Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by uujili ("uujili," "we," "us," or "our"), the operator of the online gaming platform accessible at uujili.app ("Platform"). This Policy describes how uujili collects, uses, stores, shares, and protects the personal data of individuals ("you," "your," or "Data Subject") who access or use the Platform.

uujili is committed to protecting the privacy and security of your personal data in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and all relevant issuances of the National Privacy Commission ("NPC") of the Philippines.

By registering for or using the uujili Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

2. Personal Data We Collect

uujili collects the following categories of personal data in connection with your use of the Platform:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — players must be 21 years or older)
• Nationality and country of residence
• Registered mobile number and email address
• Residential address (province, city, barangay, ZIP code)

2.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., PhilSys ID, passport, driver's license, SSS/GSIS ID, Voter's ID)
• Proof of address documents
• Selfie or liveness verification image where required
• Proof of payment method ownership (e.g., screenshot of GCash or bank account in your name)

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references
• GCash or PayMaya account reference numbers (not full credentials)
• Bank account details used for transfers (account name and last four digits only)
• Bonus and promotional credit history

2.4 Gaming Activity Data

• Game session logs, including games played, wager amounts, outcomes, and session duration
• Responsible gaming tool usage (deposit limits set, cooling-off periods activated, self-exclusion requests)
• Bonus wagering progress and promotional participation history

2.5 Technical & Device Data

• IP address and approximate geolocation (city/region level)
• Device type, operating system, and browser version
• Session identifiers and authentication tokens
• Platform interaction logs (pages visited, features used, error reports)

2.6 Communications Data

• Records of your communications with uujili customer support
• Feedback, complaints, and dispute correspondence
• Marketing preference settings and communication opt-in/opt-out records

3. How We Collect Your Data

uujili collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or update your account settings.
• Automatically: Through cookies, session tokens, and server logs when you access and interact with the Platform.
• From third parties: From identity verification service providers, payment processors (GCash, PayMaya, Philippine banks), fraud detection services, and PAGCOR-mandated reporting systems, where applicable.

4. How We Use Your Personal Data

uujili processes your personal data for the following purposes:

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to fulfill our obligations under the Terms and Conditions you agreed to upon registration, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, including the Anti-Money Laundering Act (RA 9160 as amended), PAGCOR regulations, and NPC data privacy requirements.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregate analytics, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

uujili does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

6.1 Service Providers

Third-party companies that assist uujili in operating the Platform, including identity verification providers, payment processors (GCash, PayMaya, Philippine banks), cloud hosting providers, customer support platforms, and fraud detection services. All service providers are contractually bound to process your data only on uujili's instructions and in compliance with the DPA.

6.2 Regulatory Authorities

Philippine government agencies and regulators where disclosure is required by law, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies acting under valid legal process.

6.3 Game Content Providers

Licensed game software providers (such as live dealer and slot game studios) may receive limited technical session data necessary to deliver their games. These providers do not receive your full identity or financial data.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of uujili's assets, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.

7. Cookies and Tracking Technologies

uujili uses cookies and similar technologies to operate and improve the Platform. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, responsible gaming limits display, and last-visited game categories. These improve your experience but are not essential.
• Analytics Cookies: Collect aggregated, anonymized data about how players use the Platform (e.g., most-visited pages, session duration). This data is used solely to improve uujili's services and is never linked back to individual identities.

uujili does not use advertising cookies, cross-site tracking cookies, or any third-party marketing pixels. You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the Platform.

8. Data Retention

uujili retains your personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following minimum retention periods required by Philippine law:

• Account and KYC data: Retained for a minimum of five (5) years from account closure, as required by AMLC regulations and PAGCOR record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of each session.
• Customer support communications: Retained for three (3) years from the date of the last communication.
• Marketing consent records: Retained for the duration of your account plus three (3) years, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC-recommended data disposal procedures.

9. Data Security

uujili implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption in transit: All data transmitted between your device and uujili's servers is encrypted using TLS 1.2 or higher (256-bit SSL).
• Encryption at rest: Sensitive personal data stored in uujili's databases is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data is restricted to uujili personnel and service providers who require it to perform their functions, on a strict need-to-know basis. All access is logged and audited.
• Multi-factor authentication: Administrative access to systems containing personal data requires multi-factor authentication.
• Regular security assessments: uujili conducts periodic vulnerability assessments and penetration testing of its Platform infrastructure.
• Incident response: uujili maintains a data breach response plan. In the event of a personal data breach that poses a real risk of serious harm, uujili will notify the NPC within 72 hours and affected data subjects without undue delay, as required by the DPA.

10. Your Data Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by uujili:

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 13. uujili will respond to all verified data subject requests within fifteen (15) business days of receipt, as required by the DPA IRR.

11. Children's Privacy and Age Restriction

The uujili Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations applicable to casino-style gambling. uujili does not knowingly collect personal data from individuals under the age of 21.

Age verification is a mandatory step in the uujili registration and KYC process. If uujili discovers that personal data has been collected from a person under 21 years of age, such data will be deleted immediately and the associated account will be permanently closed. Any funds deposited by an underage user will be returned to the originating payment method after verification.

If you believe that a minor has registered on the uujili Platform, please contact us immediately at the details provided in Section 13.

12. Changes to This Privacy Policy

uujili 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. Material changes will be communicated to registered players via the mobile number or email address on file, or by prominent notice on the Platform, at least seven (7) days prior to the effective date of the change.

The "Effective Date" at the top of this Policy indicates when the current version took effect. We encourage you to review this Policy periodically. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

13. Contact & Data Protection Officer

uujili has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Policy. If you have any questions, concerns, or requests regarding your personal data or this Policy, please contact our DPO:

• Data Protection Officer, uujili
• Email: [email protected]
• General Support: [email protected]
• Response Time: Within 15 business days for data subject requests; within 3 business days for general privacy inquiries

If you are not satisfied with uujili's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at [email protected] or through the NPC's official website.