uugl Privacy Policy

uugl is a PAGCOR-regulated online gaming platform accessible at uugl.net, operated by its licensed entity under a valid gaming license issued by the Philippine Amusement and Gaming Corporation (PAGCOR). uugl is the Personal Information Controller (PIC) for all personal data collected through this platform, as defined under the Data Privacy Act of 2012 (Republic Act No. 10173).

As a Personal Information Controller, uugl determines the purposes and means of processing your personal data. We have appointed a designated Data Protection Officer (DPO) who is responsible for overseeing compliance with the Data Privacy Act and for handling all data subject requests. You may contact our DPO at any time using the contact details set out in Section 15 of this Policy.

This Privacy Policy applies to all personal data collected and processed in connection with your use of the uugl website, mobile platform, customer support channels, and any related services offered under the uugl brand.

uugl collects the following categories of personal data, limited strictly to what is necessary for the purposes described in this Policy:

uugl collects your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including IP address, device identifiers, browser type, and session activity logs via cookies and similar tracking technologies (see Section 7).
• Third-party sources: Identity verification data received from accredited KYC service providers; fraud and sanctions screening data received from compliance database providers; payment transaction data received from GCash, PayMaya, and banking partners in the course of processing your transactions.
• Publicly available sources: Where required for enhanced due diligence under the Anti-Money Laundering Act, uugl may supplement your data with information from publicly accessible Philippine government or regulatory sources.

uugl uses your personal data for the following specific purposes:

• Account creation and management: To register your uugl account, verify your identity, and manage your account settings and preferences throughout your relationship with us.
• Payment processing: To process deposits and withdrawal requests, reconcile transactions, and maintain accurate financial records in Philippine Peso (PHP) across all supported payment channels.
• KYC and regulatory compliance: To verify your identity and age (21+ requirement), screen against PAGCOR exclusion lists and sanctions databases, and comply with the Anti-Money Laundering Act (Republic Act No. 9160, as amended by RA 10365) and FATF recommendations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorised account access, collusion, bonus abuse, and other security threats to the Platform and its Players.
• Responsible gaming: To monitor gameplay patterns, identify potential problem gambling indicators, and enforce responsible gaming tools including deposit limits, loss limits, cooling-off periods, and self-exclusion where necessary.
• Customer support: To respond to your queries, resolve complaints, and maintain records of support interactions for quality assurance and audit purposes.
• Platform improvement: To analyse usage patterns, diagnose technical issues, and enhance the performance, security, and features of the uugl platform.
• Marketing communications (with consent): To send you promotional offers, bonus notifications, and personalised recommendations by email or SMS, strictly where you have opted in to receive such communications. You may withdraw consent at any time.
• Legal and regulatory obligations: To retain records as required by PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other applicable Philippine regulatory bodies.

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

• Contractual necessity: Processing required to perform our contract with you — including account registration, payment processing, and providing access to games — is necessary to deliver the services you have signed up for.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act itself, FATF guidelines, and other applicable Philippine laws and regulations.
• Legitimate interests: Processing for fraud prevention, network and information security, and platform integrity, where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications and non-essential analytics cookies, which is conducted solely on the basis of your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

uugl does not sell your personal data. We share your data only in the following limited circumstances, and only to the extent necessary for each stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, InstaPay, and PESONet receive transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and data security standards.
• KYC and compliance providers: Accredited third-party identity verification and anti-money laundering screening services receive the minimum identity data required to complete KYC checks and sanctions screening in accordance with PAGCOR and AMLC requirements.
• Game providers: Third-party game studios and live casino providers receive pseudonymised player identifiers and gameplay data necessary to operate games and calculate RTP. They do not receive your full identity or financial data.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and law enforcement agencies may receive your data where required by law, court order, or a valid regulatory demand.
• IT and infrastructure providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on uugl's behalf under strict data processing agreements that prohibit independent use of your data.
• Professional advisors: Legal counsel, auditors, and compliance advisors, subject to professional confidentiality obligations, where necessary to protect uugl's legal rights or meet audit requirements.

uugl uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the uugl website. Cookies help us recognise your device, maintain your session, and remember your preferences across visits.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly — including session management, login authentication, and security tokens. These cannot be disabled without rendering the Platform non-functional.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations to provide a personalised experience.
• Analytics cookies: Collect aggregated, anonymised data about how Players navigate the Platform to help us identify performance issues and improve user experience. These are only placed with your consent.
• Marketing cookies: Track your engagement with promotional content to help us deliver relevant bonus offers. These are only placed with your explicit consent and can be withdrawn at any time via your account preferences.

