Privacy Policy

1. Introduction and Scope

This Privacy Policy governs the collection, use, storage, disclosure, and protection of personal information by nunsta in connection with your use of our online casino and sports betting platform, including our website (nunsta.cam), mobile applications, customer support services, and all related features and functionalities (collectively, the "Services"). By accessing or using nunsta Services, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your overall relationship with nunsta. Where there is any inconsistency between this Privacy Policy and other policies or agreements, the Terms & Conditions shall prevail regarding general contractual matters, while this Privacy Policy shall prevail specifically regarding data protection and privacy matters.

1.1 Data Controller

For the purposes of Philippine data protection law, nunsta acts as the data controller responsible for your personal information. As data controller, we determine the purposes and means of processing your personal data and are responsible for ensuring such processing complies with applicable data protection laws and regulations.

1.2 Changes to This Policy

nunsta reserves the right to update, amend, or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When material changes are made, we will notify you through prominent notice on our website, email notification to your registered address, or in-app notification. Your continued use of nunsta Services following notification of changes constitutes acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically.

2. Personal Information We Collect

nunsta collects various categories of personal information necessary to provide our Services, comply with legal obligations, and improve your gaming experience. The specific information we collect depends on how you interact with our platform and which features you use.

2.1 Information You Provide Directly

When you register for a nunsta account, contact customer support, participate in promotions, or otherwise interact with our Services, you voluntarily provide personal information including:

• Account Registration Data: Full legal name, date of birth, gender, residential address, email address, mobile phone number, username, password, security questions and answers, preferred language, and currency selection.
• Identity Verification Documents: Government-issued identification (passport, driver's license, national ID, UMID, SSS ID), proof of address documents (utility bills, bank statements), selfie photographs for identity verification, and any additional documents required for enhanced due diligence or regulatory compliance.
• Financial Information: Payment method details (bank account numbers, e-wallet account identifiers, cryptocurrency wallet addresses), transaction history, deposit and withdrawal records, source of funds documentation for large transactions, and tax identification numbers where required by law.
• Communication Data: Contents of your communications with nunsta customer support via email, live chat, phone, or social media, including inquiry details, complaint information, feedback, survey responses, and any attachments you provide.
• Marketing Preferences: Your consent choices regarding promotional communications, newsletter subscriptions, SMS marketing, push notifications, and personalized offers.

2.2 Information Collected Automatically

When you access or use nunsta Services, we automatically collect certain technical and usage information through various technologies:

• Device Information: Device type, model, and manufacturer; operating system and version; browser type and version; screen resolution; device identifiers (UDID, advertising ID); mobile network information; and hardware capabilities.
• Connection Data: IP address, ISP details, geographic location (country, region, city), time zone setting, connection type (WiFi, mobile data), and network quality metrics.
• Usage Analytics: Pages visited, features accessed, games played, bet history, time spent on platform, navigation paths, click patterns, scroll behavior, search queries, filters applied, and feature engagement metrics.
• Gaming Activity: Game preferences, stake sizes, win/loss records, RTP statistics, gaming patterns, session duration, favorite games list, and responsible gaming tool usage.
• Cookies and Similar Technologies: Data collected through cookies, web beacons, pixel tags, local storage, and other tracking technologies as detailed in our Cookie Policy.

2.3 Information from Third Parties

nunsta may receive personal information about you from third-party sources including:

• Payment Providers: Transaction verification data, payment method validation, fraud screening results, and anti-money laundering checks from GCash, Maya/PayMaya, banks, cryptocurrency exchanges, and other payment processors.
• Identity Verification Services: Age verification results, identity authentication data, address validation, sanctions screening, politically exposed persons (PEP) checks, and adverse media screening from specialized verification providers.
• Gaming Platform Providers: Game performance data, technical error logs, and gameplay statistics from third-party game developers and platform operators whose content appears on nunsta.
• Social Media Platforms: Public profile information if you interact with nunsta through social media channels or use social login features (where available and with your explicit consent).
• Marketing Partners: Information about how you discovered nunsta if you were referred through affiliate marketing programs or advertising campaigns (subject to applicable privacy laws and your consent).

3. How We Use Your Personal Information

nunsta processes your personal information for specific, legitimate purposes that are necessary to provide our Services, comply with legal obligations, and maintain a secure and enjoyable gaming environment.

