01
Introduction
This Privacy Policy ("Policy") describes how starhk ("we," "us," or "our") collects, uses, stores, shares, and protects the personal data of individuals ("you," "the Player," or "the User") who access or use the starhk online casino platform available at starhk.app and its associated subdomains and mobile interfaces.
starhk is committed to protecting the privacy and personal data of all its players, particularly those based in the Philippines. This Policy is designed to comply with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.
This Policy should be read together with the starhk Terms & Conditions, which govern your use of the platform. In the event of any conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.
If you have questions about this Privacy Policy or wish to exercise your data rights, please contact our Data Protection Officer at
[email protected].
02
Personal Data We Collect
starhk collects the following categories of personal data from players and platform visitors. The specific data collected depends on how you interact with the platform:
| Category |
Examples |
When Collected |
| Identity Data |
Full name, date of birth, government ID number, nationality |
Registration & KYC verification |
| Contact Data |
Email address, mobile number, residential address |
Registration & account updates |
| Financial Data |
GCash number, PayMaya account, BPI/BDO/Metrobank account details, transaction history |
Deposits, withdrawals & payment verification |
| Gaming Data |
Game history, wager amounts, win/loss records, session duration, bonus usage |
During platform use |
| Technical Data |
IP address, device type, browser type, operating system, cookies, session tokens |
Automatically on platform access |
| Communications Data |
Support chat logs, email correspondence, feedback submissions |
When you contact starhk support |
| Verification Documents |
Scanned copies of Philippine passport, driver's license, SSS/UMID card, proof of address |
KYC & withdrawal verification |
starhk does not intentionally collect sensitive personal information as defined under the Philippine Data Privacy Act (such as health data, religious beliefs, or political affiliations) unless specifically required for regulatory compliance purposes, in which case you will be notified and your explicit consent will be obtained.
03
How We Collect Your Data
starhk collects personal data through the following means:
- Direct collection: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
- Automated collection: Technical data collected automatically when you access the starhk platform, including through cookies, web beacons, log files, and similar tracking technologies. See Section 7 for more details on cookies.
- Third-party sources: Data received from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank) to verify transactions; identity verification service providers used for KYC compliance; and fraud prevention and anti-money laundering screening services.
- Publicly available sources: In limited circumstances, starhk may verify information against publicly available records for fraud prevention or regulatory compliance purposes.
04
How We Use Your Personal Data
starhk uses the personal data it collects for the following specific purposes:
- Account management: To create, maintain, and manage your starhk player account, including verifying your identity and age (21+ requirement) during registration.
- Transaction processing: To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP) via your chosen payment method.
- Regulatory compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations under the Anti-Money Laundering Act (AMLA), know-your-customer (KYC) requirements, and any directives from PAGCOR or other competent Philippine authorities.
- Platform operation and improvement: To operate, maintain, and improve the starhk platform, including personalizing your gaming experience, analyzing usage patterns, and developing new features.
- Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
- Security and fraud prevention: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other illegal or prohibited activities on the platform.
- Responsible gaming: To monitor gaming behavior and apply responsible gaming tools such as deposit limits, session reminders, and self-exclusion where appropriate or requested.
- Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent to receive such communications. You may withdraw this consent at any time.
- Legal proceedings: To establish, exercise, or defend legal claims in connection with your use of the starhk platform.
Purpose Limitation: starhk will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable Philippine law.
05
Legal Basis for Processing
Under the Philippine Data Privacy Act of 2012, starhk processes your personal data on the following legal bases:
- Contractual necessity: Processing is necessary to perform the contract between you and starhk — specifically, to provide you with access to the starhk gaming platform, process your transactions, and manage your account.
- Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML/KYC obligations, tax reporting requirements, and regulatory directives from PAGCOR and the National Privacy Commission.
- Legitimate interests: Processing is necessary for starhk's legitimate business interests, including fraud prevention, platform security, and improving the quality of our services — provided that these interests are not overridden by your rights and interests.
- Consent: For certain processing activities — particularly marketing communications and the use of non-essential cookies — starhk relies on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.
06
Data Sharing & Disclosure
starhk does not sell, rent, or trade your personal data to third parties. We share your data only in the following limited circumstances:
- Service providers: Trusted third-party vendors who assist in operating the starhk platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, customer support platforms, and analytics providers. These providers are contractually bound to process your data only on starhk's instructions and in accordance with applicable data protection law.
- Regulatory and law enforcement authorities: Philippine government agencies, including the Anti-Money Laundering Council (AMLC), PAGCOR, the National Privacy Commission (NPC), and law enforcement authorities, where disclosure is required by law, court order, or regulatory directive.
- Fraud prevention and security: Third-party fraud prevention and security screening services used to protect the integrity of the starhk platform and its players.
- Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of starhk's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.
- With your consent: In any other circumstances where you have given your explicit consent to the sharing of your data with a specific third party.
No Cross-Border Transfers Without Safeguards: starhk does not transfer your personal data outside the Philippines unless adequate data protection safeguards are in place, as required by the Philippine Data Privacy Act and NPC regulations.
07
Cookies & Tracking Technologies
starhk uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file placed on your device when you visit the starhk website. The following types of cookies are used:
- Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
- Functional cookies: Remember your preferences such as language settings, display preferences, and responsible gaming tool configurations to provide a more personalized experience.
- Analytics cookies: Collect anonymized data about how players use the starhk platform — such as which pages are visited most frequently and how long sessions last — to help us improve the platform. These are only placed with your consent.
- Marketing cookies: Used to deliver relevant promotional content and track the effectiveness of starhk's marketing campaigns. These are only placed with your explicit consent.
You can manage your cookie preferences through your browser settings or through the starhk cookie preference center. Please note that disabling certain cookies may affect the functionality of the platform.
