unagame Privacy Policy

1. Introduction

unagame ("unagame," "we," "us," or "our") operates the online gaming platform at unagame.co and is committed to protecting the privacy and personal data of all users ("you," "your," or "Data Subject"). This Privacy Policy is issued in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations.

This Policy applies to all personal data collected through your use of the unagame website, mobile interface, customer support channels, and any other service operated by unagame. By accessing the platform and creating an account, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read in conjunction with the unagame Terms & Conditions, which govern your overall use of the platform. In the event of a conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.

2. Personal Data We Collect

unagame collects the following categories of personal data from users:

1. Identity Data: Full legal name, date of birth, nationality, and government-issued identification numbers (e.g., Philippine National ID, SSS, TIN, PhilHealth, Passport, or Driver's License).
2. Contact Data: Email address, Philippine mobile number (e.g., Globe, Smart, DITO), and residential address (including city, such as Manila, Cebu, Davao, or Quezon City).
3. Financial Data: GCash account details, Maya (PayMaya) wallet information, bank account details (BPI, BDO, UnionBank, Metrobank), and transaction history.
4. Account Data: Username, encrypted password, account preferences, login timestamps, session history, and gaming activity records.
5. Technical Data: IP address, device identifiers, browser type and version, operating system, screen resolution, and approximate geolocation.
6. Usage Data: Information about how you navigate and use the unagame platform, including pages visited, game sessions initiated, bets placed, and features accessed.
7. Communications Data: Records of communications with the unagame support team via live chat, email, or any other channel.
8. Sensitive Personal Information: Where required by PAGCOR or anti-money laundering regulations, unagame may collect sensitive personal information including but not limited to source-of-funds declarations. Such data is handled with the highest level of protection and processed only to the extent strictly required by law.

3. How We Collect Your Data

1. Directly from you: During account registration, KYC verification, deposit or withdrawal transactions, customer support interactions, and promotional participation.
2. Automatically: Through cookies, web beacons, server logs, and similar tracking technologies when you access or use the unagame platform.
3. From third parties: From payment service providers (such as GCash or Maya), identity verification services, fraud prevention agencies, and PAGCOR where legally required.

4. Purposes of Processing

unagame processes your personal data for the following purposes:

1. To register and maintain your unagame account and verify your identity in compliance with PAGCOR Know Your Customer (KYC) requirements.
2. To process deposits, withdrawals, and financial transactions in Philippine Peso through supported payment channels.
3. To provide access to and operate all gaming services on the platform, including live casino, slots, bingo, rummy, Fortune Snake, and sports betting.
4. To comply with legal and regulatory obligations, including anti-money laundering (AML) obligations under Republic Act No. 9160 and reporting obligations to PAGCOR.
5. To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct.
6. To provide customer support and respond to your inquiries, complaints, and feedback.
7. To send you transaction confirmations, security alerts, and service-related communications.
8. To analyze platform usage, improve services, and develop new features — using aggregated, anonymized data where possible.
9. To enforce our Terms & Conditions and Responsible Gaming policies, including self-exclusion orders.

5. Legal Basis for Processing

All personal data processing by unagame is based on one or more of the following legal grounds as recognized under the Data Privacy Act of 2012:

1. Consent: Where you have expressly provided consent at the point of data collection, such as during account registration or marketing opt-ins.
2. Contractual Necessity: Where processing is required to fulfill our contractual obligations to you under the Terms & Conditions.
3. Legal Obligation: Where processing is necessary to comply with applicable Philippine laws and regulations, including PAGCOR directives and AML requirements.
4. Legitimate Interest: Where processing is required for fraud prevention, platform security, and internal analytics — balanced against your privacy rights.

6. Sharing Your Personal Data

unagame does not sell, rent, or trade your personal data. We may share your data only in the following limited circumstances:

1. Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law.
2. Payment Processors: GCash (Mynt), Maya Philippines, BPI, BDO, and other payment partners — only the data necessary to complete your transaction.
3. Identity Verification Providers: Third-party KYC and AML compliance partners, subject to strict data processing agreements.
4. Technology Partners: Game software providers and platform infrastructure providers who process data solely on our instructions and under data processing agreements that comply with the DPA.
5. Law Enforcement: Where required by a court order or lawful request from Philippine law enforcement agencies.

