Privacy Policy — nunstar Philippine Online Casino

1.1 This Privacy Policy applies to all personal data processed by nunstar in connection with the operation of the online gaming platform accessible at nunstar.win, including all associated mobile-optimized interfaces, customer support channels, and promotional communications.

1.2 This policy applies to all registered players, prospective players who browse the platform without completing registration, and any individuals who contact nunstar's customer support team.

1.3 This policy does not apply to third-party websites or services that may be referenced on the platform. nunstar is not responsible for the privacy practices of third-party entities.

1.4 nunstar is committed to processing personal data in a manner that is transparent, proportionate, and consistent with the rights of data subjects under Philippine law. If you have questions about this policy at any point, our Data Protection Officer is available at the contact details in Section 16.

• "Personal Data" means any information that identifies or can reasonably be used to identify a natural person, directly or indirectly, including but not limited to name, mobile number, email address, national ID number, financial account details, IP address, and device identifiers.
• "Sensitive Personal Information" means personal data about an individual's race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations; health, education, genetic data; any proceeding for any offense committed or alleged to have been committed; the issuance of a license or permit, or other government benefit; and specifically financial data such as bank account details — as defined under RA 10173.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure, or deletion.
• "Data Controller" means nunstar, the entity that determines the purposes and means of processing personal data.
• "Data Processor" means a third party that processes personal data on behalf of nunstar pursuant to a written data processing agreement.
• "NPC" means the National Privacy Commission of the Philippines.
• "DPO" means nunstar's designated Data Protection Officer.

3.1 nunstar collects the following categories of personal data, grouped by the context in which they are collected:

Registration and Account Data:

• Full legal name (as it appears on government-issued ID);
• Date of birth;
• Gender;
• Philippine mobile number;
• Email address;
• Residential address (barangay, city/municipality, province);
• Username and encrypted password.

KYC and Identity Verification Data:

• Government-issued photo identification (front and back): passport, driver's license, PhilSys National ID, UMID, SSS ID, or equivalent;
• Proof of address documentation;
• Selfie or liveness verification image for biometric matching;
• Source of funds declaration for high-value accounts.

Financial and Transaction Data:

• GCash or PayMaya account number (or other registered payment method identifier);
• Deposit and withdrawal amounts, dates, and reference numbers;
• Bank account or card details (last four digits and issuing institution only — full card data is never stored by nunstar);
• Wagering history and game session records.

Technical and Usage Data:

• IP address and geolocation data at login;
• Device type, operating system, and browser information;
• Session duration, pages visited, game events, and click-stream data;
• Cookie identifiers and analytics data.

Communications Data:

• Live chat transcripts, email correspondence, and support ticket content;
• Preferences for marketing communications (opt-in/opt-out records).

4.1 nunstar collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or submit a complaint or responsible gaming request;
• Automatically: Through cookies, server logs, and analytics tools when you access and interact with the platform;
• From payment service providers: Transaction confirmation data from GCash, PayMaya, and banking partners necessary to verify and reconcile payment records;
• From identity verification partners: Where nunstar uses a third-party KYC service to validate government-issued identification documents, that service returns a verification result and matched data to nunstar;
• From PAGCOR or law enforcement: Where required by regulation or court order, nunstar may receive data from or share data with Philippine regulatory authorities.

5.1 nunstar processes personal data on the following legal bases as recognized under RA 10173:

6.1 nunstar uses personal data for the following specific purposes:

• To create, verify, and maintain your nunstar Account;
• To verify your identity and age in compliance with PAGCOR's 21+ player eligibility requirements;
• To process deposits, withdrawals, and account balance management in Philippine Pesos;
• To detect, investigate, and prevent fraud, unauthorized account access, and money laundering activity;
• To fulfill nunstar's obligations under PAGCOR's licensing conditions and AMLC reporting requirements;
• To deliver customer support services and respond to player inquiries and complaints;
• To operate, monitor, and improve platform performance, game fairness, and user experience;
• To administer bonuses, promotions, and loyalty programs;
• To enforce nunstar's Terms & Conditions and resolve disputes;
• To send service notifications, including account security alerts and important policy updates;
• To send marketing communications, where you have provided consent and have not subsequently withdrawn it.

6.2 nunstar will not use your personal data for purposes materially different from those listed above without providing prior notice and, where required by RA 10173, obtaining your consent.

7.1 nunstar does not sell, rent, or trade your personal data. We share personal data only with the following categories of recipients and only to the extent necessary for the stated purpose:

• Payment Service Providers: GCash, PayMaya, InstaPay network members, and banking partners — for the purpose of processing deposits and withdrawals. These partners process data as independent data controllers under their own privacy policies.
• Identity Verification (KYC) Partners: Third-party services engaged to validate government-issued identification documents. These services act as data processors under contract with nunstar and are prohibited from using your data for their own purposes.
• Game Content Providers: PAGCOR-licensed game providers (including live dealer studios and RNG slot providers) receive technical session data necessary to deliver their games within the nunstar platform. They do not receive personal identification data beyond what is necessary for fraud prevention.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and Philippine law enforcement agencies, where nunstar is legally required to disclose information or where disclosure is necessary to protect the rights of other players or the platform's integrity.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by nunstar, under confidentiality obligations.

7.2 All third-party data processors engaged by nunstar are required to execute data processing agreements that impose obligations equivalent to those set out in this Privacy Policy and compliant with RA 10173.

