Privacy Policy – How nugame Protects Your Personal Data

nugame, accessible at nugame.cam, is an online gaming platform operated under PAGCOR license guidelines and serving Filipino players across the Philippines. For the purposes of this Privacy Policy, the entity operating nugame acts as the Data Controller responsible for the personal information collected from and processed in relation to registered players and platform visitors.

As Data Controller, nugame determines the purposes and means of processing your personal data. We are bound by the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines, in addition to any applicable PAGCOR data handling requirements.

For any privacy-related inquiries, including requests to exercise your data subject rights, you may contact our Data Protection Officer through the official support email: [email protected]

nugame collects personal data necessary to provide platform services, comply with legal and regulatory obligations, and maintain the security and integrity of the platform. The categories of personal data we may collect include the following:

nugame collects personal data through the following channels:

• Direct Submission: Information you provide when registering your nugame account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated Technical Collection: Data collected automatically when you access the nugame platform, including IP addresses, device identifiers, session durations, page interaction patterns, and browser specifications. This collection occurs through standard server logs, cookies, and similar technologies described in Section 6.
• Payment Processors: Transaction reference data received from payment partners such as GCash, PayMaya (Maya), and Philippine banks when you initiate a deposit or withdrawal. nugame does not receive or store full payment instrument credentials.
• Third-Party Verification Services: Data received from identity verification and anti-money laundering screening services engaged by nugame for regulatory compliance purposes.
• Regulatory Sources: Data or directives received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine government agencies in connection with lawful regulatory processes.

nugame processes your personal data only for specific, legitimate purposes and on a recognized legal basis under the Data Privacy Act of 2012. The primary purposes for which we process personal data are:

• Account Registration and Management: To create, verify, and maintain your nugame player account, including age verification to confirm you are 21 years of age or older as required by PAGCOR regulations. Legal basis: performance of contract; legal obligation.
• Payment Processing: To facilitate deposits and withdrawals in Philippine Peso through GCash, PayMaya, and Philippine bank channels, and to maintain accurate transaction records. Legal basis: performance of contract; legal obligation.
• Regulatory Compliance: To fulfill nugame's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), Know Your Customer (KYC) requirements, and other applicable Philippine laws. Legal basis: legal obligation; legitimate interest.
• Platform Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct. Legal basis: legitimate interest; legal obligation.
• Responsible Gaming: To monitor gameplay patterns for indicators of problem gambling behavior, enforce player-set responsible gaming limits, and comply with PAGCOR's responsible gaming directives. Legal basis: legitimate interest; legal obligation.
• Customer Support: To respond to your inquiries, resolve complaints, and manage disputes in connection with your nugame account. Legal basis: performance of contract; legitimate interest.
• Service Improvement: To analyze aggregated platform usage data for the purpose of improving game performance, user experience, and platform reliability. Legal basis: legitimate interest.
• Marketing Communications (where consented): To send promotional offers, bonus announcements, and platform updates to players who have provided explicit consent to receive such communications. You may withdraw this consent at any time. Legal basis: consent.

nugame does not sell, rent, or trade your personal data to third parties for marketing or commercial purposes. We may share your personal data only in the following limited circumstances:

• Regulatory and Government Authorities: nugame is legally required to share certain player information with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies when compelled by law, court order, or regulatory directive. We have no discretion to refuse such disclosures where legally mandated.
• Payment Service Providers: Transaction data necessary to process your deposits and withdrawals is shared with your chosen payment provider — such as GCash, PayMaya, BPI, BDO, or Metrobank. These providers operate under their own privacy policies and are independently regulated.
• Identity Verification and KYC Providers: We engage third-party identity verification services to assist in meeting KYC compliance requirements. These providers receive only the data necessary to perform the specific verification task and are bound by contractual data protection obligations.
• Technology and Infrastructure Providers: nugame uses reputable third-party cloud infrastructure, game software providers, and platform technology partners to deliver the service. These providers process data only on our instructions and under data processing agreements that impose appropriate security and confidentiality obligations.
• Fraud Prevention and Security Services: Certain data may be shared with anti-fraud services to detect and prevent unauthorized activity, money laundering, and other security threats affecting the platform.

In all cases where data is shared with third-party processors, nugame ensures that appropriate contractual safeguards are in place, consistent with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

nugame uses cookies and similar tracking technologies to support the technical operation of the platform, maintain your login session, and gather aggregated usage analytics. The types of cookies we use include:

• Strictly Necessary Cookies: Required for core platform functions including login session management, security token validation, and payment flow integrity. These cannot be disabled without preventing core platform functionality.
• Functional Cookies: Used to remember your platform preferences, such as language settings and responsible gaming limit configurations, across sessions.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players interact with the nugame platform — page visit frequency, session duration, feature usage — to help us identify performance issues and improve user experience. Individual players are not identifiable from analytics data.

