nurtstar Privacy Policy

1. Introduction

1.1 nurtstar is committed to protecting the privacy and personal data of every player who uses our platform. This Privacy Policy describes what personal information nurtstar collects, the purposes for which it is used, who it may be shared with, how long it is retained, and the rights available to you as a data subject under Philippine law.

1.2 As a personal information controller under the Data Privacy Act of 2012, nurtstar is responsible for the personal data it collects and processes in connection with the operation of nurtstar.net and associated services.

1.3 This Privacy Policy should be read alongside the nurtstar Terms & Conditions and Responsible Gaming Policy. In the event of any conflict between this policy and applicable Philippine data protection law, the law shall prevail.

1.4 We may update this Privacy Policy from time to time to reflect changes in our practices or applicable legal requirements. The most current version will always be published at nurtstar.net/privacy-policy. Continued use of the platform after the publication of an updated policy constitutes acceptance of the revised terms.

2. Data We Collect

2.1 nurtstar collects personal data from you in the following categories:

2.2 nurtstar does not collect sensitive personal information beyond what is strictly necessary for identity verification and compliance purposes. We do not collect racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data unless expressly required by applicable law.

3. How We Use Your Data

3.1 nurtstar uses the personal data it collects for the following purposes:

• Account Management: Creating, verifying, and maintaining your nurtstar account, including KYC identity verification as required by PAGCOR and anti-money-laundering regulations;
• Service Delivery: Processing deposits, withdrawals, and game transactions denominated in Philippine Pesos;
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, money laundering, unauthorized account access, and other prohibited conduct;
• Legal & Regulatory Compliance: Meeting obligations under the Data Privacy Act, PAGCOR licensing requirements, and applicable anti-money-laundering laws (AMLA and its amendments);
• Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance;
• Responsible Gaming: Monitoring gambling patterns to identify potential problem gaming and administering responsible gaming tool requests, including deposit limits and self-exclusion;
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve platform performance, game selection, and user experience;
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications.

3.2 nurtstar does not use automated decision-making or profiling in ways that produce legal or similarly significant effects on players, except where required for fraud prevention or regulatory compliance, in which case players retain the right to request human review of automated decisions.

4. Legal Basis for Processing

4.1 nurtstar processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract between you and nurtstar (account creation, payment processing, game service delivery);
• Legal Obligation: Processing required to comply with applicable law, including PAGCOR regulatory requirements, AMLA obligations, and KYC mandates;
• Legitimate Interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and optional platform features, where you have provided explicit, informed consent that may be withdrawn at any time.

5. Data Sharing

5.1 nurtstar does not sell your personal data to third parties. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: GCash, PayMaya, and partner banks (BPI, BDO, Metrobank) receive transaction data necessary to process deposits and withdrawals;
• Game Providers: Licensed game providers receive the minimum account and session data required to deliver their games on the nurtstar platform;
• KYC & Compliance Providers: Identity verification and anti-money-laundering service providers receive identity documents and related data as required by law;
• Regulatory Authorities: PAGCOR and other Philippine government agencies and law enforcement bodies may receive data where nurtstar is legally obligated to disclose it;
• Technology Providers: Cloud hosting, platform infrastructure, and customer support technology providers operate under strict data processing agreements and are prohibited from using nurtstar player data for any other purpose.

5.2 All third-party service providers engaged by nurtstar who process personal data on our behalf are required to implement appropriate technical and organizational measures to protect that data, and are contractually prohibited from using it for purposes beyond those specified by nurtstar.

6. Cookies & Tracking Technologies

6.1 nurtstar uses cookies and similar tracking technologies on the platform to support session management, security, and platform performance. The following types of cookies are used:

• Essential Cookies: Required for the platform to function. These include session authentication cookies and security tokens. These cannot be disabled without impairing platform functionality;
• Performance Cookies: Collect anonymized data about how players use the platform (pages visited, session duration, errors encountered) to support platform improvement;
• Preference Cookies: Store your language, display, and game settings so they persist between sessions.

6.2 nurtstar does not use third-party advertising or cross-site tracking cookies. You may manage cookie preferences through your browser settings, though disabling essential cookies will impair your ability to log in and use the platform.

7. Data Retention

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

• Account and KYC data: Retained for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction;
• Gaming and session logs: Retained for a minimum of two (2) years;
• Customer support communications: Retained for two (2) years from the date of the interaction;
• Marketing consent records: Retained for the duration of the consent plus three (3) years.

7.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be attributed to any individual.

8. Your Rights as a Data Subject

8.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by nurtstar:

• Right to be Informed: The right to know what personal data nurtstar collects about you and how it is used;
• Right of Access: The right to request a copy of the personal data nurtstar holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to applicable legal retention requirements;
• Right to Object: The right to object to processing based on legitimate interests, including direct marketing;
• Right to Data Portability: The right to receive a copy of your personal data in a structured, machine-readable format;
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

8.2 To exercise any of the above rights, please contact nurtstar's Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) calendar days as required by the DPA and its implementing rules.

9. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and nurtstar servers;
• Encrypted storage of sensitive personal data including government ID numbers and financial account references;
• Access controls limiting personal data access to authorized nurtstar personnel on a strict need-to-know basis;
• Regular security assessments and penetration testing of platform infrastructure;
• Multi-factor authentication requirements for administrative access to player data systems.

9.2 In the event of a personal data breach that is likely to result in harm to your rights and freedoms, nurtstar will notify the National Privacy Commission and affected players within the timeframes prescribed by the DPA and its implementing rules.

10. Children's Privacy

10.1 The nurtstar platform is strictly prohibited for persons under the age of 21 years, in accordance with Philippine gaming regulations. nurtstar does not knowingly collect personal data from persons under 21. If we become aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account.

10.2 If you are a parent or guardian and believe that a minor has registered on the nurtstar platform using false information, please contact us immediately at [email protected].

11. Cross-Border Data Transfers

11.1 Where nurtstar transfers personal data to third-party service providers located outside the Philippines — including cloud infrastructure and game provider partners — such transfers are conducted only where adequate data protection safeguards are in place, consistent with the requirements of the Data Privacy Act and NPC regulations on cross-border transfers.

11.2 nurtstar will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate contractual safeguards, including standard data protection clauses approved by the National Privacy Commission.

12. Changes to This Privacy Policy

12.1 nurtstar may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable legal requirements. The "Last Updated" date at the top of this page reflects when the current version became effective.

12.2 Material changes to this Privacy Policy will be communicated to registered players via in-account notification or email to the registered address on file. Continued use of the nurtstar platform following the effective date of any updated policy constitutes acceptance of the revised terms.

13. Contact Us

13.1 For any questions, concerns, or requests relating to this Privacy Policy or your personal data held by nurtstar, please contact our Data Protection Officer:

13.2 You also have the right to file a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated. The NPC can be reached through its official government channels.