8.1 nunstar uses cookies and similar technologies (including session tokens, local storage, and analytics pixels) to operate and improve the platform. The categories of cookies used are:

• Strictly Necessary Cookies: Required for the platform to function. These include authentication session cookies, security tokens, and load-balancing cookies. These cannot be disabled without preventing use of the platform.
• Functional Cookies: Remember your preferences such as language settings, game display options, and responsible gaming tool configurations.
• Analytics Cookies: Collect aggregated, anonymized data about how players use the platform to help nunstar improve performance and user experience. No individual player is identified in analytics reports.
• Security Cookies: Used to detect fraudulent activity, multiple account creation attempts, and unusual login patterns.

8.2 Marketing or third-party advertising cookies are not used on the nunstar platform.

8.3 You may control functional and analytics cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent you from logging into your Account.

9.1 nunstar implements technical and organizational measures to protect personal data against unauthorized access, loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit;
• AES-256 encryption for sensitive personal data stored at rest, including KYC documents and financial records;
• Role-based access controls ensuring that nunstar staff can only access personal data that is necessary for their specific function;
• Multi-factor authentication for internal access to systems containing personal data;
• Regular penetration testing and vulnerability assessments by independent security professionals;
• Comprehensive audit logging of all access to personal data systems;
• Staff training on data privacy obligations and incident response procedures.

9.2 While nunstar takes data security seriously, no online system can guarantee absolute security. Players are reminded that they bear responsibility for maintaining the confidentiality of their login credentials and should contact support immediately upon suspecting unauthorized account access.

10.1 nunstar retains personal data for the following periods, after which data is securely deleted or irreversibly anonymized:

10.2 Where retention beyond the above periods is required by a court order, regulatory investigation, or pending dispute, nunstar will retain the relevant data for the duration of that proceeding.

11.1 Under Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, nunstar players have the following rights with respect to their personal data:

11.2 To exercise any of these rights, please contact nunstar's Data Protection Officer at the email address provided in Section 16. We will respond to valid requests within thirty (30) calendar days of receipt. In complex or high-volume cases, this period may be extended by a further sixty (60) days with prior notice.

11.3 Certain rights — particularly erasure and portability — may be limited where nunstar is required to retain the data to comply with PAGCOR, AMLC, or other legal obligations. Where a right is restricted, nunstar will explain the specific legal basis for the restriction.

12.1 If nunstar becomes aware that personal data has been collected from an individual under 21 years of age — whether through registration fraud or otherwise — the Account will be immediately suspended and all personal data associated with that Account will be deleted, with the exception of records required to be retained for AML reporting purposes.

12.2 Parents or guardians who become aware that a minor has attempted to register or use the nunstar platform are requested to notify nunstar at [email protected] immediately so that appropriate action can be taken.

13.1 nunstar's primary data processing infrastructure is hosted in data centers located in or serving the Philippines. In certain cases, personal data may be transferred to or accessed from servers or processors located outside the Philippines — for example, in connection with cloud-based analytics tools or international game provider technical systems.

13.2 Where personal data is transferred outside the Philippines, nunstar ensures that adequate safeguards are in place, including:

• Data transfer agreements incorporating the standard contractual clauses approved by the NPC;
• Binding corporate rules where applicable;
• Transfer only to jurisdictions with data protection laws deemed adequate by the NPC.

13.3 Players may request details of specific cross-border transfers affecting their personal data by contacting the DPO.

14.1 In the event of a personal data breach — meaning any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data — nunstar will follow the following notification process:

• Internal Detection: nunstar's security team operates continuous monitoring. Upon confirmed detection of a breach, an internal incident response process is activated within two (2) hours;
• NPC Notification: Where the breach is likely to give rise to a real risk of serious harm to affected data subjects, nunstar will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by NPC Circular No. 16-03;
• Player Notification: Affected players will be notified without undue delay by email or in-platform notification, including a description of the nature of the breach, the data categories affected, the likely consequences, and the measures nunstar has taken or proposes to take to address the breach.

14.2 Players who suspect unauthorized activity on their Account should contact support immediately. Security concerns can be reported to [email protected].

15.1 nunstar reviews this Privacy Policy regularly and may update it to reflect changes in applicable Philippine law, NPC guidelines, PAGCOR requirements, or nunstar's data practices.

15.2 Material changes — meaning changes that affect how your personal data is processed or that reduce your rights — will be communicated to registered players via email and in-platform notification at least fourteen (14) days before the changes take effect.

15.3 Non-material changes (such as clarifications of existing practices or administrative updates) will take effect upon posting and are reflected in the "Last Updated" date at the top of this document.

15.4 Continued use of the nunstar platform after the effective date of any amended Privacy Policy constitutes acceptance of the updated terms. Players who do not accept material changes should close their Account before the effective date.

16.1 nunstar has appointed a Data Protection Officer (DPO) as required under RA 10173. The DPO is responsible for overseeing nunstar's compliance with Philippine data privacy law and serving as the primary contact for data subjects exercising their rights under this policy.

16.2 To contact nunstar's Data Protection Officer or to submit a data privacy request, please use the following:

• Email: [email protected] (Subject: "Data Privacy Request – [Your Full Name]")
• Live Chat: Available 24/7 from the nunstar platform — ask to be connected to the Data Privacy team.
• Response Time: Data privacy inquiries are acknowledged within 48 hours and resolved within 30 calendar days.

16.3 If you are not satisfied with nunstar's response to a data privacy request or complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about the NPC's complaint process is available on the NPC's official government website.