hugph Casino – Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") describes how hugph Casino ("hugph," "we," "us," or "our"), accessible at hugph.club, collects, uses, discloses, stores, and protects personal data provided by players and visitors ("you") in connection with your use of the hugph platform and related services.

This Policy applies to all personal data collected through the hugph website, mobile web platform, live chat support, email communications, and any other channel through which you interact with hugph. It does not apply to third-party websites or services that may be linked from hugph — those entities operate under their own privacy policies.

hugph operates under PAGCOR regulatory oversight and processes personal data in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC) of the Philippines.

By registering an account with hugph or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2. Data Controller

hugph Casino acts as the personal information controller (PIC) as defined under the Philippine Data Privacy Act with respect to all personal data collected from players and visitors of hugph.club. For all privacy-related enquiries, data access requests, or complaints, you may contact hugph's designated Data Protection Officer (DPO) at: [email protected]

hugph's DPO is responsible for overseeing compliance with the DPA, maintaining the personal data processing records required by law, and acting as the point of contact with the National Privacy Commission.

3. Data We Collect

hugph collects personal data through several channels. The categories of data collected and the circumstances under which they are collected are set out in the table below:

hugph does not intentionally collect sensitive personal information as defined under the DPA (such as health data, political affiliations, or biometric data) beyond what is strictly required for identity verification purposes.

4. How We Use Your Data

hugph uses your personal data for the following purposes:

• Account creation and management — Creating and maintaining your hugph account, verifying your identity, and managing your account settings and preferences.
• Service delivery — Processing deposits and withdrawals in PHP via GCash, Maya, BPI, BDO, and other supported payment methods; crediting bonuses; and providing access to games and betting services.
• Legal and regulatory compliance — Meeting hugph's obligations under PAGCOR's licensing conditions, the Philippine Anti-Money Laundering Act (AMLC requirements), and the Data Privacy Act. This includes performing KYC verification, monitoring for suspicious transactions, and reporting to relevant Philippine authorities as required by law.
• Customer support — Responding to enquiries, resolving disputes, and processing complaints submitted through hugph's live chat or email support channels.
• Fraud prevention and security — Detecting and preventing fraudulent activity, account takeovers, bonus abuse, money laundering, and other prohibited conduct on the hugph platform.
• Responsible gaming — Monitoring gaming behaviour to identify potential signs of problem gambling and administering self-exclusion, cooling-off periods, and deposit limits in accordance with hugph's Responsible Gaming Policy.
• Marketing communications — Sending promotional offers, bonus notifications, and platform updates to players who have opted in. Marketing communications are always optional and can be disabled at any time.
• Platform improvement — Analysing aggregated and anonymised usage data to improve hugph's games, features, performance, and user experience.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, hugph processes your personal data on the following lawful bases:

• Contractual necessity — Processing is necessary to perform the contract between hugph and you as a registered player (i.e., to operate your account, process transactions, and deliver the Services).
• Legal obligation — Processing is required to comply with hugph's obligations under Philippine law, including PAGCOR regulations, the AMLA, and the DPA.
• Legitimate interests — Processing is necessary for hugph's legitimate interests in fraud prevention, platform security, and service improvement, provided those interests are not overridden by your fundamental rights.
• Consent — For marketing communications and optional data uses, hugph relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Data

hugph does not sell or rent your personal data to any third party. hugph may share your personal data only in the following circumstances:

• Payment processors — GCash (Mynt), Maya (PayMaya Philippines), BPI, BDO, UnionBank, 7-Eleven Cliqq, and other payment service providers receive the transaction data strictly necessary to process your deposits and withdrawals.
• Game providers — Licensed third-party game software providers receive a pseudonymous player identifier to deliver game content and record game outcomes. Game providers do not receive your full name, contact details, or financial data.
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities may receive data as required by law or by lawful order.
• Service providers — Technology, cloud infrastructure, fraud detection, and customer support service providers engaged by hugph under data processing agreements that bind them to confidentiality and compliance with the DPA.
• Corporate transactions — In the event of a merger, acquisition, or sale of all or part of hugph's business, personal data may be transferred as part of that transaction, subject to appropriate safeguards and notice to affected players.

All third parties who receive hugph player data are contractually obligated to process it only for the specified purposes and in compliance with applicable Philippine law.

