nustabet Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by nustabet ("nustabet," "we," "us," or "our") and applies to all personal information collected from individuals ("you," "Player," or "User") who access or use the nustabet website, mobile platform, games, and associated services (collectively, the "Platform").

nustabet is committed to protecting the privacy and personal data of all users in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). This Policy describes what personal data we collect, why we collect it, how we use and protect it, and what rights you have in relation to your data.

This Policy should be read together with our Terms & Conditions, which govern your use of the nustabet Platform. By registering an account 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. Information We Collect

nustabet collects personal data through various means, including directly from you during registration and account use, automatically through your interaction with the Platform, and from third-party sources where permitted by law. The categories of personal data we collect include:

2.1 Information You Provide Directly

• Registration Data: Full name, date of birth, gender, nationality, residential address, email address, and mobile number provided when creating your nustabet account.
• Identity Verification (KYC) Documents: Government-issued identification (e.g., PhilSys ID, passport, driver's license, UMID, SSS ID, voter's ID), proof of address, and selfie photographs submitted for account verification purposes.
• Financial Information: Payment method details (e.g., GCash account number, Maya account, bank account details) used for deposits and withdrawals. Note: nustabet does not store full payment card numbers on its servers.
• Communications: Messages, queries, and feedback submitted to nustabet via live chat, email, or any other support channel.

2.2 Information Collected Automatically

• Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and unique device identifiers.
• Usage Data: Pages visited, games played, session duration, click patterns, search queries within the Platform, and referring URLs.
• Transaction Data: Records of all deposits, withdrawals, bets placed, game results, and bonus activity on your nustabet account.
• Location Data: General geographic location derived from your IP address, used to verify eligibility and comply with jurisdictional restrictions.

2.3 Information from Third Parties

• Identity verification and fraud prevention service providers used to validate KYC documents.
• Payment processors and e-wallet providers (GCash, Maya, partner banks) for transaction verification purposes.
• Regulatory authorities, including PAGCOR, where disclosure is required by law.

3. How We Use Your Information

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

4. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform our obligations under the nustabet Terms & Conditions, including account management, game provision, and payment processing.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions and Anti-Money Laundering Act (AMLA) requirements.
• Legitimate Interests: Processing is necessary for nustabet's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights.
• Consent: For certain processing activities — such as sending promotional communications — nustabet relies on your explicit consent, which you may withdraw at any time.

5. Sharing of Personal Data

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

• Service Providers: Third-party vendors who assist nustabet in operating the Platform, including payment processors (GCash, Maya, partner banks), identity verification providers, IT infrastructure providers, and customer support platform operators. These providers are contractually bound to process your data only on nustabet's instructions and in accordance with applicable data protection laws.
• Regulatory and Law Enforcement Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other government bodies where disclosure is required by Philippine law or a valid legal order.
• Fraud Prevention and Security Partners: Third-party fraud detection and cybersecurity services engaged to protect the integrity of the nustabet Platform and its players.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of nustabet's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

6. Cookies and Tracking Technologies

nustabet uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the Platform, analyse usage patterns, and support security functions. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including maintaining your nustabet Login session and enabling secure transactions. These cannot be disabled.
• Performance and Analytics Cookies: Used to collect anonymised data about how players interact with the nustabet Platform, helping us identify areas for improvement.
• Functional Cookies: Allow the Platform to remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Security Cookies: Used to detect and prevent fraudulent activity, protect against unauthorised access, and support our responsible gaming monitoring systems.

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 nustabet Platform. For more information on managing cookies, refer to your browser's help documentation.

7. Data Retention

nustabet retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active nustabet account, and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by Philippine anti-money laundering regulations.
• KYC Documents: Identity verification documents are retained for the period required by PAGCOR and AMLC regulations, typically five (5) years from the end of the business relationship.
• Communications and Support Records: Customer support interactions are retained for up to three (3) years from the date of the last interaction.
• Usage and Technical Data: Anonymised or aggregated usage data may be retained indefinitely for analytical and platform improvement purposes.

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

8. Data Security

nustabet implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and the nustabet Platform is encrypted using industry-standard Secure Socket Layer (SSL) / Transport Layer Security (TLS) protocols.
• Access Controls: Access to personal data is restricted to authorised nustabet personnel and service providers on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Secure Data Storage: Personal data is stored on secure servers with physical and logical access controls, regular security patching, and intrusion detection systems.
• Regular Security Audits: nustabet conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities in the Platform.
• Staff Training: All nustabet personnel with access to personal data receive regular training on data protection obligations and security best practices.

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 nustabet:

• Right to Be Informed: You have the right to be informed about how nustabet collects and processes your personal data, as set out in this Privacy Policy.
• Right of Access: You may request a copy of the personal data nustabet 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 held by nustabet. You may update certain account details directly through your nustabet 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, subject to nustabet's legal and regulatory 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 nustabet's legitimate interests.
• Right to Data Portability: You may request that nustabet provide your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: If you believe nustabet has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact nustabet's Data Privacy Officer using the contact details provided in Section 13 of this Policy. nustabet will respond to all verified data subject requests within fifteen (15) business days, in accordance with NPC guidelines.

10. Children and Minors

The nustabet Platform is strictly intended for individuals aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. nustabet does not knowingly collect personal data from individuals under the age of 21.

If nustabet 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 nustabet Platform, please contact our support team immediately so that we can investigate and take appropriate action.

11. Cross-Border Data Transfers

In the course of providing its services, nustabet may transfer your personal data to service providers or infrastructure partners located outside the Philippines. Where such transfers occur, nustabet ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under Philippine law.
• Transfers only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission.
• Implementation of additional technical and organisational security measures where required.

By using the nustabet Platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the delivery of our services, subject to the safeguards described above.

12. Changes to This Policy

nustabet 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, nustabet will notify registered players via email or an in-platform notification prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the nustabet Platform following any update to this Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed about how nustabet protects your personal data.

13. Contact Our Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by nustabet, please contact our designated Data Privacy Officer (DPO):

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through its official government channels.