You can manage your cookie preferences at any time through your browser settings or the cookie consent manager available on the uugl platform. Disabling non-essential cookies will not affect your ability to use core platform features.

uugl retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention obligations:

• Account and KYC records: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and the Anti-Money Laundering Act (which mandates a 5-year retention period for covered transaction records).
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLC and BIR record-keeping requirements.
• Customer support communications: Retained for three (3) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing consent records: Retained for the duration of your account and for one (1) year following account closure or withdrawal of consent, as evidence of your consent status.
• Technical and security logs: Retained for twelve (12) months for fraud prevention and platform security analysis, after which they are securely deleted or anonymised.

Upon expiry of the applicable retention period, your personal data is securely deleted or irreversibly anonymised in accordance with uugl's data destruction procedures. Anonymised data may be retained indefinitely for statistical and analytical purposes, as it can no longer be attributed to any identifiable individual.

uugl implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, and destruction:

• 256-bit SSL/TLS encryption on all data transmissions between your device and uugl servers, ensuring your login credentials, payment details, and personal information are never exposed in transit.
• Data encryption at rest for all stored personal data, including KYC documents and financial records, using industry-standard encryption algorithms.
• Multi-factor authentication (MFA) options available to all Players for account login, reducing the risk of unauthorised access even if credentials are compromised.
• Role-based access controls (RBAC) ensuring that uugl staff can only access the personal data necessary for their specific job functions. No employee has unrestricted access to all Player data.
• Regular penetration testing conducted by independent cybersecurity professionals to identify and remediate vulnerabilities in the Platform before they can be exploited.
• Continuous security monitoring with automated intrusion detection systems and 24/7 security operations oversight to identify and respond to threats in real time.
• Staff training: All uugl employees who handle personal data receive mandatory data privacy and security training, and are bound by confidentiality obligations as a condition of their engagement.

While uugl takes every reasonable precaution to protect your data, no online system is entirely immune to risk. You also play an important role in keeping your account secure — please use a strong, unique password for your uugl account and enable MFA if you have not already done so.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by uugl. All requests are handled by our Data Protection Officer and will be responded to within fifteen (15) business days of receipt:

The uugl Platform is strictly intended for individuals who are at least 21 years of age, in accordance with PAGCOR regulations governing online casino gambling in the Philippines. uugl does not knowingly collect, process, or retain personal data from individuals under the age of 21.

If uugl becomes aware that personal data has been collected from an individual who is under 21, the relevant account will be immediately suspended, all associated personal data will be deleted in accordance with our data destruction procedures, and any deposited funds will be returned to their verified source after completing any required regulatory review.

If you have reason to believe that a minor has created an account on uugl, please contact our Data Protection Officer immediately using the contact details in Section 15. uugl takes underage gambling extremely seriously and cooperates fully with any PAGCOR or law enforcement investigation into such matters.

Certain third-party service providers engaged by uugl — including cloud infrastructure providers, game studios, and cybersecurity platforms — may be located outside the Philippines. Where personal data is transferred to a recipient in another country, uugl ensures that such transfers comply with Section 21 of the Data Privacy Act and the NPC's guidelines on cross-border data transfers.

Specifically, uugl takes the following safeguards before transferring your data outside the Philippines:

• Entering into a data processing agreement or data transfer agreement with the recipient that imposes data protection obligations equivalent to those required under Philippine law.
• Verifying that the recipient country's data protection laws provide an adequate level of protection, where relevant NPC guidance exists.
• Limiting the scope of transferred data to the minimum necessary for the service provider to perform their contracted function.

uugl does not transfer personal data to any country or entity where doing so would contravene applicable Philippine data privacy regulations or PAGCOR licensing conditions.

The uugl Platform may contain references to or integrations with third-party services such as game providers, payment gateways, and identity verification services. While uugl carefully selects its service partners, we have no control over the privacy practices of external platforms or services.

This Privacy Policy applies solely to personal data processed by uugl in connection with the uugl Platform. uugl is not responsible for the privacy policies, data handling practices, or security measures of any third party. If you interact directly with a third-party service — including by visiting an external website or app — you do so subject to that third party's own privacy policy.

uugl reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, applicable law, PAGCOR regulatory requirements, or NPC guidance. The effective date at the top of this page indicates when the current version came into force.

Where a material change is made to this Policy — such as a new purpose for processing, a new category of data collected, or a change in your rights — uugl will notify registered Players by email to their registered address and by displaying a prominent notice on the Platform prior to the change taking effect.

Your continued use of the uugl Platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree with the updated Policy, you should discontinue use of the Platform and request account closure before the changes take effect.

The most current version of this Privacy Policy is always available at uugl.net/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact uugl's designated Data Protection Officer through the following channels:

• Email: [email protected] — use subject line "Data Privacy Request" for all formal data subject requests
• Live Chat: Available 24/7 directly through the uugl Platform for general privacy queries
• Operating Hours: Philippine Standard Time (UTC+8), 24 hours a day, 7 days a week
• Response Time: Formal data subject requests are acknowledged within 3 business days and resolved within 15 business days