nustr Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") is issued by the operator of the nustr Platform ("nustr," "we," "us," "our"), a PAGCOR-licensed online gaming operator providing services to registered players in the Philippines via the website nustr.co and all associated interfaces.

This Policy applies to all personal data processed by nustr in connection with your registration, use of the nustr Platform, participation in games and promotions, and communication with nustr's support team. By registering an account on nustr or otherwise using the Platform, you acknowledge that you have read, understood, and agreed to the data practices described in this Policy.

nustr is the Data Controller of your personal data as defined under Republic Act No. 10173 (the "Data Privacy Act of 2012" or "DPA"). Our designated Data Protection Officer ("DPO") can be reached at [email protected] with the subject line "Data Privacy Inquiry."

2. Personal Data We Collect

nustr collects the following categories of personal data from Players:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., PhilSys National ID, SSS, UMID, passport, driver's license) collected during registration and KYC verification.
• Contact Data: Philippine mobile number (e.g., +63 9xx format), email address, and residential address — including barangay, city or municipality (e.g., Makati, Quezon City, Cebu City, Davao City), province, and postal code.
• Financial Data: GCash wallet number or PayMaya account, BPI/BDO/Metrobank account details used for deposits and withdrawals, transaction amounts and timestamps, and balance history within nustr's PHP wallet.
• Gaming Data: Game session records, bet amounts, game outcomes, win/loss history, bonus usage, and responsible gaming limit settings associated with your nustr account.
• Technical Data: IP address, device type and model, operating system, browser type and version, screen resolution, time zone, and connection type logged during each Platform session.
• Behavioural Data: Pages visited within the nustr Platform, features accessed, game lobby navigation patterns, and session duration — used to improve Platform usability and personalise your experience.
• Communications Data: Records of chat and email correspondence with nustr's support team, including the content of messages, timestamps, and outcomes of support interactions.

3. How We Collect Your Data

nustr collects personal data through the following means:

• Direct Submission: Information you provide during registration, KYC document upload, payment method linking, promotional opt-in, or support contact.
• Automated Collection: Technical and behavioural data collected automatically via server logs, session cookies, and analytics tools when you access the nustr Platform.
• Third-Party Providers: Identity verification data from Philippine government ID verification services; payment transaction data from GCash, PayMaya, and banking partners; and fraud-prevention signals from our security technology providers.
• PAGCOR Compliance Processes: Data shared with nustr by PAGCOR as part of licensing, audit, or regulatory compliance processes.

4. How nustr Uses Your Personal Data

nustr processes your personal data for the following purposes:

• Account Management: To create, maintain, and authenticate your nustr account; process logins; and manage account settings and preferences.
• Service Delivery: To make games available, process bets and payouts, credit bonuses, and provide the full range of gaming and account services described on the nustr Platform.
• Payments Processing: To facilitate PHP deposits and withdrawals via GCash, PayMaya, and banking channels; reconcile transactions; and resolve payment disputes.
• Identity Verification & KYC: To verify your identity and age (21+) in compliance with PAGCOR's KYC requirements and the Anti-Money Laundering Act (AMLA) as amended by RA 10927.
• Regulatory Compliance: To meet nustr's obligations under PAGCOR's licensing terms, AMLA reporting requirements, and data governance rules, including submission of required reports to PAGCOR and the Anti-Money Laundering Council (AMLC).
• Fraud Prevention & Security: To detect and prevent fraudulent activity, collusion, bonus abuse, money laundering, and unauthorized account access.
• Responsible Gaming: To implement deposit limits, session reminders, and self-exclusion measures you have activated, and to identify patterns of play that may indicate problem gambling requiring intervention.
• Platform Improvement: To analyse aggregated usage patterns and identify opportunities to improve the nustr Platform's design, performance, and game offering.
• Marketing Communications: To send promotional offers, new game announcements, and nustr updates to Players who have opted in to marketing communications. Players may withdraw marketing consent at any time via account settings or by contacting [email protected].
• Customer Support: To respond to inquiries, resolve disputes, and document support interactions for quality assurance.