3.1 Service Provision and Account Management

We use your personal information to:

• Create, maintain, and administer your nunsta account
• Authenticate your identity and verify your eligibility to use our Services
• Process your deposits, withdrawals, and other financial transactions
• Provide access to casino games, sports betting markets, and platform features
• Calculate and credit winnings, bonuses, loyalty points, and other rewards
• Respond to your inquiries, support requests, and complaints
• Communicate important account information, transaction confirmations, and service updates
• Implement responsible gaming tools including deposit limits, self-exclusion, and reality checks

3.2 Legal and Regulatory Compliance

We process your personal information to comply with legal obligations including:

• PAGCOR licensing requirements and regulatory reporting obligations
• Philippine Anti-Money Laundering Act (AMLA) and related regulations requiring customer due diligence, transaction monitoring, and suspicious activity reporting
• Philippine Data Privacy Act requirements regarding data subject rights, security measures, and breach notification
• Age verification and prevention of underage gambling in accordance with Philippine law
• Tax reporting obligations under Philippine tax law and international tax treaties
• Cooperation with law enforcement investigations, court orders, and regulatory audits
• Prevention of fraud, money laundering, terrorism financing, and other illegal activities

3.3 Security and Fraud Prevention

We process your personal information to:

• Detect and prevent unauthorized account access, identity theft, and account takeover attempts
• Identify and block fraudulent transactions, payment fraud, and bonus abuse
• Monitor for collusion, chip dumping, and other forms of gaming fraud
• Maintain platform security through intrusion detection, vulnerability management, and security incident response
• Enforce our Terms & Conditions and protect nunsta's legitimate business interests
• Comply with sanctions screening and prevent transactions with prohibited jurisdictions or sanctioned individuals

3.4 Service Improvement and Analytics

We use aggregated and anonymized data to:

• Analyze platform performance, user experience, and feature effectiveness
• Identify technical issues, bugs, and areas for improvement
• Optimize game selection, payment methods, and platform features based on usage patterns
• Develop new products, services, and features that better serve Filipino players
• Conduct market research and competitive analysis
• Generate statistical reports for business intelligence and strategic planning

3.5 Marketing and Personalization

With your explicit consent, we may use your personal information to:

• Send promotional emails about bonuses, tournaments, new games, and special offers
• Deliver SMS notifications about time-sensitive promotions and account updates
• Provide personalized game recommendations based on your preferences and playing history
• Display relevant bonus offers aligned with your gaming activity and VIP tier
• Send birthday bonuses and loyalty rewards
• Conduct customer satisfaction surveys and request feedback

You may withdraw your marketing consent at any time through account settings, unsubscribe links in emails, or by contacting customer support. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

4. Legal Basis for Processing

Under Philippine data protection law, nunsta must have a valid legal basis for processing your personal information. We rely on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (Terms & Conditions) and provide the Services you requested, including account management, transaction processing, and customer support.
• Legal Obligation: Processing is required to comply with legal obligations imposed by PAGCOR regulations, anti-money laundering laws, data privacy laws, tax laws, and other applicable Philippine and international legal requirements.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security enhancement, service improvement, and business analytics, provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: For marketing communications, optional data collection, and certain tracking technologies, we obtain your explicit, informed, and freely given consent, which you may withdraw at any time.
• Vital Interests: In rare circumstances, processing may be necessary to protect your vital interests or those of another person, such as preventing self-harm in responsible gaming contexts.

5. How We Share Your Personal Information

nunsta does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your personal information with carefully selected third parties in the following circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment Processors: GCash, Maya/PayMaya, banks, cryptocurrency payment gateways, and other payment service providers to process deposits and withdrawals
• Identity Verification Services: KYC/AML compliance providers who verify your identity, age, and address
• Game Platform Providers: Third-party game developers and aggregators who supply casino games and sports betting platforms
• Cloud Hosting Providers: Infrastructure and hosting companies that store and process data on secure servers
• Customer Support Tools: Live chat platforms, ticketing systems, and CRM software providers
• Marketing Service Providers: Email marketing platforms, SMS gateways, and advertising networks (where you have consented to marketing)
• Analytics Providers: Tools that help us understand platform usage and improve user experience

All service providers are contractually obligated to maintain confidentiality, process data only for specified purposes, implement appropriate security measures, and comply with applicable data protection laws.

5.2 Legal and Regulatory Authorities

We may disclose your personal information to:

• PAGCOR and other gaming regulators for licensing compliance and regulatory oversight
• Philippine National Police, Anti-Money Laundering Council (AMLC), or other law enforcement agencies investigating criminal activity
• Courts, tribunals, and government authorities in response to valid legal process (subpoenas, court orders, warrants)
• Tax authorities for compliance with tax reporting obligations
• Data privacy regulatory authorities investigating data protection complaints

5.3 Business Transfers

If nunsta undergoes a business transition such as merger, acquisition, asset sale, or bankruptcy, your personal information may be transferred to the successor entity. We will notify you via email and prominent website notice before your personal information becomes subject to a different privacy policy.