08
Data Security
starhk implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:
- TLS/SSL encryption for all data transmitted between your device and the starhk platform.
- Encryption at rest for sensitive data including passwords (stored as salted hashes), payment details, and identity documents.
- Access controls: Personal data is accessible only to starhk personnel and service providers who have a legitimate need to access it for the purposes described in this Policy. Access is governed by role-based permissions and is regularly reviewed.
- Two-factor authentication (2FA) available for all player accounts to prevent unauthorized access.
- Regular security audits and penetration testing of the starhk platform infrastructure.
- Incident response procedures: starhk maintains documented procedures for responding to personal data breaches, including notification to the National Privacy Commission and affected data subjects within the timeframes required by Philippine law.
While starhk takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials. Please refer to Section 3 of the starhk Terms & Conditions for your account security obligations.
Data Breach Notification: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, starhk will notify you and the National Privacy Commission of the Philippines within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.
09
Data Retention
starhk retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:
| Data Category |
Retention Period |
Basis |
| Account & Identity Data |
Duration of account + 5 years after closure |
AML/KYC regulatory requirement |
| Financial Transaction Data |
10 years from transaction date |
Philippine AMLA & tax law |
| Gaming History |
5 years from account closure |
Regulatory compliance & dispute resolution |
| Support Communications |
3 years from last interaction |
Legitimate interest (dispute resolution) |
| Marketing Preferences |
Until consent is withdrawn |
Consent |
| Technical / Log Data |
12 months |
Security & fraud prevention |
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with any individual. Where data must be retained for legal or regulatory reasons beyond the standard period, it will be stored securely and access will be restricted to authorized personnel only.
10
Your Data Rights
Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by starhk:
- Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
- Right of access: You have the right to request a copy of the personal data starhk 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 starhk holds about you. You can update most account information directly through your starhk account settings.
- 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 starhk's legal and regulatory retention obligations.
- Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to starhk's overriding legitimate grounds.
- Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
- Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
- Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that starhk has violated your data privacy rights.
To exercise any of these rights, please contact the starhk Data Protection Officer at [email protected]. starhk will respond to all data rights requests within 30 calendar days of receipt, as required by Philippine law. In complex cases, this period may be extended by a further 30 days, in which case you will be notified of the extension and the reason for it.
Identity Verification for Data Requests: To protect your privacy, starhk will verify your identity before processing any data rights request. You may be asked to provide a copy of a government-issued ID to confirm that the request is being made by the account holder.
11
Children & Minors
The starhk platform is strictly intended for adults aged 21 years and above, in accordance with applicable Philippine online gaming regulations. starhk does not knowingly collect personal data from any person under the age of 21.
If starhk becomes aware that personal data has been collected from a person under the age of 21, the relevant account will be immediately closed, all data will be deleted (subject to any mandatory regulatory retention obligations), and any funds deposited will be returned to the payment source.
If you are a parent or guardian and believe that a minor in your care has registered on the starhk platform, please contact the starhk support team immediately at [email protected] so that the matter can be investigated and resolved promptly.
21+ Age Requirement: starhk conducts mandatory age verification for all accounts. Providing false information about your age during registration is a violation of the starhk Terms & Conditions and may constitute a criminal offence under applicable Philippine law.
12
Marketing Communications
starhk may send you promotional emails, SMS messages, and in-platform notifications about bonuses, new games, special events, and other starhk offers — but only where you have given your explicit consent to receive such communications during registration or at a later date.
You can withdraw your consent to receive marketing communications at any time by:
- Clicking the "unsubscribe" link in any marketing email from starhk.
- Updating your communication preferences in your starhk account settings.
- Contacting the starhk support team at [email protected] and requesting to be removed from marketing lists.
Please note that withdrawing consent for marketing communications does not affect your receipt of transactional communications — such as deposit confirmations, withdrawal notifications, account security alerts, and support responses — which are sent as part of the starhk service and cannot be opted out of while your account is active.
13
Third-Party Links
The starhk platform may contain links to third-party websites or services, such as payment provider portals. starhk is not responsible for the privacy practices of any third-party website or service. This Privacy Policy applies solely to the starhk platform at starhk.app and its associated subdomains.
We encourage you to review the privacy policies of any third-party services you access through or in connection with the starhk platform, particularly those of your chosen payment providers (GCash, PayMaya, BPI, BDO, Metrobank), as their data handling practices are governed by their own policies and not by this document.
14
Updates to This Privacy Policy
starhk 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 regulatory requirements. When we make material changes to this Policy, we will notify you by:
- Posting a prominent notice on the starhk platform homepage and login page.
- Sending an email notification to the address registered on your starhk account.
- Updating the "Effective Date" at the top of this Privacy Policy.
Your continued use of the starhk platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated Policy, you should stop using the platform and may request account closure by contacting the starhk support team.
We recommend that you review this Privacy Policy periodically to stay informed about how starhk protects your personal data. Previous versions of this Policy are available upon request by contacting our Data Protection Officer.
15
Contact & Data Protection Officer
starhk has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012 and NPC Circular 17-01. The DPO is responsible for overseeing starhk's compliance with applicable data protection law and serving as the primary point of contact for data subjects and the National Privacy Commission.
If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by starhk, please contact the Data Protection Officer using the details below:
Data Protection Officer
starhk DPO Office
Response Time
Within 30 calendar days
You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe that starhk has not handled your personal data in accordance with the Philippine Data Privacy Act of 2012. The NPC can be reached through its official website at privacy.gov.ph.
Our Commitment: starhk takes all privacy complaints seriously. Every complaint received by the DPO will be acknowledged within 5 business days and investigated thoroughly. We are committed to resolving all data privacy concerns fairly and transparently, in accordance with Philippine law.