ug772 Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") is issued by ug772, the operator of the online gaming platform accessible at ug772.cam ("Platform," "we," "us," "our"). It describes how we collect, use, store, disclose, and protect personal data relating to players, website visitors, and prospective registrants ("you," "your," "data subject").

1.2 ug772 is a PAGCOR-regulated online gaming operator. As part of our licensing obligations, we are required to collect and verify certain personal information from all registered players. This Policy explains how that information — and all other personal data we collect — is handled in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and all issuances of the National Privacy Commission ("NPC").

1.3 This Policy applies to all personal data collected through the ug772 Platform, including data collected during account registration, use of games and services, customer support interactions, and payment processing. It applies whether you access the Platform from a desktop browser, mobile browser, or any other device.

1.4 This Policy should be read alongside the ug772 Terms & Conditions and Responsible Gaming Policy, which together form the full legal framework governing your relationship with ug772.

2. Data Controller

2.1 For the purposes of the DPA and applicable data protection law, ug772 is the personal information controller ("PIC") in respect of the personal data described in this Policy.

2.2 ug772 has appointed a Data Protection Officer ("DPO") in accordance with Section 21 of the DPA IRR. The DPO is responsible for overseeing ug772's data protection compliance program and serves as the primary point of contact for data subjects and the NPC in relation to privacy matters.

2.3 Contact details for the ug772 DPO are provided in Section 16 of this Policy.

3. Personal Data We Collect

3.1 ug772 collects the following categories of personal data:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, nationality, government ID number, photograph	KYC/AML compliance, age verification (21+), account registration
Contact Data	Email address, Philippine mobile number, home address	Account communication, support, regulatory notices
Financial Data	GCash number, PayMaya details, bank account number (BDO/BPI/Metrobank), transaction records	Deposit and withdrawal processing, AML compliance
Gaming Data	Game history, bet amounts, win/loss records, session durations, bonus usage	Platform operation, regulatory reporting, responsible gaming monitoring
Technical Data	IP address, device type, browser type, operating system, login timestamps	Security, fraud prevention, platform optimization
Communications Data	Live chat transcripts, support emails, feedback submissions	Customer support, quality assurance, dispute resolution
Preference Data	Responsible gaming settings, notification preferences, language settings	Personalizing your experience, responsible gaming compliance

3.2 ug772 does not process special categories of sensitive personal information (as defined under Section 3(l) of the DPA) unless required to do so by applicable law or with your explicit consent.

4. How We Collect Your Data

4.1 Directly from you: When you register for an ug772 account, complete KYC verification, make deposits or withdrawals, contact our support team, or respond to surveys or promotional communications.

4.2 Automatically: When you use the Platform, we automatically collect Technical Data through cookies, log files, and similar tracking technologies. See Section 8 for more information on cookies.

4.3 From third parties: We may receive personal data about you from identity verification providers, fraud screening services, payment processors (including GCash and PayMaya), and PAGCOR where required under applicable regulations.

5. Legal Basis for Processing

5.1 ug772 processes your personal data on one or more of the following legal bases as recognized under the DPA:

• Consent (Section 12(a), DPA): Where you have given your free, specific, informed, and unambiguous consent to the processing of your personal data for a stated purpose — for example, receiving promotional emails or SMS. You may withdraw consent at any time by contacting us or updating your account preferences.
• Contract (Section 12(b), DPA): Processing is necessary for the performance of a contract to which you are a party — specifically, the ug772 Terms & Conditions governing your account and use of the Platform.
• Legal Obligation (Section 12(c), DPA): Processing is necessary for ug772 to comply with applicable law, including PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), and the DPA.
• Legitimate Interests (Section 12(f), DPA): Processing is necessary for the legitimate interests pursued by ug772 — including fraud prevention, platform security, and improving our services — where those interests are not overridden by your rights and interests as a data subject.

6. How We Use Your Personal Data

6.1 ug772 uses your personal data for the following purposes:

• Registering and managing your ug772 account;
• Verifying your identity and age (21+ requirement) in compliance with PAGCOR regulations and AML law;
• Processing deposits and withdrawals via GCash, PayMaya, BDO, BPI, and Metrobank;
• Providing and personalizing the gaming experience on the Platform;
• Monitoring gaming activity for responsible gaming compliance, including detecting problem gambling indicators;
• Detecting, investigating, and preventing fraud, cheating, money laundering, and other prohibited activities;
• Providing customer support in Tagalog and English;
• Sending transactional communications such as deposit confirmations, withdrawal receipts, and account notifications;
• Sending marketing communications where you have given your consent, or where permitted under applicable law;
• Complying with reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the NPC, and other competent authorities;
• Maintaining the security and integrity of the Platform;
• Resolving disputes and enforcing our Terms & Conditions.

7. Sharing Your Personal Data

7.1 ug772 does not sell, rent, or trade your personal data. We may share your data with the following categories of third parties, strictly for the purposes described in this Policy:

• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government bodies as required by law;
• Payment Processors: GCash, PayMaya, BDO, BPI, Metrobank, and related payment service providers for transaction processing;
• Identity Verification Providers: Third-party KYC and AML screening services to verify your identity and comply with regulatory requirements;
• IT and Security Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements;
• Customer Support Providers: Third-party live chat and support tools used to deliver the ug772 support experience;
• Professional Advisers: Legal, audit, and compliance professionals where reasonably necessary;
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all assets, your data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

7.2 Where ug772 engages third-party processors, we require them to process your data only on our instructions, maintain appropriate security measures, and comply with applicable data protection law. We do not authorize processors to use your data for their own independent purposes.