7. Data Retention

hugph retains personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and operational requirements. Specific retention periods are as follows:

• Account and KYC data — Retained for a minimum of five (5) years from account closure, as required by AMLC regulations and PAGCOR licensing conditions.
• Financial transaction records — Retained for a minimum of ten (10) years from the date of each transaction, in accordance with AMLC record-keeping requirements.
• Gaming history — Retained for three (3) years from the date of each transaction for dispute resolution purposes, and thereafter in anonymised form for statistical analysis.
• Support communications — Retained for two (2) years from the date of the last interaction, or longer if a dispute is pending.
• Marketing data — Retained until you withdraw consent or for two (2) years from your last interaction with hugph marketing communications, whichever is earlier.

Upon expiry of the applicable retention period, hugph will securely delete or anonymise your personal data in accordance with its data disposal procedures.

8. Cookies & Tracking Technologies

hugph Casino uses cookies and similar tracking technologies to operate the Platform, maintain your login session, and analyse usage patterns. The types of cookies hugph uses include:

• Essential cookies — Required for core platform functionality, including session management, login state, and security features. These cannot be disabled without impairing your ability to use hugph Casino.
• Analytics cookies — Used to collect aggregated and anonymised data about how Filipino players navigate and use the hugph platform, enabling hugph to improve its design and functionality. No personally identifying data is shared with analytics providers.
• Preference cookies — Store your platform preferences such as language, game display settings, and responsible gaming configurations so that your settings persist between sessions.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies does not affect your ability to play or transact on hugph, but may affect certain personalisation features.

9. Security Measures

hugph implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and hugph's servers.
• Encrypted storage of passwords using modern cryptographic hashing (passwords are never stored in plain text).
• Two-factor authentication (2FA) available to all hugph account holders.
• Role-based access controls limiting access to personal data to hugph staff with a legitimate need.
• Regular security audits and penetration testing of hugph's platform infrastructure.
• Incident response procedures aligned with NPC notification requirements in the event of a personal data breach.

While hugph takes all reasonable steps to protect your data, no online platform can guarantee absolute security. Players are encouraged to use strong, unique passwords and to enable 2FA on their hugph accounts.

10. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by hugph:

• Right to be informed — The right to know what personal data hugph collects, how it is used, and with whom it is shared.
• Right of access — The right to request a copy of the personal data hugph holds about you, including information about its sources and processing history.
• Right to rectification — The right to request correction of inaccurate or incomplete personal data in your hugph account.
• Right to erasure / blocking — The right to request deletion or blocking of your personal data where processing is no longer necessary or was unlawful, subject to hugph's legal retention obligations.
• Right to object — The right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability — The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint — The right to file a complaint with the National Privacy Commission of the Philippines if you believe hugph has violated your data privacy rights.

To exercise any of these rights, contact hugph's Data Protection Officer at [email protected]. hugph will respond to verified data requests within ten (10) business days of receipt. hugph may require identity verification before processing data requests to prevent unauthorised access to your information.

11. Children's Privacy

hugph Casino is strictly intended for adults aged 21 years and above. hugph does not knowingly collect personal data from individuals under 21 years of age. If hugph becomes aware that personal data has been collected from a person under the required age, that account will be suspended immediately and all associated data deleted, except where retention is required for legal compliance purposes.

If you believe that a minor has registered on hugph, please contact hugph's support team immediately at [email protected].

12. International Data Transfers

hugph's primary data processing infrastructure is located in the Philippines. Where personal data is transferred to service providers or game technology partners operating outside the Philippines, hugph ensures that such transfers are made only to entities that provide an adequate level of data protection, consistent with the requirements of the Philippine Data Privacy Act and NPC regulations on cross-border data transfers.

All international data transfer arrangements are documented by hugph and available for review by the National Privacy Commission upon request.

13. Changes to This Privacy Policy

hugph reserves the right to update this Privacy Policy at any time to reflect changes in law, regulatory requirements, or platform operations. Material changes will be communicated to registered players via the Platform or by email to your registered address at least 14 days before they take effect.

The current version of this Privacy Policy is always accessible at hugph.club/privacy-policy. The effective date at the top of this document indicates the date of the most recent revision. Continued use of hugph Casino after the effective date of any update constitutes acceptance of the revised Policy.

14. Contact & Complaints

For all privacy-related enquiries, data subject rights requests, or complaints, contact hugph's Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 on the hugph platform
• Response Time: Within 10 business days for written requests

If your concern is not resolved to your satisfaction by hugph, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (privacy.gov.ph) in accordance with NPC's complaint procedures.