Privacy Policy

1 Introduction

1.1 uuujl ("we," "us," "our") is committed to protecting the privacy and personal data of all players and visitors who use the uuujl platform. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by uuujl.

1.2 This Privacy Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations, as administered by the National Privacy Commission ("NPC").

1.3 Please read this Privacy Policy carefully to understand our practices regarding your personal data. If you have any questions or concerns about how uuujl handles your data, please refer to Section 14 for our contact details.

2 Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, uuujl is the personal information controller in respect of the personal data collected through the uuujl platform.

2.2 uuujl has designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. The DPO may be contacted via the details provided in Section 14.

3 Personal Data We Collect

3.1 uuujl collects the following categories of personal data from players and platform visitors:

3.2 uuujl does not collect sensitive personal information as defined under the DPA (such as health data, political opinions, or religious beliefs) unless specifically required for responsible gaming purposes, in which case your explicit consent will be obtained.

4 How We Collect Your Data

4.1 Directly from you. uuujl collects personal data that you provide directly when you register an Account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions.

4.2 Automatically. When you access the uuujl platform, we automatically collect certain technical and usage data through cookies, log files, and similar tracking technologies. Please refer to Section 9 for more information on our use of cookies.

4.3 From third parties. uuujl may receive personal data about you from third-party identity verification providers, payment processors (such as GCash and Maya), fraud prevention services, and regulatory authorities where required by law.

5 How We Use Your Personal Data

5.1 uuujl uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and administer your uuujl Account, including processing your uuujl Login and verifying your identity;
• Service delivery: To provide you with access to games, process deposits and withdrawals, and deliver the features of the uuujl platform;
• Legal and regulatory compliance: To comply with our obligations under Philippine gaming regulations, the DPA, anti-money laundering laws, and PAG COR requirements;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorised account access, and other illegal activities;
• Responsible gaming: To monitor gaming behaviour, enforce deposit limits and self-exclusion requests, and identify players who may need support;
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance;
• Marketing and promotions: To send you information about uuujl promotions, bonuses, and new features, where you have consented to receive such communications;
• Platform improvement: To analyse usage patterns, conduct research, and improve the performance, security, and features of the uuujl platform;
• Age verification: To verify that all players are aged 21 or above in compliance with Philippine gaming regulations.

5.2 uuujl will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by applicable law.

6 Legal Basis for Processing

6.1 uuujl processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform our contract with you — that is, to operate your uuujl Account and deliver the services you have requested;
• Legal obligation: Processing is necessary to comply with our legal and regulatory obligations under Philippine law, including PAGCOR regulations and anti-money laundering requirements;
• Legitimate interests: Processing is necessary for uuujl's legitimate interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and interests;
• Consent: Where we rely on your consent as the legal basis for processing — for example, for direct marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Sharing Your Personal Data

7.1 uuujl does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Payment processors: GCash, Maya, and partner banks (BPI, BDO, UnionBank, Metrobank, Landbank, PNB, Security Bank) to process deposits and withdrawals;
• Identity verification providers: Third-party KYC and age verification service providers engaged to assist with regulatory compliance;
• Fraud prevention services: Providers of fraud detection and anti-money laundering screening tools;
• Game software providers: Licensed game developers and content providers whose games are available on the uuujl platform, to the extent necessary to deliver gameplay;
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers who process data on our behalf under strict data processing agreements;
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities where required by law or regulatory directive;
• Professional advisers: Lawyers, auditors, and accountants where necessary for the conduct of uuujl's business.

7.2 All third parties with whom uuujl shares personal data are required to handle such data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

8 Data Retention

8.1 uuujl retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

8.2 As a general rule, uuujl retains Account data for a minimum of five (5) years following the closure of your Account, in compliance with Philippine anti-money laundering regulations and PAGCOR record-keeping requirements.

8.3 Technical and usage data collected through cookies and log files is retained for shorter periods as set out in our Cookie Policy. Marketing consent records are retained for as long as you remain a registered player or until you withdraw your consent, whichever is earlier.

8.4 When personal data is no longer required, uuujl will securely delete or anonymise it in accordance with our internal data retention and disposal procedures.

9 Cookies and Tracking Technologies

9.1 The uuujl platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and collect usage analytics. A cookie is a small text file placed on your device when you visit a website.

9.2 uuujl uses the following types of cookies:

• Strictly necessary cookies: Essential for the operation of the platform, including maintaining your login session and ensuring platform security. These cannot be disabled.
• Performance and analytics cookies: Used to collect anonymised information about how players use the platform, helping us identify areas for improvement.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalise your experience.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content and measure the effectiveness of our marketing campaigns.

9.3 You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the uuujl platform. Your consent to non-essential cookies will be requested when you first visit the platform.

10 Data Security

10.1 uuujl implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the uuujl platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls ensuring that only authorised personnel can access personal data, on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for internal systems and, where available, for player Accounts;
• Incident response procedures to detect, report, and address personal data breaches promptly.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, uuujl will notify the National Privacy Commission and affected players in accordance with the requirements of the DPA and NPC Circular No. 16-03.

11 Your Data Subject Rights

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

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy;
• Right of access: You have the right to request a copy of the personal data uuujl holds about you, along with information about how it is being processed;
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe that uuujl has not handled your personal data in accordance with the DPA.

11.2 To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 14. uuujl will respond to all verified requests within thirty (30) days of receipt, in accordance with NPC guidelines.

11.3 Please note that certain rights are subject to limitations under applicable law. For example, uuujl may be required to retain certain data to comply with legal obligations even if you request its deletion.

12 Children's Privacy

12.1 The uuujl platform is strictly intended for individuals aged 21 years and above. uuujl does not knowingly collect personal data from persons under the age of 21.

12.2 If uuujl becomes 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. Any balance in such an Account will be forfeited.

12.3 If you are a parent or guardian and believe that your child has provided personal data to uuujl, please contact us immediately using the details in Section 14.

13 Changes to This Privacy Policy

13.1 uuujl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

13.2 Where changes are material, uuujl will notify registered players via the email address associated with their Account and/or by posting a prominent notice on the platform prior to the changes taking effect.

13.3 Your continued use of the uuujl platform following the effective date of any amended Privacy Policy constitutes your acknowledgement of the changes. If you do not agree to the amended Privacy Policy, you should cease using the platform and may close your Account in accordance with our Terms & Conditions.

14 Contact Our Data Protection Officer

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by uuujl, please contact our Data Protection Officer:

14.2 All email addresses displayed on this page are presented as plain text for informational purposes only. Please do not send sensitive personal or financial information via unencrypted email.

14.3 You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with our response to your privacy concern. The NPC can be reached through its official government channels.