nunstar Privacy Policy

1 Introduction

nunstar ("nunstar," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the nunstar online gaming platform (the "Platform"). This Privacy Policy describes how nunstar collects, uses, stores, shares, and protects personal information in connection with your use of the Platform, including all games, services, features, and functionality made available through the nunstar website and any associated mobile-optimized interfaces.

This Privacy Policy applies to all registered players, visitors, and any other individuals whose personal data nunstar processes in connection with the operation of the Platform. It should be read together with nunstar's Terms and Conditions and Responsible Gaming Policy, both of which are incorporated herein by reference.

By accessing the nunstar Platform, creating an account, or otherwise providing your personal information to nunstar, 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. If you do not agree with any part of this Privacy Policy, you should discontinue your use of the Platform immediately.

2 Data We Collect

nunstar collects personal data that is necessary for the operation of the Platform, the provision of gaming services, compliance with legal obligations, and the improvement of the player experience. The categories of personal data nunstar may collect include, but are not limited to, the following:

3 How We Collect Data

nunstar collects personal data through a variety of means, both directly from you and automatically through your use of the Platform. The primary methods of data collection include:

• Account Registration: When you create a nunstar account, you provide identity and contact data directly through the registration form.
• KYC Verification: When you submit identity documents for account verification, nunstar collects copies of government-issued IDs, proof of address, and payment method documentation.
• Deposits and Withdrawals: Financial data is collected when you initiate transactions through supported payment channels including GCash, PayMaya, BPI, BDO, and Metrobank.
• Platform Usage: Technical and gaming data is collected automatically as you navigate and interact with the nunstar Platform, including through cookies, log files, and session tracking technologies.
• Customer Support: Communications data is collected when you contact nunstar's support team via live chat, email, or any other support channel.
• Promotions and Surveys: If you participate in nunstar promotions, competitions, or feedback surveys, additional data may be collected as part of those activities.
• Third-Party Sources: nunstar may receive data about you from third-party identity verification providers, payment processors, and fraud prevention services, where permitted by applicable law.

4 How We Use Your Data

nunstar uses the personal data it collects for specific, legitimate purposes directly related to the operation of the Platform and the provision of gaming services to Filipino players. nunstar does not use your personal data for any purpose that is incompatible with the purposes described in this Privacy Policy without your prior consent.

• Account Management: To create, maintain, and manage your nunstar player account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to nunstar's games, process your deposits and withdrawals in Philippine Peso (₱), and deliver the gaming services you have requested.
• Legal Compliance: To comply with applicable Philippine laws and regulations, including the Data Privacy Act of 2012, Anti-Money Laundering Act, and PAGCOR regulatory requirements, including KYC and AML obligations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal or prohibited conduct on the Platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce responsible gaming tools such as deposit limits and self-exclusion, and fulfill nunstar's duty of care to players.
• Customer Support: To respond to your inquiries, resolve disputes, process complaints, and provide technical assistance through nunstar's support channels.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the performance, features, and user experience of the nunstar Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and other marketing communications where you have provided your consent to receive such communications. You may withdraw your consent at any time.
• Legal Claims: To establish, exercise, or defend legal claims in connection with your use of the nunstar Platform.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, nunstar processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and nunstar, including the provision of gaming services, account management, and the processing of financial transactions.
• Legal Obligation: Processing is necessary for nunstar to comply with its legal obligations under Philippine law, including KYC requirements, AML obligations, and PAGCOR regulatory requirements.
• Legitimate Interests: Processing is necessary for nunstar's legitimate interests in operating a secure, fair, and commercially viable gaming platform, including fraud prevention, platform security, and business analytics, provided that such interests are not overridden by your rights and interests.
• Consent: For certain processing activities, such as the sending of marketing communications and the use of non-essential cookies, nunstar relies on your freely given, specific, informed, and unambiguous consent. You have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

nunstar does not sell your personal data to third parties for their own marketing purposes. nunstar may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: nunstar shares financial data with payment service providers, including GCash, PayMaya, BPI, BDO, and Metrobank, to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• Identity Verification Providers: nunstar engages third-party KYC and identity verification service providers to assist in verifying player identities and complying with AML obligations.
• Regulatory Authorities: nunstar may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine regulatory and law enforcement authorities where required by law or where nunstar has a good-faith belief that disclosure is necessary to comply with a legal obligation.
• Fraud Prevention Services: nunstar may share technical and identity data with fraud detection and prevention service providers to protect the integrity of the Platform and its players.
• IT and Infrastructure Providers: nunstar engages third-party technology providers for hosting, data storage, and platform infrastructure. These providers process data on nunstar's behalf and are contractually bound to maintain appropriate security standards.
• Professional Advisors: nunstar may share data with its legal, financial, and compliance advisors where necessary for the conduct of nunstar's business operations or the defense of legal claims.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of nunstar's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

All third parties with whom nunstar shares personal data are required to process such data in accordance with applicable data protection laws and nunstar's data processing requirements. nunstar does not permit third-party recipients to use your personal data for their own independent purposes without your consent.

7 Cookies & Tracking Technologies

nunstar uses cookies and similar tracking technologies to operate and improve the Platform, personalize your experience, and analyze usage patterns. A cookie is a small text file placed on your device when you visit the nunstar Platform. Cookies allow nunstar to recognize your device on subsequent visits and remember your preferences and session information.