8. Cookies & Tracking Technologies

8.1 ug772 uses cookies and similar technologies on the Platform to provide core functionality, analyze usage, and improve your experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function — including session management, login authentication, and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings, responsible gaming limits, and display options.
• Analytical Cookies: Help us understand how players interact with the Platform — such as which games are most popular and where technical errors occur. This data is aggregated and anonymized where possible.
• Security Cookies: Assist in detecting and preventing fraudulent activity, account takeover attempts, and other unauthorized access.

8.2 You can manage non-essential cookies through your browser settings. Note that disabling cookies may affect the functionality of some Platform features. ug772 does not use third-party advertising cookies.

9. Data Retention

9.1 ug772 retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations.

9.2 Under PAGCOR regulations and AML law, ug772 is required to retain transaction records, identity verification documents, and gaming data for a minimum of five (5) years from the date of the relevant transaction or from account closure, whichever is later.

9.3 Where personal data is no longer required for any lawful purpose and no legal retention obligation applies, ug772 will securely delete or anonymize that data.

9.4 Data related to resolved disputes or legal claims may be retained for the applicable prescriptive period under Philippine law, which is generally up to ten (10) years for contractual claims.

10. Data Security

10.1 ug772 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit;
• Encryption at rest for sensitive stored data, including financial data and identity documents;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Multi-factor authentication for internal system access;
• Regular security audits, vulnerability assessments, and penetration testing;
• Secure data center infrastructure with physical access controls;
• Employee training on data protection and information security.

10.2 While ug772 takes all reasonable steps to protect your data, no transmission over the internet or electronic storage method is 100% secure. You are responsible for keeping your account credentials confidential and for logging out from shared or public devices.

11. Your Data Subject Rights

11.1 Under the Data Privacy Act of 2012 and its IRR, you have the following rights in relation to your personal data held by ug772:

• Right to be Informed (Section 16(a), DPA): The right to be informed whether personal data pertaining to you is being processed, and to receive information about the nature, purpose, and scope of that processing.
• Right of Access (Section 16(b), DPA): The right to reasonable access to your personal data held by ug772, including a copy of the data and information about how it is used.
• Right to Rectification (Section 16(c), DPA): The right to have inaccurate or incomplete personal data corrected or completed without unreasonable delay.
• Right to Erasure / Right to be Forgotten (Section 16(d), DPA): The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations.
• Right to Object (Section 16(f), DPA): The right to object to the processing of your personal data, including for direct marketing purposes. Where you object to processing based on legitimate interests, ug772 will cease processing unless there are compelling legitimate grounds that override your interests.
• Right to Data Portability (Section 18, DPA): The right to obtain a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Damages (Section 16(e), DPA): The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, or unlawfully obtained personal data.

11.2 To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 16. ug772 will respond to your request within fifteen (15) working days of receipt, as required by the DPA IRR.

11.3 Please note that certain rights are subject to limitations. For example, ug772 may be unable to delete data that we are legally required to retain under PAGCOR regulations or AML law.

12. Children's Privacy

12.1 The ug772 Platform is strictly for adults aged twenty-one (21) years and above, in accordance with PAGCOR regulations and applicable Philippine law. ug772 does not knowingly collect personal data from persons under the age of 21.

12.2 Age is verified during the account registration process through mandatory KYC document submission. Any account found to belong to a person under 21 years of age will be closed immediately and any balance handled in accordance with applicable regulations.

12.3 If you believe that ug772 has inadvertently collected personal data from a person under the age of 21, please contact us immediately so that we can take appropriate action.

13. Marketing Communications

13.1 ug772 may send you marketing communications about promotions, bonuses, and new games where you have given your consent at registration or subsequently through your account settings.

13.2 You may withdraw your consent to receive marketing communications at any time by updating your preferences in your ug772 account settings or by contacting our support team. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

13.3 ug772 will continue to send you transactional and account-related communications (such as deposit confirmations, withdrawal receipts, and important account notices) even if you have opted out of marketing communications, as these are necessary for the performance of the contract between us.

13.4 ug772 will not share your contact details with third parties for the purpose of direct marketing without your explicit consent.

14. Third-Party Links

14.1 The ug772 Platform may contain links to third-party websites or services. This Privacy Policy applies only to the ug772 Platform. ug772 is not responsible for the privacy practices of any third-party websites or services, and we encourage you to review the privacy policies of any third-party sites you visit.

14.2 The inclusion of any third-party link on the ug772 Platform does not constitute an endorsement of the linked site, its content, or its privacy practices.

15. Changes to This Policy

15.1 ug772 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform functionality.

15.2 Where changes to this Policy are material — meaning they significantly affect your rights or how your data is processed — ug772 will notify you by email to your registered address or by a prominent notice on the Platform, at least seven (7) days before the changes take effect.

15.3 The date of the most recent update is displayed at the top of this Policy. Your continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms.

15.4 We encourage you to review this Policy periodically to stay informed about how ug772 is protecting your data.

16. Contact & Complaints

16.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact the ug772 Data Protection Officer through the following channels:

• Email (DPO): [email protected] — mark your message "Attn: Data Protection Officer" (plain text — not a clickable link)
• Live Chat: Available on the ug772 Platform, 24 hours a day, 7 days a week, in Tagalog and English
• Response Time: ug772 will acknowledge your data privacy request within three (3) business days and provide a substantive response within fifteen (15) working days as required by the DPA IRR

16.2 Complaint to the NPC. If you are not satisfied with ug772's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent government body responsible for enforcing the Data Privacy Act of 2012. Information on how to file a complaint is available on the NPC's official website.

16.3 ug772 cooperates fully with the NPC and will respond promptly to any inquiry or investigation initiated by the Commission.