You may control non-essential cookie categories through your browser settings. Please note that disabling certain cookies may affect the functionality of the nugame platform. Strictly necessary cookies cannot be rejected without preventing your ability to use the service.

nugame retains personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following retention guidelines:

• Active Account Data: Retained for the duration of the active account relationship plus a minimum of five (5) years following account closure, as required by anti-money laundering regulations applicable to gaming operators in the Philippines.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of collection or the date of account closure, whichever is later, in compliance with AMLA and PAGCOR requirements.
• Transaction Records: Financial transaction histories are retained for a minimum of five (5) years from the date of the transaction, consistent with Philippine financial record-keeping requirements.
• Customer Support Correspondence: Retained for three (3) years from the date of the interaction, or longer where the correspondence relates to an ongoing dispute or regulatory inquiry.
• Technical Logs: Server access logs and security event logs are retained for a minimum of twelve (12) months for security audit and fraud investigation purposes.
• Marketing Preferences: Records of your consent to or opt-out from marketing communications are retained for the duration of the account relationship plus a reasonable period to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is either securely deleted or anonymized in a manner that prevents re-identification of the individual player.

nugame implements a range of technical and organizational security measures to protect the personal data of Filipino players against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the nugame platform is encrypted using the same standard applied by Philippine commercial banks.
• Encrypted Data Storage: Sensitive personal data stored in nugame systems is encrypted at rest using industry-standard encryption protocols.
• Two-Factor Authentication (2FA): Available and recommended for all players, adding a critical second layer of account protection via SMS OTP to your registered Philippine mobile number.
• Access Controls: Internal access to personal player data is restricted on a need-to-know basis. Staff with access to player data are subject to confidentiality obligations and periodic security training.
• Security Monitoring: nugame operates continuous monitoring of its platform infrastructure to detect unusual access patterns, intrusion attempts, and other security events.
• Regular Security Reviews: The platform undergoes periodic security assessments to identify and remediate potential vulnerabilities in line with industry best practices.

Despite these measures, no internet-based system can guarantee absolute security. In the event of a data breach that creates a likely risk of harm to affected players, nugame will notify affected individuals and the National Privacy Commission within the timeframes required by Philippine law.

Under the Data Privacy Act of 2012, registered players on nugame have the following rights with respect to their personal data:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy serves as nugame's primary means of fulfilling this obligation.
• Right of Access: You may request a copy of the personal data nugame holds about you, along with information about the purposes for which it is processed.
• Right to Rectification: If any of the personal data nugame holds about you is inaccurate or incomplete, you have the right to request correction. You may update certain account details directly through your nugame account settings.
• Right to Erasure (Right to be Forgotten): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent upon which processing is based — subject to overriding legal and regulatory retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for marketing purposes at any time. You may also object to processing based on legitimate interests, though this right is subject to nugame's overriding legitimate grounds.
• Right to Data Portability: Where technically feasible, you may request that nugame provide your personal data in a structured, commonly used format.
• Right to Complain: If you believe nugame has processed your personal data in violation of the Data Privacy Act of 2012, you have the right to file a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with a clear description of your request and sufficient information to verify your identity. nugame will respond to data subject rights requests within thirty (30) days of receipt, consistent with NPC guidelines.

nugame does not knowingly collect personal data from individuals under the age of 21. The platform is strictly restricted to persons who are twenty-one (21) years of age or older, consistent with PAGCOR regulations governing online gaming in the Philippines.

Age verification is performed during the account registration process and through KYC document checks. If nugame discovers or is informed that personal data has been collected from an individual under 21, the affected account will be suspended immediately, the personal data will be deleted to the extent permitted by regulatory obligations, and any balance will be handled in accordance with applicable regulations.

Parents and guardians who believe a minor may have accessed the nugame platform are encouraged to contact our support team immediately at [email protected].

The nugame platform may incorporate game content, payment widgets, or technology components provided by third-party service providers. Where such components involve the processing of player data, nugame engages those providers under contractual data processing agreements that require them to maintain appropriate data security and privacy standards.

nugame is not responsible for the privacy practices of third-party payment providers such as GCash or PayMaya, or of the banks (BPI, BDO, Metrobank) through which transactions are processed. Players are encouraged to review the privacy policies of their payment providers independently.

The nugame platform does not contain hyperlinks to external websites for browsing purposes. All navigation remains within the nugame domain, consistent with our site-wide link policy.

nugame may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR requirements, or technology. Material changes to this policy will be communicated to registered players via email notification to the address on record and/or a prominent notice on the platform, providing reasonable advance notice before the revised policy takes effect.

Where changes are required to comply with an urgent legal or regulatory obligation, they may take effect immediately. The date at the top of this policy will always reflect the most recent revision.

Continued use of the nugame platform after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with a revised policy, you should cease using the platform and may request account closure in accordance with the Terms and Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or nugame's processing of your personal data, you may contact our Data Protection Officer through the following official channel:

Email (plain text — not a clickable link): [email protected]

Please include "Privacy Request" in your subject line and provide sufficient detail about your inquiry or request to allow us to respond effectively. We will acknowledge all privacy inquiries within five (5) business days and provide a substantive response within thirty (30) days, consistent with National Privacy Commission guidelines.

For complaints that cannot be resolved through our internal process, you have the right to escalate the matter to the National Privacy Commission of the Philippines. Information about the NPC complaints process is available through official Philippine government channels.