nustra Privacy Policy

1. Introduction and Scope

nustra ("we," "us," "our," or the "Company") is committed to protecting the privacy and personal information of all individuals who use our online gaming platform ("Platform"). This Privacy Policy describes how we collect, use, disclose, store, and protect your personal data when you visit our website, register an account, or use any of our services.

This Privacy Policy applies to all users of the nustra Platform, including visitors, registered players, and former account holders. By accessing or using the Platform, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with these terms, you must discontinue use of the Platform immediately.

nustra complies with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and all relevant issuances by the National Privacy Commission (NPC) of the Philippines. We also adhere to internationally recognized data protection principles to ensure the highest standards of privacy and security for our users.

2. Data Controller Information

For the purposes of the Data Privacy Act of 2012, nustra is the data controller responsible for your personal information. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer (DPO) at:

• Email: [email protected]
• Mailing Address: nustra Data Protection Office, Metro Manila, Philippines
• Contact Hours: Monday to Friday, 9:00 AM – 6:00 PM Philippine Standard Time

3. Personal Information We Collect

nustra collects various types of personal information depending on how you interact with our Platform. The categories of personal data we collect include:

3.1 Registration and Account Information

When you create an account with nustra, we collect the following information:

• Full legal name (first name, middle name, last name)
• Date of birth (to verify age eligibility)
• Gender
• Residential address (street address, barangay, city, province, postal code)
• Email address
• Mobile phone number
• Username and password (encrypted)
• Preferred language and currency

3.2 Identity Verification Documents

To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, we require you to submit identity verification documents before your first withdrawal or at any time we deem necessary for security purposes. These documents may include:

• Government-issued identification (Philippine passport, driver's license, Unified Multi-Purpose ID, Postal ID, National ID)
• Proof of address (utility bills, bank statements, government correspondence dated within the last three months)
• Selfie or photograph holding your ID (for facial verification)
• Copies of credit or debit cards (with middle digits masked for security)

3.3 Payment and Financial Information

When you make deposits or withdrawals, we collect payment-related information, which may include:

• Payment method details (GCash account, PayMaya account, bank account number, card number)
• Transaction amounts, dates, and statuses
• Billing address (if different from residential address)
• Payment processor transaction IDs and receipts

Please note that sensitive payment data such as full credit card numbers and CVV codes are processed and stored by our third-party payment processors in compliance with Payment Card Industry Data Security Standards (PCI-DSS). nustra does not store complete credit card information on our servers.

3.4 Gaming and Usage Data

To provide our services and improve user experience, we collect information about your gaming activity and Platform usage, including:

• Games played, bet amounts, wins, and losses
• Session duration, login and logout times
• Deposit and withdrawal history
• Bonus claims, wagering progress, and bonus history
• Communication with customer support (chat logs, email correspondence, call recordings)
• Responsible gaming settings (deposit limits, loss limits, self-exclusion requests)

3.5 Technical and Device Information

When you access the nustra Platform, we automatically collect certain technical information through cookies, log files, and similar technologies:

• IP address and geolocation data (country, region, city)
• Device type, operating system, and browser type and version
• Screen resolution and device identifiers
• Referring URLs, pages visited, and clickstream data
• Time zone settings and access times
• Network and internet service provider information

3.6 Marketing and Communication Preferences

We collect information about your communication preferences, including:

• Email, SMS, and push notification preferences
• Opt-in or opt-out status for promotional materials
• Response data from marketing campaigns (email opens, link clicks)

4. How We Use Your Personal Information

nustra uses your personal information for the following purposes:

4.1 Account Management and Service Delivery

• To create, maintain, and manage your user account
• To verify your identity and age eligibility
• To process deposits, withdrawals, and payment transactions
• To enable gameplay and provide access to gaming services
• To apply bonuses, promotions, and loyalty rewards
• To communicate with you regarding your account, transactions, and service updates

4.2 Legal and Regulatory Compliance

• To comply with KYC, AML, and Counter-Terrorist Financing (CTF) obligations
• To meet regulatory requirements imposed by PAGCOR and other relevant authorities
• To detect, prevent, and investigate fraud, money laundering, and other illegal activities
• To enforce our Terms and Conditions and other legal agreements
• To respond to legal requests, court orders, and government inquiries

4.3 Security and Fraud Prevention

• To monitor for suspicious activity, collusion, or bonus abuse
• To protect the integrity of our games and Platform
• To investigate disputes, complaints, and policy violations
• To implement responsible gaming measures and self-exclusion tools

4.4 Marketing and Personalization

• To send promotional emails, SMS messages, and push notifications about new games, bonuses, and special offers (with your consent)
• To personalize your experience based on your gaming preferences and behavior
• To conduct surveys, gather feedback, and improve our services
• To provide customer support and address your inquiries

4.5 Analytics and Service Improvement

• To analyze Platform usage, gaming trends, and user behavior
• To optimize Platform performance, features, and user interface
• To test new games, features, and promotional campaigns
• To generate aggregated, anonymized reports for business analysis

5. Legal Basis for Processing Personal Data

Under the Data Privacy Act of 2012, nustra processes your personal information based on the following legal grounds:

• Consent: You have given explicit consent for us to process your personal data for specific purposes, such as marketing communications.
• Contract Performance: Processing is necessary to fulfill our contractual obligations to you, such as providing gaming services, processing transactions, and managing your account.
• Legal Obligation: Processing is required to comply with legal and regulatory obligations, including KYC, AML, and tax reporting requirements.
• Legitimate Interest: Processing is necessary for our legitimate business interests, such as fraud prevention, security, and service improvement, provided that such interests do not override your fundamental rights and freedoms.