5. Legal Basis for Processing

nustr processes personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform nustr's obligations under the Player Account Agreement — including account management, game delivery, and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AMLA reporting obligations, and other applicable Philippine laws.
• Legitimate Interest: Processing for fraud prevention, platform security, and responsible gaming monitoring where nustr's legitimate interest in maintaining a safe, compliant platform does not override Player privacy rights.
• Consent: Processing for marketing communications and optional personalisation features, where you have given explicit, informed consent that can be withdrawn at any time.

6. Data Sharing & Disclosure

nustr does not sell your personal data. We share personal data only in the following circumstances:

• PAGCOR and Regulatory Authorities: nustr is legally required to share certain Player data with PAGCOR, the AMLC, and other Philippine government authorities upon lawful request or as mandated by licensing conditions.
• Payment Processors: Financial data is shared with GCash (G-Xchange, Inc.), PayMaya Philippines, Inc., and banking partners solely for the purpose of processing deposits and withdrawals.
• KYC & Fraud Prevention Providers: Identity data is shared with licensed identity verification and fraud detection technology providers engaged by nustr to fulfil KYC and AML obligations.
• Game Providers: Aggregated, pseudonymised gaming data may be shared with nustr's game content licensors for game performance analysis and RTP auditing. No personally identifiable data is shared with game providers beyond what is necessary for session authentication.
• Legal Proceedings: nustr may disclose personal data in response to a valid court order, subpoena, or other lawful legal process issued by a Philippine court or authorized government body.

7. Cookies & Tracking Technologies

nustr uses cookies and similar technologies to maintain your logged-in session, remember Platform preferences, detect fraudulent login attempts, and collect aggregated analytics on Platform usage. Session cookies are deleted when you close your browser. Persistent cookies remain on your device for a defined period to improve your next visit experience.

You may configure your browser to refuse cookies; however, doing so may impair certain nustr Platform functions, including maintaining your login session. nustr does not use third-party advertising cookies or cross-site tracking technologies for behavioural advertising purposes.

8. Data Retention

nustr retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and transaction records: Retained for a minimum of five (5) years after account closure in compliance with AMLA recordkeeping requirements.
• KYC documentation: Retained for a minimum of five (5) years from the date of the last transaction, as required by PAGCOR and AMLA regulations.
• Support communications: Retained for three (3) years from the date of the interaction unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of the consent plus three (3) years to demonstrate compliance with consent requirements.

9. Security Measures

nustr implements technical and organisational security measures appropriate to the risk level of the personal data processed, including: 256-bit TLS encryption for all data in transit; encryption at rest for stored sensitive personal data including financial identifiers and government ID numbers; access controls limiting data access to nustr personnel on a strict need-to-know basis; regular security vulnerability assessments; and incident response procedures for personal data breaches in compliance with the National Privacy Commission's breach notification requirements under NPC Circular 16-03.

10. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, nustr Players have the following rights with respect to their personal data:

• Right to be Informed: The right to know what personal data nustr collects about you and how it is used — fulfilled by this Policy.
• Right of Access: The right to request a copy of the personal data nustr holds about you.
• Right to Rectification: The right to correct inaccurate or incomplete personal data in your nustr account.
• Right to Erasure / Blocking: The right to request deletion or blocking of personal data that is unlawfully processed or no longer necessary, subject to nustr's legal retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Object: The right to object to processing based on legitimate interest, including direct marketing.
• Right to Damages: The right to seek compensation for damages suffered due to inaccurate, incomplete, or unlawfully processed personal data.

To exercise any of these rights, contact nustr's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." nustr will respond within fifteen (15) business days. If you are not satisfied with nustr's response, you may lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Children and Minors

The nustr Platform is strictly for individuals aged 21 years and above. nustr does not knowingly collect personal data from persons below 21 years of age. If nustr becomes aware that personal data has been collected from a minor, the relevant account will be immediately suspended and the data will be deleted in accordance with applicable law. If you believe a minor has registered on the nustr Platform, please contact [email protected] immediately.

12. Changes to This Privacy Policy

nustr may update this Privacy Policy from time to time to reflect changes in data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes will be communicated to registered Players via email or in-platform notification at least seven (7) calendar days before the updated Policy takes effect. Continued use of the nustr Platform after the effective date of any update constitutes acceptance of the revised Policy. The current version of this Policy is always accessible at nustr.co/privacy-policy.