unagame Privacy Policy

1. Who We Are

This Privacy Policy is issued by unagame ("Company," "we," "us," or "our"), the operator of the online gaming platform accessible at unagame.club ("Platform"). unagame is a PAGCOR-regulated online gaming operator serving Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, unagame acts as the Personal Information Controller with respect to the personal data of its registered players and platform visitors. This means we determine the purposes and means by which your personal data is processed.

This Privacy Policy applies to all personal data collected through the unagame Platform, including data collected via account registration, gameplay, financial transactions, customer support interactions, and any other use of the Platform. By using the unagame Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Personal Data We Collect

unagame collects only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we collect include:

Identity & Contact Data

Financial Data

Technical & Usage Data

Communications Data

unagame does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where strictly required by law (e.g., for age verification or AML compliance purposes, with your explicit consent).

3. How We Collect Your Data

unagame collects your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and use the Platform, including through cookies, web beacons, and similar tracking technologies (see Section 8).
• Third-party sources: Identity verification data from KYC service providers; fraud detection data from anti-fraud partners; payment data from payment processors (GCash, Maya, banks); and publicly available information where permitted by law.
• Regulatory sources: Data received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other regulatory bodies in connection with our compliance obligations.

4. Why We Use Your Data

unagame processes your personal data for the following purposes:

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act (RA 9160), and the Data Privacy Act (RA 10173).
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications and certain cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing Your Personal Data

unagame 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 and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya/Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and debit card processors, for the purpose of processing your financial transactions.
• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with PAGCOR and AML requirements.
• Fraud prevention and security partners: Service providers who assist us in detecting and preventing fraudulent activity on the Platform.
• Game software providers: Licensed game developers and providers whose games are available on the unagame Platform, to the extent necessary for game operation and fairness auditing.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where required by law or regulatory obligation.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by unagame in connection with our business operations, subject to confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of all or part of unagame'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 unagame shares personal data are required to process that data in accordance with applicable Philippine data protection law and are prohibited from using it for any purpose other than those specified by unagame.

7. Data Retention

unagame retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

• Account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and Philippine AML regulations.
• 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 after the end of the business relationship, or longer if required by applicable law.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Marketing data: Retained until you withdraw your consent or opt out of marketing communications.
• Technical and usage data: Retained for up to twelve (12) months from collection, unless a longer retention period is required for security or fraud investigation purposes.

When your personal data is no longer required, unagame will securely delete or anonymize it in accordance with our data disposal procedures and applicable Philippine law.

8. Cookies & Tracking Technologies

The unagame Platform uses cookies and similar tracking technologies to enhance your experience, analyze Platform usage, and support our security and fraud prevention measures. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled.
• Performance and analytics cookies: Used to collect anonymized information about how visitors use the Platform, helping us improve functionality and user experience.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content and track the effectiveness of our marketing campaigns. These cookies are only set if you have provided your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the unagame Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the Platform.

9. Data Security

unagame implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the unagame Platform
• Encryption at rest for all sensitive personal and financial data stored on our servers
• Multi-factor authentication options for player accounts
• Regular security audits and penetration testing conducted by independent third-party security firms
• Access controls ensuring that only authorized personnel can access personal data, on a strict need-to-know basis
• Intrusion detection systems and 24/7 security monitoring
• Staff training on data protection and information security best practices

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, unagame will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by unagame:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our 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 our legitimate interests.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another 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 your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer (DPO) using the contact details provided in Section 14. unagame will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with NPC requirements.

Please note that certain rights may be subject to limitations where processing is required for compliance with a legal obligation, for the performance of a task carried out in the public interest, or for the establishment, exercise, or defense of legal claims.

11. Children's Privacy

The unagame Platform is strictly intended for persons who are 21 years of age or older, in accordance with the minimum age requirement for online gambling in the Philippines as prescribed by PAGCOR. unagame does not knowingly collect personal data from individuals under the age of 21.

If unagame becomes aware that it has inadvertently collected personal data from a person under 21 years of age, it will immediately suspend the relevant account, delete the personal data in question, and cancel any pending transactions associated with that account. Any funds deposited by an underage user will be returned to the source of deposit after deducting any bonuses or promotional credits received.

If you are a parent or guardian and believe that your child has registered an account on the unagame Platform, please contact our Data Protection Officer immediately using the contact details in Section 14.

12. Cross-Border Data Transfers

In certain circumstances, unagame may transfer your personal data to recipients located outside the Philippines, for example to game software providers, KYC service providers, or cloud infrastructure providers whose servers are located in other countries.

Where such transfers occur, unagame ensures that appropriate safeguards are in place to protect your personal data, in accordance with the requirements of the Data Privacy Act of 2012 and NPC guidelines on cross-border data transfers. These safeguards may include:

• Transferring data only to countries that the NPC has determined provide an adequate level of data protection
• Implementing standard contractual clauses approved by the NPC with the recipient
• Obtaining your explicit consent to the transfer where required

By using the unagame Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

13. Changes to This Privacy Policy

unagame 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. Any changes will be effective immediately upon posting the revised Privacy Policy to the Platform.

Where changes are material, unagame will provide reasonable advance notice via email or an in-platform notification. The "Last Updated" date at the top of this page indicates when the Privacy Policy was most recently revised.

Your continued use of the unagame Platform following the posting of any amended Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

14. Contact & Data Protection Officer

unagame has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO through the following channels:

• Live Chat: Available 24/7 within your unagame account dashboard — the fastest way to reach us
• Email (DPO): [email protected]
• General Support: [email protected]
• Response Time: Within 5 minutes via live chat; within 24 hours via email for general queries; within 30 days for formal data subject requests

If you are not satisfied with our response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.