6. Sharing and Disclosure of Personal Information

nustra does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients under strict confidentiality and data protection agreements:

6.1 Service Providers and Business Partners

We engage trusted third-party service providers to support our operations, including:

• Payment processors (GCash, PayMaya, banks, card networks)
• Identity verification and KYC service providers
• Game developers and software providers
• Cloud hosting and IT infrastructure providers
• Customer support platforms and communication tools
• Marketing and analytics service providers

These service providers are contractually obligated to process your data only for the purposes we specify and in accordance with our instructions. They must implement appropriate security measures and are prohibited from using your data for their own purposes.

6.2 Regulatory Authorities and Law Enforcement

We may disclose your personal information to government agencies, regulatory bodies, and law enforcement authorities when required by law or when necessary to:

• Comply with legal obligations, court orders, or subpoenas
• Cooperate with investigations into fraud, money laundering, or other illegal activities
• Respond to requests from PAGCOR, the National Privacy Commission, or other regulatory authorities
• Protect the rights, property, or safety of nustra, our users, or the public

6.3 Corporate Transactions

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to a successor entity. We will notify you via email or prominent notice on our Platform before your information is transferred and becomes subject to a different privacy policy.

7. Data Retention

nustra retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Active Accounts: Personal data is retained for the duration of your account's active status and as long as you continue to use our services.
• Closed Accounts: After account closure, we retain certain information for a minimum of five (5) years to comply with legal, regulatory, and tax obligations, as well as to resolve disputes and enforce our agreements.
• Transaction Records: Financial transaction records are retained for at least ten (10) years in accordance with AML and tax reporting requirements.
• Marketing Data: Marketing-related data is retained until you withdraw consent or request deletion, after which it is removed within sixty (60) days.

Once the retention period expires, we securely delete or anonymize your personal data in accordance with industry best practices.

8. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

8.1 Right to Access

You have the right to request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format.

8.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most of your account information directly through your account settings.

8.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes it was collected or when you withdraw consent. However, we may retain certain information to comply with legal obligations or to establish, exercise, or defend legal claims.

8.4 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may opt out by clicking the unsubscribe link in promotional emails or by adjusting your communication preferences in your account settings.

8.5 Right to Data Portability

You have the right to request a copy of your personal data in a portable format to transfer to another service provider, where technically feasible.

8.6 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time. However, withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

8.7 Right to Lodge a Complaint

If you believe we have violated your privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within thirty (30) days.

9. Security Measures

nustra takes the security of your personal information seriously and has implemented a range of technical, organizational, and physical security measures to protect your data from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of sensitive data during transmission using SSL/TLS protocols
• Encryption of stored data using industry-standard encryption algorithms
• Secure access controls and authentication mechanisms
• Regular security audits and vulnerability assessments
• Firewalls, intrusion detection, and intrusion prevention systems
• Employee training on data protection and confidentiality obligations
• Restricted access to personal data on a need-to-know basis

While we strive to protect your personal information, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any unauthorized access to your account.

10. Cookies and Tracking Technologies

nustra uses cookies, web beacons, and similar tracking technologies to enhance your experience on our Platform. Cookies are small text files stored on your device that allow us to recognize you and remember your preferences. We use the following types of cookies:

• Essential Cookies: Required for the Platform to function properly, such as authentication and security cookies.
• Functional Cookies: Enable enhanced features and personalization, such as remembering your language preference.
• Analytics Cookies: Help us understand how visitors use the Platform by collecting anonymous usage data.
• Marketing Cookies: Used to deliver personalized advertisements and track the effectiveness of marketing campaigns.

You can manage your cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of the Platform.

11. International Data Transfers

Your personal information may be transferred to and processed in countries outside the Philippines, including jurisdictions that may not provide the same level of data protection as Philippine law. When we transfer your data internationally, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses or other legal mechanisms approved by the National Privacy Commission, to protect your information in accordance with this Privacy Policy.

12. Children's Privacy

The nustra Platform is intended for individuals aged twenty-one (21) years and above. We do not knowingly collect or solicit personal information from individuals under the age of 21. If we become aware that we have collected personal information from a minor without proper consent, we will take immediate steps to delete that information. If you believe we have inadvertently collected information from a minor, please contact us at [email protected].

13. Changes to This Privacy Policy

nustra reserves the right to modify, update, or amend this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify you by posting the updated Privacy Policy on our Platform with a revised "Last Updated" date. We may also notify you via email or through a prominent notice on the Platform. Your continued use of the Platform after the effective date of the updated Privacy Policy constitutes your acceptance of the changes.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Privacy Inquiry – [Your Account Username]
• Response Time: We aim to respond to all privacy inquiries within thirty (30) days.