Privacy Policy

01 Introduction

clubph ("we", "us", "our", "the Platform") operates the online gaming platform accessible at clubph.one and is committed to protecting the privacy and personal data of all registered players and website visitors. This Privacy Policy describes the types of information we collect, how that information is used, with whom it may be shared, and the rights available to you as a data subject under Philippine law.

This policy is written in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), and its Implementing Rules and Regulations. clubph is committed to upholding the principles of transparency, legitimate purpose, and proportionality in all personal data processing activities.

By accessing clubph or submitting your personal information during registration or account use, you consent to the collection and use of your data as described in this Privacy Policy.

02 Information We Collect

clubph collects personal information through several touchpoints during your use of the Platform. The categories of data collected include:

clubph does not collect full payment card numbers. All financial transaction processing involving GCash, PayMaya, BPI, BDO, or Metrobank is handled through the respective payment provider's secure infrastructure — clubph receives only transaction confirmation references and masked account identifiers.

03 How We Use Your Data

clubph uses the personal data collected from players and visitors for the following purposes:

1. Account Creation and Management — to register your clubph account, verify your identity, and maintain your player profile;
2. Service Delivery — to provide access to games, process deposits and withdrawals, and administer bonuses and promotions;
3. Identity Verification (KYC) — to comply with anti-money laundering (AML) obligations and verify that you meet the 21+ age requirement under Philippine gaming regulations;
4. Fraud Prevention and Security — to detect and prevent fraudulent activity, unauthorised account access, money laundering, and other prohibited conduct;
5. Responsible Gaming — to enforce self-exclusion orders, monitor gaming patterns for signs of problem gambling, and apply deposit or loss limits you have set;
6. Customer Support — to respond to your support enquiries and resolve disputes;
7. Marketing Communications — to send promotional offers, bonus announcements, and platform updates to players who have opted in to receive such communications (you may opt out at any time);
8. Legal and Regulatory Compliance — to meet obligations under the Data Privacy Act, PAGCOR guidelines, and any applicable anti-money laundering laws of the Philippines;
9. Platform Improvement — to analyse usage patterns, identify technical issues, and improve the overall clubph experience.

clubph does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

04 Legal Basis for Processing

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

• Contractual Necessity — processing required to register your account, provide gaming services, and process financial transactions;
• Legal Obligation — processing required to comply with PAGCOR guidelines, AML laws, and other applicable Philippine regulations;
• Legitimate Interests — processing for fraud prevention, platform security, and responsible gaming monitoring, where our interests do not override your fundamental rights;
• Consent — processing for marketing communications, where you have explicitly opted in.

Where consent is the legal basis for processing, you retain the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

05 Data Sharing

clubph may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual protections:

• Payment Processors — GCash, PayMaya (Maya), BPI, BDO, Metrobank, and other authorised payment service providers for the purpose of processing deposits and withdrawals;
• Identity Verification Providers — third-party KYC service providers used to verify government-issued IDs and confirm age eligibility;
• Game Software Providers — licensed game content providers who may receive anonymised or pseudonymised technical data to facilitate gameplay and RTP auditing;
• Regulatory Authorities — PAGCOR and other Philippine government agencies, where disclosure is required by law or regulatory directive;
• Law Enforcement — Philippine law enforcement agencies, where disclosure is required in response to a lawful request, court order, or to prevent illegal activity.

clubph does not transfer personal data outside of the Philippines to countries that do not provide an adequate level of data protection without appropriate safeguards in place.

06 Cookies & Tracking Technologies

The clubph website uses cookies and similar tracking technologies to ensure the platform functions correctly, to maintain your logged-in session, and to analyse how players use the site.

Essential cookies cannot be disabled as they are necessary for the Platform to function. You may manage functional and analytics cookies through your browser settings. Note that disabling certain cookies may affect your experience on the clubph platform.

07 Data Retention

clubph retains personal data for the period necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required by law. Specific retention periods include:

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years following account closure, as required under Philippine AML regulations;
• Financial transaction records — retained for a minimum of five (5) years from the date of each transaction;
• Responsible gaming records (including self-exclusion data) — retained for the duration of the exclusion and for two (2) years thereafter to prevent re-registration;
• Support communications — retained for two (2) years following resolution of the relevant matter;
• Technical logs — retained for twelve (12) months for security and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

08 Data Security

clubph implements industry-standard technical and organisational security 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 clubph servers;
• Encrypted storage of sensitive personal data at rest;
• Access controls limiting internal access to personal data on a strict need-to-know basis;
• Two-factor authentication options for player account access;
• Regular security audits and vulnerability assessments of clubph platform infrastructure;
• Incident response procedures for detecting, containing, and reporting personal data breaches in accordance with the Data Privacy Act's notification requirements.

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, clubph will notify the affected players and the National Privacy Commission of the Philippines within the timeframe required by the Data Privacy Act.

09 Your Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data processed by clubph:

• Right to Be Informed — the right to be notified of how your personal data is collected and processed, as described in this Privacy Policy;
• Right of Access — the right to request a copy of the personal data clubph holds about you;
• Right to Rectification — the right to request correction of inaccurate or incomplete personal data;
• Right to Erasure — the right to request deletion of your personal data, subject to clubph's legal retention obligations;
• Right to Object — the right to object to the processing of your personal data for direct marketing purposes;
• Right to Data Portability — the right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint — the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact clubph using the details provided in Section 13 of this Privacy Policy. clubph will respond to all verified data rights requests within thirty (30) days of receipt.

10 Children's Privacy

The clubph platform is strictly intended for adults aged 21 years and older in accordance with Philippine gaming regulations. clubph does not knowingly collect personal data from individuals under 21 years of age.

Where clubph has reason to believe that personal data has been collected from an individual who does not meet the minimum age requirement, the account and all associated data will be closed and deleted without notice, and any deposited funds will be returned to the payment source after deducting any administrative costs incurred.

If you believe that personal data relating to an underage individual has been submitted to clubph, please contact us immediately at the email address in Section 13.

11 Third-Party Services

The clubph platform integrates with certain third-party services to provide payment processing, game content, identity verification, and customer support functionality. Each third-party service provider operates under their own privacy policy and data processing terms. clubph requires all third-party processors to implement appropriate data protection measures consistent with the standards described in this policy.

clubph is not responsible for the privacy practices of third-party payment providers (including GCash and PayMaya) when you interact directly with their interfaces. We encourage you to review the privacy policies of GCash and PayMaya independently when authorising transactions through those services.

12 Changes to This Privacy Policy

clubph reserves the right to update this Privacy Policy at any time. Material changes to the way we collect or process your personal data will be communicated to registered players via email to the address on file and/or through a prominent notice on the clubph website prior to the changes taking effect.

The date of the most recent revision is shown at the top of this document. Your continued use of the clubph platform following notification of changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with any changes, you should cease using the Platform and request account closure.

13 Contact Us

For questions about this Privacy Policy, to exercise your data rights, or to report a privacy concern, please contact the clubph Data Protection Officer:

You also have the right to file a complaint with the National Privacy Commission of the Philippines if you believe your data rights under the Data Privacy Act have not been upheld by clubph.