Privacy Policy

01 Scope and Application

This Privacy Policy applies to all personal data collected, processed, stored, and used by hugph in connection with the operation of the hugph Casino platform, accessible at hugph.cam and all associated subdomains, mobile web interfaces, and digital services offered under the hugph brand (collectively, the "Platform").

This Policy applies to all registered players, prospective players who browse the Platform, and any other individual whose personal data hugph processes in connection with the Platform's operation, including customer support interactions, marketing communications, and regulatory compliance activities.

This Privacy Policy is to be read together with the hugph Terms & Conditions and the hugph Responsible Gaming Policy. Where any conflict exists between this Policy and another hugph document on the subject of personal data, this Privacy Policy shall prevail.

02 Data Controller Identity

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, hugph acts as the personal information controller in respect of personal data collected from players and users of the Platform.

hugph has designated a Data Protection Officer (DPO) who is responsible for overseeing the Platform's compliance with RA 10173 and this Privacy Policy, handling data subject requests, and serving as the point of contact with the National Privacy Commission. Contact details for the hugph DPO are set out in Section 14 of this Policy.

03 Personal Data We Collect

hugph collects the following categories of personal data from players and Platform users:

hugph does not collect sensitive personal information as defined under RA 10173 (such as racial or ethnic origin, political opinions, religious beliefs, health data, or sexual life) except where strictly required by applicable law — for example, health-related data provided voluntarily in connection with a responsible gaming self-exclusion request.

04 How We Collect Your Data

hugph collects personal data through the following channels and methods:

4.1 Direct Collection

You provide data directly to hugph when you register an account on the Platform, complete the KYC identity verification process, make a deposit or request a withdrawal, contact hugph customer support via live chat or email, respond to surveys or promotions, or update your account settings or responsible gaming preferences.

4.2 Automated Collection

hugph automatically collects certain technical and behavioral data when you access the Platform, including your IP address, device identifiers, browser information, pages visited, time spent on pages, game sessions opened, and click behavior within the Platform interface. This data is collected through server logs, session tracking, and cookies as described in Section 6.

4.3 Third-Party Collection

hugph receives certain data from trusted third-party service providers in connection with Platform operations, including:

• Identity verification results from KYC/AML service providers who verify the authenticity of your Philippine government-issued ID and confirm your identity against available databases.
• Payment confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, Landbank, and cryptocurrency payment processors confirming successful transaction processing.
• Fraud signal data from fraud detection and prevention service providers.
• Geolocation data derived from your IP address to verify your location during account access.

05 Purposes and Legal Bases for Processing

hugph processes your personal data for the following purposes, each supported by an applicable legal basis under the Data Privacy Act of 2012:

• Account registration and management — Necessary for the performance of the service contract between you and hugph. hugph cannot provide you with a player account without processing your registration data.
• Identity verification (KYC) — Necessary for compliance with hugph's legal obligations under Philippine AML law (RA 9160 as amended) and applicable PAGCOR licensing requirements. Consent is not the basis for KYC — it is a legal obligation.
• Processing deposits and withdrawals — Necessary for the performance of the contract with you as a player, and to fulfill the financial transaction you have requested.
• Responsible gaming monitoring — Necessary for compliance with hugph's duty-of-care obligations and regulatory requirements to protect players from gambling-related harm, including monitoring for problem gambling indicators as part of hugph's responsible gaming framework.
• Anti-money laundering monitoring — Necessary for compliance with RA 9160 (Anti-Money Laundering Act) as amended, including the obligation to monitor transactions, maintain records, and report suspicious activities to the AMLC.
• Customer support — Necessary for the performance of the service contract and hugph's legitimate interest in resolving player issues effectively.
• Platform security and fraud prevention — Necessary for hugph's legitimate interests in protecting the integrity of the Platform, detecting unauthorized access, and preventing fraud against hugph and its players.
• Marketing communications — Based on your explicit consent where you have opted in to receive promotional emails or SMS from hugph. You may withdraw this consent at any time via your account notification settings or by contacting hugph support.
• Platform analytics and improvement — Based on hugph's legitimate interests in understanding how the Platform is used in order to improve game selection, interface usability, and the overall hugph player experience for Filipino users.

06 Cookies and Tracking Technologies

hugph uses cookies and similar tracking technologies on the Platform for the following purposes:

6.1 Essential Cookies

These cookies are strictly necessary for the Platform to function. They enable session management (keeping you logged in during your casino session), security token verification, and basic Platform navigation. These cookies cannot be disabled without impairing your ability to use the hugph Platform.

6.2 Performance and Analytics Cookies

hugph uses internal analytics tools to understand aggregated Platform usage patterns — which games are most popular, how players navigate the site, and where technical performance issues may arise. This data is collected in aggregate and is not used to build individual behavioral profiles beyond what is necessary for the purposes described in Section 5.

6.3 Functional Cookies

These cookies remember your Platform preferences — such as your selected language, preferred game categories, and last login method — to provide a more personalized experience during subsequent visits.

6.4 Managing Cookies

You may adjust your browser settings to refuse or delete cookies. Note that disabling essential cookies will impair or prevent your ability to log in and use the hugph Platform. For more information on managing cookies on your mobile device or browser, consult your device or browser's help documentation.

07 Data Sharing and Disclosure

hugph does not sell, rent, or trade your personal data to any third party for commercial purposes. hugph shares personal data only in the following circumstances:

7.1 Service Providers

hugph engages carefully selected third-party service providers who process personal data on hugph's behalf under written data processing agreements that impose confidentiality, security, and data protection obligations consistent with RA 10173. These include KYC/AML verification providers, payment processing partners (GCash, PayMaya, partner banks), fraud detection providers, cloud infrastructure providers, and customer support platform providers.

