonymise personal data.

9. Data Security

nunstargame implements the following technical and organisational security measures to protect your personal data:

• SSL/TLS Encryption: All data transmitted between your device and nunstargame's servers is encrypted using TLS 1.2 or higher.
• Encryption at Rest: Sensitive data stored on nunstargame's servers, including KYC documents and financial records, is encrypted at rest.
• Two-Factor Authentication (2FA): Players are strongly encouraged to enable 2FA on their accounts. 2FA is available via OTP to your registered Philippine mobile number.
• Access Controls: Access to player personal data within nunstargame's organisation is restricted on a need-to-know basis and subject to role-based access controls.
• Fraud Monitoring: nunstargame employs automated fraud detection systems that flag anomalous login patterns, unusual transaction activity, and potential account takeover attempts.
• Data Breach Response: In the event of a personal data breach, nunstargame will notify the National Privacy Commission (NPC) within 72 hours of becoming aware, and notify affected Data Subjects as required by the DPA.

While nunstargame takes all reasonable precautions, no online platform can guarantee absolute data security. Players are responsible for maintaining the confidentiality of their own account credentials.

10. 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 nunstargame:

• Right to Be Informed: The right to be told what personal data nunstargame collects, why, and how it is used — which this Policy fulfils.
• Right of Access: The right to request a copy of the personal data nunstargame holds about you.
• Right to Rectification: The right to correct inaccurate or incomplete personal data in your nunstargame account.
• Right to Erasure / "Right to be Forgotten": The right to request deletion of personal data in certain circumstances. Note that data required for regulatory compliance (KYC, AML) cannot be deleted during mandatory retention periods.
• Right to Object: The right to object to processing based on legitimate interest, including direct marketing communications.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) at privacy.gov.ph if you believe nunstargame has violated your data privacy rights.

To exercise any of the above rights, contact nunstargame's Data Protection Officer via the live chat or email channel listed in Section 14. nunstargame will respond to verified requests within 15 business days.

11. Children & Minors

nunstargame is strictly an adult platform. Access is limited to persons who are at least 21 years of age as required by PAGCOR. nunstargame does not knowingly collect personal data from individuals under 21 years of age. Age is verified during the KYC process using a valid Philippine government-issued ID.

If nunstargame becomes aware that personal data has been collected from a person under the age of 21, the account will be immediately suspended, the data will be deleted, and any deposits or winnings associated with the account will be handled in accordance with PAGCOR's underage gaming procedures.

12. Cross-Border Data Transfers

nunstargame primarily processes and stores player data within systems located in or accessible from the Philippines. Where data processing involves service providers located outside the Philippines (for example, cloud infrastructure providers), nunstargame ensures that adequate data protection safeguards are in place, including contractual clauses that require the receiving party to provide a level of protection equivalent to the Data Privacy Act of 2012.

nunstargame will not transfer your personal data to a foreign jurisdiction without appropriate safeguards and, where required, notification to or approval from the National Privacy Commission.

13. Changes to This Privacy Policy

nunstargame may update this Privacy Policy from time to time to reflect changes in our data processing practices, new legal requirements, or platform updates. Material changes will be communicated to registered Players via the mobile number or email address on file, and/or by a notice on the nunstargame platform.

The updated Policy will take effect on the date indicated at the top of this page. We encourage you to review this Policy periodically. Continued use of nunstargame following the effective date of a revised Policy constitutes your acceptance of the changes.

14. Contact & Data Protection Officer

For privacy-related queries, data subject access requests, or to reach nunstargame's Data Protection Officer, please use the following contact channels:

• Live Chat: Available 24/7 directly on the nunstargame platform. Mention "Privacy" or "DPO Request" in your opening message.
• Email: support at nunstargame.win — Response within 12 hours for general support; DPO requests responded to within 15 business days.

For complaints that cannot be resolved through nunstargame's internal process, you may contact the National Privacy Commission of the Philippines through its official government website.