5.4 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with third parties for research, analytics, marketing, or other purposes. Such data is not considered personal information under data protection laws.

6. International Data Transfers

nunsta primarily operates within the Philippines and stores data on servers located in secure facilities within the country or in jurisdictions with adequate data protection standards. However, some of our service providers may process data in countries outside the Philippines. When we transfer your personal information internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by data protection authorities
• Privacy Shield certification or equivalent frameworks (where applicable)
• Adequacy decisions recognizing equivalent data protection standards
• Your explicit consent for specific transfers (where required by law)

We conduct due diligence on all international service providers to verify their data protection practices meet our standards and comply with Philippine data privacy law requirements for cross-border data transfers.

7. Data Security Measures

nunsta implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, destruction, or loss. Our security practices include:

• Encryption: 256-bit SSL/TLS encryption for all data transmission between your device and our servers; encryption at rest for sensitive data stored in databases
• Access Controls: Role-based access restrictions limiting employee access to personal information on a need-to-know basis; multi-factor authentication for administrative access
• Network Security: Firewalls, intrusion detection/prevention systems, DDoS protection, and regular security vulnerability assessments
• Secure Development: Security-by-design principles in software development; regular code reviews and penetration testing
• Employee Training: Mandatory data protection and security training for all staff handling personal information; confidentiality agreements
• Incident Response: Documented procedures for detecting, investigating, and responding to security incidents and data breaches
• Third-Party Security: Due diligence and contractual security requirements for all service providers accessing personal information
• Physical Security: Controlled access to data centers and facilities; 24/7 surveillance and monitoring

While we implement industry-leading security measures, no system is completely secure. You acknowledge that data transmission over the internet carries inherent risks, and nunsta cannot guarantee absolute security. You are responsible for maintaining the security of your account credentials and should immediately notify us of any unauthorized account access.

8. Data Retention

nunsta retains your personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by law. Specific retention periods include:

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with data protection best practices. Anonymized data that cannot identify you may be retained indefinitely for analytics and research purposes.

9. Your Privacy Rights

Under the Philippine Data Privacy Act and our commitment to transparency, you have the following rights regarding your personal information:

9.1 Right to Access

You have the right to request confirmation of whether we process your personal information and to obtain a copy of such information. We will provide access in a commonly used electronic format where feasible.

9.2 Right to Rectification

You may request correction of inaccurate or incomplete personal information. You can update most account information directly through your nunsta profile settings.

9.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal information where: (a) it is no longer necessary for the purposes collected; (b) you withdraw consent and no other legal basis exists; (c) you object to processing and no overriding legitimate grounds exist; (d) processing is unlawful; or (e) erasure is required by legal obligation. This right is subject to exceptions where retention is necessary for legal compliance, dispute resolution, or fraud prevention.

9.4 Right to Object

You may object to processing based on legitimate interests or for direct marketing purposes. We will cease such processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

9.5 Right to Data Portability

You may request transfer of your personal information to another service provider in a structured, commonly used, machine-readable format where technically feasible.

9.6 Right to Restrict Processing

You may request limitation of processing where: (a) you contest accuracy pending verification; (b) processing is unlawful but you oppose erasure; (c) we no longer need the data but you require it for legal claims; or (d) you object to processing pending verification of our legitimate grounds.

9.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw such consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

9.8 Right to Lodge a Complaint

You have the right to file a complaint with the Philippine National Privacy Commission if you believe your data protection rights have been violated.

Exercising Your Rights: To exercise any privacy rights, contact our Data Protection Officer via email at [email protected] with "Privacy Rights Request" in the subject line. We will respond to verified requests within thirty (30) days. Identity verification may be required to prevent unauthorized disclosure of personal information.

10. Cookies and Tracking Technologies

nunsta uses cookies, web beacons, and similar technologies to enhance user experience, analyze platform usage, and deliver personalized content. For detailed information about our use of cookies, the types of cookies we deploy, how to manage cookie preferences, and your opt-out options, please refer to our separate Cookie Policy. By continuing to use nunsta Services, you consent to our cookie practices as described in the Cookie Policy.

11. Children's Privacy

nunsta Services are strictly intended for individuals aged 21 years or older in compliance with Philippine gambling laws. We do not knowingly collect personal information from minors. If we discover that we have inadvertently collected information from an individual under 21 years of age, we will immediately delete such information and terminate the associated account. Parents or guardians who believe their child has provided personal information to nunsta should contact us immediately.

12. Contact Information and Data Protection Officer

For questions, concerns, or requests regarding this Privacy Policy or nunsta's data protection practices, please contact: