hugph Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how hugph ("hugph," "we," "us," or "our"), the operator of the online gaming platform at hugph.app, collects, uses, stores, shares, and protects the personal data of individuals ("you," "Player," or "User") who access or use the hugph platform and its associated services.

hugph operates within the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines. This Policy is designed to comply fully with those requirements.

This Policy applies to all personal data collected through the hugph website at hugph.app, the hugph mobile application (where available), hugph customer support channels, and any other hugph service or communication channel through which you interact with us.

2 Data Controller

hugph is the data controller responsible for the personal data collected through the hugph platform. As data controller, hugph determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 and all applicable NPC regulations.

hugph has appointed a Data Protection Officer (DPO) who is responsible for overseeing hugph's data protection compliance program and serving as the primary point of contact for data privacy matters. Contact details for the hugph DPO are provided in Section 14 of this Policy.

3 Personal Data We Collect

3.1 Data You Provide Directly

When you register for a hugph account, complete KYC verification, make deposits or withdrawals, contact customer support, or participate in promotions, you provide us with personal data including:

3.2 Data Collected Automatically

When you access and use the hugph platform, we automatically collect certain technical and behavioral data, including:

• IP address and approximate geographic location (city/region level)
• Device type, operating system, and browser information
• Session data including login timestamps, session duration, and pages visited
• Game activity data including games played, wagers placed, and outcomes
• Cookie and tracking technology data (see Section 7)

3.3 Data from Third Parties

hugph may receive personal data about you from third-party sources, including payment processors (such as GCash and Maya) for transaction verification purposes, identity verification service providers for KYC compliance, and fraud prevention and anti-money laundering screening services.

4 How We Use Your Personal Data

hugph processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your hugph player account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to hugph games, process your deposits and withdrawals, and deliver the services you have requested.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160, as amended), and other applicable Philippine laws and regulations, including mandatory reporting obligations.
• KYC Verification: To verify your identity, age (21+), and eligibility to use the hugph platform in accordance with PAGCOR regulations.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, and other prohibited conduct on the hugph platform.
• Customer Support: To respond to your inquiries, resolve complaints, and provide technical assistance.
• Responsible Gaming: To monitor gameplay patterns for signs of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent to receive such communications.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the hugph platform, games, and user experience.

5 Legal Basis for Processing

hugph processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to perform our contract with you (the hugph Terms and Conditions), including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with hugph's legal obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests: Processing necessary for hugph's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications and certain non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Data Sharing & Disclosure

6.1 Service Providers

hugph shares personal data with carefully selected third-party service providers who assist us in operating the hugph platform. These include payment processors (GCash, Maya, and Philippine banking partners), identity verification and KYC service providers, game software providers, cloud hosting and IT infrastructure providers, and customer support platform providers. All service providers are contractually bound to process your data only on hugph's instructions and in accordance with the Data Privacy Act of 2012.

6.2 Regulatory and Law Enforcement Authorities

hugph is required by Philippine law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities upon lawful request or as required by applicable regulations. hugph will comply with all such lawful requests.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of hugph's business, your personal data may be transferred to the acquiring entity as part of that transaction. hugph will notify you of any such transfer and ensure that the acquiring entity is bound by privacy obligations no less protective than those in this Policy.

7 Cookies & Tracking Technologies

hugph uses cookies and similar tracking technologies (such as web beacons and local storage) on the hugph platform. These technologies serve the following purposes:

• Essential Cookies: Required for the hugph platform to function correctly, including maintaining your login session, remembering your language preferences, and ensuring platform security. These cannot be disabled without affecting platform functionality.
• Performance Cookies: Used to collect anonymized data about how players use the hugph platform, helping us identify and fix technical issues and improve platform performance.
• Functional Cookies: Used to remember your preferences and personalize your hugph experience, such as your preferred game categories and display settings.
• Analytics Cookies: Used to understand aggregate usage patterns on the hugph platform. Analytics data is processed in anonymized or pseudonymized form where possible.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the hugph platform. For essential cookies, no opt-out is available as they are strictly necessary for platform operation.

8 Data Retention

hugph retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention periods:

• Account Data: Retained for the duration of your hugph account and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of the Philippines.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications, after which it will be deleted or anonymized within thirty (30) days.

Upon expiry of the applicable retention period, hugph will securely delete or anonymize your personal data in accordance with NPC guidelines on data disposal.

9 Your Data Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by hugph:

To exercise any of these rights, please contact the hugph Data Protection Officer using the contact details in Section 14. hugph will respond to all verified data privacy requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

10 Data Security

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

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the hugph platform.
• Encryption of sensitive data at rest, including financial data and KYC documents.
• Role-based access controls ensuring that only authorized hugph personnel with a legitimate business need may access personal data.
• Regular security assessments, penetration testing, and vulnerability scanning of the hugph platform.
• Mandatory data privacy and security training for all hugph employees who handle personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

11 Children's Privacy

The hugph platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine law and PAGCOR regulations. hugph does not knowingly collect personal data from individuals under the age of 21.

If hugph becomes aware that it has inadvertently collected personal data from a person under 21 years of age, it will take immediate steps to delete such data and close the associated account. If you believe that hugph may have collected data from a minor, please contact us immediately using the details in Section 14.

12 Third-Party Links

The hugph platform may contain links to third-party websites or services for informational purposes. hugph is not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies solely to personal data collected through the hugph platform. We encourage you to review the privacy policies of any third-party websites you visit.

13 Changes to This Privacy Policy

hugph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC regulations. Where changes are material, hugph will provide reasonable advance notice to registered players via the hugph platform or by email to your registered address, no less than seven (7) days before the changes take effect.

The most current version of this Privacy Policy will always be available at hugph.app/privacy-policy. The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the hugph platform after the effective date of any revised Policy constitutes your acceptance of the updated terms.

14 Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or hugph's data processing practices, please contact the hugph Data Protection Officer:

hugph is registered with the National Privacy Commission of the Philippines as required under the Data Privacy Act of 2012. For complaints that cannot be resolved directly with hugph, you may contact the NPC at privacy.gov.ph.