7.2 Regulatory and Law Enforcement Authorities

hugph discloses personal data to Philippine regulatory and law enforcement authorities where required by applicable law or where hugph is compelled to do so by a valid legal order, court order, or regulatory direction. This includes disclosures to the Anti-Money Laundering Council (AMLC), PAGCOR, the National Privacy Commission (NPC), and the National Bureau of Investigation (NBI) or Philippine National Police (PNP) where required in connection with an investigation. hugph will notify affected players of such disclosures where legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a substantial part of hugph's business assets, personal data held by hugph may be transferred to the acquiring entity as part of that transaction. hugph will notify affected players via their registered email address of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

08 International Data Transfers

hugph's primary data processing infrastructure is located within or in close proximity to the Philippines. However, certain service providers engaged by hugph — including cloud infrastructure providers and specialist KYC/AML verification services — may process data in servers located outside the Philippines.

Where personal data is transferred outside the Philippines, hugph ensures that such transfers are made only to recipients who provide an adequate level of data protection, either through contractual provisions based on standard data protection clauses, binding corporate rules, or by virtue of the recipient country's data protection framework being recognized as adequate by the NPC or under applicable Philippine law.

Filipino players may request information about the specific safeguards applied to any international transfer of their personal data by contacting the hugph Data Protection Officer at the details set out in Section 14.

09 Data Retention

hugph retains personal data for the periods necessary to fulfill the purposes described in this Privacy Policy and to comply with hugph's legal obligations. The following general retention periods apply:

• Active account data: Retained for the duration of the player's active hugph Account plus a minimum of five (5) years after account closure, consistent with Philippine AML record-keeping requirements under RA 9160.
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of the last transaction on the account, as required by AMLC regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required under Philippine AML law and applicable PAGCOR regulations.
• Customer support communications: Retained for three (3) years from the date of the interaction, or longer where the communication relates to an open dispute or regulatory matter.
• Marketing preference data: Retained until you withdraw your marketing consent, after which hugph will suppress your details from marketing activity within a reasonable period of no more than 30 days.
• Technical and log data: Retained for a maximum of twelve (12) months from collection, except where longer retention is required in connection with a security incident or fraud investigation.

Upon expiry of applicable retention periods, hugph will securely delete or anonymize personal data in accordance with its data disposal procedures, unless retention is required or permitted by applicable Philippine law.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 (RA 10173), Filipino players registered on the hugph Platform have the following rights in respect of their personal data:

To exercise any of the above rights, please contact the hugph Data Protection Officer using the contact details in Section 14. hugph will verify your identity before processing any data subject request and will respond within fifteen (15) business days of receiving a complete and verified request, as required by NPC regulations.

Please note that certain rights are subject to limitations — for example, hugph cannot delete KYC and transaction records that it is legally required to retain under Philippine AML law, even upon request.

11 Security Measures

hugph implements the following technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction:

• Encryption in transit: All data transmitted between your device and hugph's Platform is protected by TLS 1.2 or higher (256-bit SSL encryption), equivalent to the standard used by major Philippine banks.
• Encryption at rest: Sensitive data stored on hugph's infrastructure, including KYC documents and financial account details, is encrypted at rest using industry-standard encryption protocols.
• Access controls: hugph staff access to personal data is granted on a strict need-to-know basis. All staff with access to player data undergo data privacy training and are bound by confidentiality obligations.
• Two-factor authentication: hugph accounts support SMS OTP two-factor authentication to protect against unauthorized account access.
• Vulnerability management: hugph conducts regular security assessments of its Platform infrastructure and promptly remediates identified vulnerabilities.
• Incident response: hugph maintains a documented data breach response procedure aligned with NPC notification requirements, ensuring rapid detection, containment, and notification in the event of a security incident.

12 Children's and Minors' Privacy

The hugph Platform is strictly intended for individuals who are 21 years of age or older, consistent with the minimum age requirements for gambling activities in the Philippines. hugph does not knowingly collect, process, or store personal data from individuals under the age of 21.

If hugph discovers or has reason to believe that personal data from an individual under 21 has been collected, hugph will promptly close the associated account, return any deposited funds where possible, void any winnings, and delete the personal data associated with the underage account from hugph's active systems, subject to any retention obligations under applicable law.

Parents and guardians who believe a minor has registered on the hugph Platform are encouraged to contact hugph's customer support or Data Protection Officer immediately so that the matter can be investigated and resolved without delay.

13 Changes to This Privacy Policy

hugph reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable Philippine data privacy law, NPC guidance, hugph's data processing activities, or Platform features. The Effective Date at the top of this document will be updated each time a material change is made.

Where changes to this Privacy Policy are material in nature, hugph will notify registered players via their registered email address no less than 14 days before the revised Policy takes effect. For non-material changes, updated versions will be made available on this page immediately upon publication.

Your continued use of the hugph Platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the revised Policy. If you do not agree to any revised Privacy Policy, you may close your hugph Account in accordance with the hugph Terms & Conditions.

14 Contact and Data Protection Officer Details

For all privacy-related inquiries, data subject rights requests, or concerns about hugph's data processing practices, please contact the hugph Data Protection Officer through the following channels:

• Email (DPO): [email protected] — please include "Data Privacy Request" in the subject line of your message
• Live Chat: Available 24/7 on the hugph Platform — for urgent privacy concerns or to request immediate account-level actions such as marketing opt-out
• Response Commitment: hugph will acknowledge all DPO contact requests within 3 business days and will respond fully to verified data subject requests within 15 business days as required by NPC regulations

If you are not satisfied with hugph's response to your privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC). Information on how to file an NPC complaint is published on the NPC's official website.