You may manage your cookie preferences through your browser settings. Please note that disabling essential or security cookies may impair the functionality of the nunstar Platform and prevent you from accessing certain features. For optional cookies, you may withdraw your consent at any time through your nunstar account settings.

8 Data Retention

nunstar retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The specific retention periods applicable to different categories of personal data are determined by reference to the nature of the data, the purpose for which it is processed, and nunstar's legal obligations.

• Account Data: Retained for the duration of your active account and for a period of five (5) years following account closure, in accordance with Philippine AML record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC Documentation: Retained for a minimum of five (5) years following the end of the business relationship, or longer where required by applicable law.
• Gaming History: Retained for a period of three (3) years from the date of each gaming session, unless a longer retention period is required for dispute resolution or regulatory purposes.
• Support Communications: Retained for a period of two (2) years from the date of the last communication, unless the matter relates to an ongoing dispute or legal claim.
• Marketing Data: Retained until you withdraw your consent to marketing communications or for a period of two (2) years from your last interaction with nunstar's marketing communications, whichever is earlier.

Upon expiry of the applicable retention period, nunstar will securely delete or anonymize your personal data in accordance with its data disposal procedures. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for analytical purposes, as it no longer constitutes personal data.

9 Data Security

nunstar takes the security of your personal data seriously and implements a comprehensive set of technical and organizational measures designed to protect your data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• 256-bit SSL Encryption: All data transmitted between your device and the nunstar Platform is encrypted using industry-standard 256-bit Secure Sockets Layer (SSL) technology, the same standard used by Philippine banks and financial institutions.
• Access Controls: Access to personal data within nunstar's systems is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Secure Data Storage: Personal data is stored on secure servers with appropriate physical and logical access controls, firewalls, and intrusion detection systems.
• Regular Security Audits: nunstar conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in its systems and infrastructure.
• Incident Response: nunstar maintains a data breach response plan and will notify affected players and the National Privacy Commission (NPC) in the event of a personal data breach, in accordance with the requirements of the Data Privacy Act of 2012.
• Staff Training: All nunstar personnel who handle personal data receive regular training on data protection obligations and security best practices.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by nunstar. nunstar is committed to facilitating the exercise of these rights promptly and without undue burden:

• Right to Be Informed: You have the right to be informed about how nunstar collects, uses, and processes your personal data, as set out in this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data nunstar holds about you, together with information about how that data is being processed.
• Right to Rectification: You have the right to request the correction of any inaccurate or incomplete personal data nunstar holds about you. You may update certain account information directly through your nunstar account settings.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to nunstar's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on nunstar's legitimate interests.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that nunstar transmit that data to another data controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that nunstar has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact nunstar's Data Protection Officer using the contact details provided in Section 14 of this Privacy Policy. nunstar will respond to all data subject requests within thirty (30) days of receipt, or within such other period as may be required by applicable law.

11 Children's Privacy

The nunstar Platform is strictly intended for adults aged twenty-one (21) years and above. nunstar does not knowingly collect, process, or retain personal data from individuals under the age of 21. The 21+ age requirement is enforced at registration through age verification procedures conducted in accordance with PAGCOR guidelines.

If nunstar becomes aware that it has inadvertently collected personal data from an individual under the age of 21, it will take immediate steps to delete such data and close the associated account. If you are a parent or guardian and believe that your child has registered on the nunstar Platform, please contact our support team immediately so that we can take appropriate action.

12 Third-Party Links

The nunstar Platform may contain references to third-party services, such as payment providers and identity verification services, that are necessary for the operation of the Platform. nunstar is not responsible for the privacy practices of any third-party service providers, and this Privacy Policy does not apply to the data processing activities of such third parties.

nunstar encourages you to review the privacy policies of any third-party service providers whose services you use in connection with the nunstar Platform, including your chosen payment provider (such as GCash, PayMaya, BPI, BDO, or Metrobank), to understand how they collect and process your personal data.

nunstar selects third-party service providers with care and requires all providers who process personal data on nunstar's behalf to maintain appropriate data protection standards consistent with the requirements of the Data Privacy Act of 2012.

13 Changes to This Policy

nunstar reserves the right to update or amend this Privacy Policy at any time to reflect changes in its data processing practices, applicable law, or regulatory requirements. The revised Privacy Policy will be published on the nunstar Platform with an updated effective date. Where changes are material, nunstar will provide reasonable advance notice to registered players via email or through a prominent notice on the Platform.

Your continued use of the nunstar Platform following the publication of any amendment to this Privacy Policy constitutes your acknowledgment of the revised Policy. If you do not agree with the amended Privacy Policy, you should discontinue your use of the Platform and may request the closure of your account in accordance with nunstar's account closure procedures.

nunstar maintains an archive of previous versions of this Privacy Policy, which are available upon written request to nunstar's Data Protection Officer.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or nunstar's data processing practices, please contact nunstar's Data Protection Officer. nunstar is committed to addressing all privacy-related inquiries promptly and transparently.

You may also contact nunstar's support team via live chat on the Platform, available 24 hours a day, seven days a week. For data subject requests, including requests for access, rectification, or erasure of personal data, please contact the Data Protection Officer directly using the details below.

If you are not satisfied with nunstar's response to your privacy inquiry or data subject request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for administering and implementing the Data Privacy Act of 2012 in the Philippines.