All third parties with whom unagame shares personal data are contractually obligated to handle such data in accordance with the Data Privacy Act of 2012 and applicable NPC regulations.

7. Data Retention

unagame retains personal data for as long as your account is active and for such additional periods as required by law. Specific retention periods are as follows:

1. Account and identity data: Retained for the duration of the account relationship plus a minimum of five (5) years following account closure, in accordance with PAGCOR and AML record-keeping requirements.
2. Financial transaction records: Retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act.
3. Customer support communications: Retained for three (3) years from the date of the last interaction.
4. Technical and usage logs: Retained for a maximum of twelve (12) months, after which they are anonymized or deleted.

Upon the expiry of applicable retention periods, personal data is securely deleted or anonymized in a manner that prevents reconstruction of identifiable information.

8. Cookies and Tracking Technologies

unagame uses cookies and similar tracking technologies to operate the platform, maintain your session, and improve your experience. Categories of cookies used include:

1. Essential Cookies: Required for the basic operation of the platform, including authentication and session management. These cannot be disabled without affecting platform functionality.
2. Performance Cookies: Used to analyze how users interact with the platform — page load times, error rates, and navigation paths — in aggregated, anonymized form.
3. Functional Cookies: Used to remember your preferences, such as language settings and display configurations, between sessions.

You may configure your browser to refuse non-essential cookies. Note that doing so may affect the functionality of certain features on the unagame platform. unagame does not use cookies to track your activity on third-party websites.

9. Security Measures

unagame implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

1. 256-bit SSL/TLS encryption for all data transmitted between your device and unagame servers.
2. Encryption of sensitive data at rest, including passwords (which are stored as salted cryptographic hashes and are never accessible in plaintext by unagame staff).
3. Role-based access controls ensuring that only authorized personnel can access personal data, and only to the extent required by their job function.
4. Regular security assessments and penetration testing of platform infrastructure.
5. Incident response procedures aligned with NPC breach notification requirements under NPC Circular 16-03.

While unagame takes all reasonable steps to protect your data, no electronic system is entirely immune to risk. You are responsible for maintaining the security of your account credentials and for notifying unagame immediately of any suspected unauthorized access.

10. Your Data Subject Rights

As a Data Subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by unagame:

1. Right to be Informed: To know what personal data is being collected, the purpose, and how it will be used — as provided in this Privacy Policy.
2. Right to Access: To obtain a copy of your personal data held by unagame, subject to identity verification.
3. Right to Correction: To request the correction of inaccurate or incomplete personal data in your account.
4. Right to Erasure: To request deletion of your personal data where there is no longer a legal or legitimate basis for its retention. Note that some data must be retained to comply with PAGCOR and AML regulations.
5. Right to Object: To object to processing based on legitimate interest grounds, where applicable.
6. Right to Data Portability: To receive a copy of your personal data in a structured, commonly used format where technically feasible.
7. Right to Lodge a Complaint: To file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of the above rights, please contact the unagame Data Protection Officer (DPO) at [email protected] with the subject line "Data Privacy Request." Requests will be acknowledged within 72 hours and resolved within 30 days of receipt.

11. Children's Privacy

The unagame platform is strictly intended for individuals aged 21 years and above. unagame does not knowingly collect personal data from persons under the age of 21. If unagame becomes aware that personal data has been collected from an individual below the minimum age requirement, such data will be immediately deleted and the account terminated. Parents or guardians who believe a minor may have registered an account are urged to contact unagame at [email protected] immediately.

12. Cross-Border Data Transfers

unagame primarily stores and processes data within the Philippines. Where personal data must be transferred to entities outside the Philippines — for example, to international game software providers — such transfers are conducted only in accordance with Section 21 of the Data Privacy Act of 2012, which requires that the receiving party provides an adequate level of data protection equivalent to Philippine standards. All cross-border transfers are subject to data processing agreements incorporating the NPC's standard contractual clauses.

13. Changes to This Privacy Policy

unagame reserves the right to update or amend this Privacy Policy at any time. Where material changes are made, unagame will notify registered users via email to the registered address or via a prominent notice on the platform. The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of the unagame platform following notification of changes constitutes your acceptance of the revised Privacy Policy.

14. Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the unagame Data Protection Officer: