1 Who We Are
Unagame (referred to as "Unagame," "we," "us," or "our" throughout this policy) operates the online gaming and sports betting platform accessible at unagame.click. For the purposes of the Philippine Data Privacy Act of 2012, Unagame acts as the Personal Information Controller (PIC) for all personal data collected through the platform.
Our designated Data Privacy Officer (DPO) is responsible for overseeing compliance with this policy and applicable data protection law. You can contact the DPO directly at support@unagame.click for any privacy-related concerns.
2 Data We Collect
Unagame collects personal data from players in several ways. The type of data collected depends on how you interact with the platform.
Registration Data
When you create an Unagame account, we collect:
- Full legal name
- Date of birth
- Email address
- Mobile phone number
- Username and password (stored in encrypted form)
Verification (KYC) Data
To comply with anti-money laundering regulations and verify player identity, we may collect:
- Government-issued ID (e.g., PhilSys National ID, passport, SSS/GSIS ID, driver's licence, UMID)
- Proof of address (e.g., utility bill, bank statement)
- Selfie or photo for identity confirmation
- Payment method ownership confirmation
Transaction Data
Every deposit, withdrawal, bonus claim, and bet placed on Unagame generates a transaction record. This includes amounts in Philippine Peso (₱), timestamps, payment method references, and game or market identifiers.
Technical & Behavioural Data
Unagame automatically collects certain technical data when you use the platform, including IP address, device type and operating system, browser type, session duration, pages visited, and clickstream data. This information is used to improve platform performance, detect fraud, and personalise your experience.
Unagame does not collect sensitive personal information (such as religious beliefs, health data, or political affiliations) and has no legitimate reason to do so. If you are ever asked for this type of data by someone claiming to represent Unagame, please report it immediately.
3 How We Use Your Data
The table below summarises the primary purposes for which Unagame processes your personal data:
| Purpose |
Data Used |
Why It's Necessary |
| Account creation & management |
Registration data |
To set up and maintain your Unagame account |
| Identity verification |
KYC documents, selfie |
Legal obligation under AML/KYC regulations |
| Payment processing |
Transaction data, payment method details |
To process deposits and withdrawals in ₱ |
| Fraud & security monitoring |
Technical data, transaction history |
To protect you and the platform from abuse |
| Customer support |
Account data, communications history |
To resolve queries and complaints efficiently |
| Marketing communications |
Email, phone number |
With your explicit consent only — opt-out anytime |
| Regulatory compliance |
All relevant data categories |
To meet obligations under Philippine gaming and privacy law |
| Platform improvement |
Anonymised behavioural data |
To improve features, fix bugs, and optimise performance |
4 Legal Basis for Processing
Under the Philippine Data Privacy Act of 2012, Unagame processes your personal data on the following legal bases:
- Contractual necessity: Processing required to fulfil our obligations to you as an account holder — including running your account, processing bets, and managing payments.
- Legal obligation: Processing required to comply with Philippine law, including anti-money laundering requirements, gaming regulations, and tax obligations.
- Legitimate interests: Processing necessary to protect the security of the platform, prevent fraud, and improve our services — where these interests are not overridden by your rights.
- Consent: Processing for marketing communications and optional analytics, where you have provided explicit opt-in consent. You may withdraw this consent at any time.
Unagame shares your data only when required by law or to process your payments securely.
We Never Sell Your Data
This is a firm commitment at Unagame. Your personal information will never be sold to third parties for commercial purposes. The only sharing that takes place is strictly limited, clearly defined, and driven by necessity — not profit.
When we do share data with third-party partners (such as payment processors or KYC verification providers), we ensure those partners maintain data security standards consistent with ours and comply with applicable Philippine privacy law. We require data processing agreements with all third parties who handle your information.
5 Sharing Your Data
Unagame may share your personal data with the following categories of third parties, strictly on a need-to-know basis:
Payment Service Providers
To process deposits and withdrawals, Unagame shares relevant transaction and identity data with payment partners including GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet processors, and card network processors (Visa, Mastercard). These providers act as independent data controllers for their own processing activities.
Identity Verification Providers
KYC document verification may be conducted by a regulated third-party provider. Your ID documents and verification data are shared only for this purpose and are not retained by the provider beyond what is required for the verification process.
Regulatory & Law Enforcement Authorities
Unagame will disclose personal data to Philippine regulatory bodies (including PAGCOR and the National Privacy Commission) and law enforcement agencies when legally required to do so, or when we reasonably believe disclosure is necessary to comply with applicable law.
Technology Infrastructure Partners
Unagame uses third-party cloud infrastructure and software tools to operate the platform. Data stored on or processed by these systems is subject to strict data processing agreements and may be subject to international data transfer safeguards where applicable.
Unagame will never share your data with advertising networks, data brokers, or social media platforms for targeting or profiling purposes. If you receive unsolicited marketing claiming to be from Unagame, please contact us immediately so we can investigate.
6 Cookies & Tracking Technologies
The Unagame platform uses cookies and similar tracking technologies to provide a functional and personalised experience. Here's what each type of cookie does:
- Essential cookies: Required for basic platform functionality — such as keeping you logged in and remembering your session preferences. These cannot be disabled without affecting your ability to use the platform.
- Analytics cookies: Used to understand how players interact with the platform — page visits, session durations, feature usage. Data collected is anonymised and aggregated.
- Preference cookies: Store your language settings, display preferences, and other customisations so you don't have to reset them each visit.
- Security cookies: Help detect and prevent fraudulent activity, bot traffic, and account takeover attempts.
You can manage your cookie preferences through your browser settings. Note that disabling non-essential cookies may affect certain features of the Unagame platform.
7 Data Retention
Unagame retains your personal data for as long as your account is active and for a period thereafter as required by law or legitimate business necessity. Key retention periods are as follows:
- Account and transaction records: Retained for a minimum of 5 years after account closure to comply with anti-money laundering regulations.
- KYC documents: Retained for the duration of the account plus 5 years, unless a longer period is required by applicable regulation.
- Customer support communications: Retained for 3 years from the date of the interaction.
- Marketing preferences and consent records: Retained until you withdraw consent or close your account, plus 1 year for audit purposes.
- Technical / behavioural logs: Retained in anonymised or aggregated form for up to 2 years for analytics purposes.
When data is no longer required, it is securely deleted or anonymised in accordance with industry best practices.
8 Security Measures
Unagame implements a layered security approach to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Our measures include:
- TLS/SSL encryption for all data transmitted between your device and Unagame servers.
- AES-256 encryption for sensitive data stored at rest, including payment details and identity documents.
- Role-based access controls — only authorised Unagame staff with a specific need can access your personal data.
- Two-factor authentication (2FA) available for all player accounts to prevent unauthorised login.
- Regular security audits and penetration testing to identify and address vulnerabilities before they can be exploited.
- Incident response procedures — in the unlikely event of a data breach, Unagame will notify affected players and the National Privacy Commission within the timeframes required by law.
While Unagame maintains rigorous security standards, no online platform is completely immune to risk. You play an important part in keeping your account secure by using a strong, unique password and enabling 2FA.
9 Your Rights Under the DPA
As a data subject under Republic Act 10173, you have the following rights regarding your personal data held by Unagame:
