clubph Privacy Policy

1. Who We Are

clubph is a PAGCOR-regulated online gaming platform operating at clubph.asia and serving adult Filipino players across the Philippines. In the context of this Privacy Policy, clubph is the Data Controller responsible for the personal data you provide when registering and using the platform. Our designated Data Protection Officer can be contacted at the address provided in Section 14 of this policy.

2. Personal Data We Collect

clubph collects the following categories of personal data:

• Identity Data: Full legal name, date of birth, nationality, government-issued ID type and number (e.g., PhilSys National ID, UMID, Passport, Driver's License, Voter's ID, SSS/GSIS ID).
• Contact Data: Philippine mobile number, email address, residential address in the Philippines.
• Account Data: Username, encrypted password, account registration date, login history, and session information.
• Financial Data: GCash number, Maya account details, bank account numbers (BPI, BDO, Metrobank, UnionBank), deposit and withdrawal transaction history, and PHP balance records.
• Gaming Data: Game play history, wager amounts, winnings and losses, bonus usage, sports betting history, and session duration.
• Technical Data: IP address, device type, operating system, browser type, and geolocation data (country/region level) to verify that access originates from the Philippines.
• Communications Data: Records of your interactions with clubph customer support, including live chat transcripts, emails, and support ticket history.

3. How We Collect Personal Data

clubph collects personal data through the following means:

• Direct submission: Information you provide during account registration, KYC verification, deposit and withdrawal forms, and support interactions.
• Automated collection: Technical data collected automatically when you access the platform, including through cookies and server logs.
• Third-party payment providers: Transaction confirmation data from GCash, Maya, and banking partners, necessary to process deposits and withdrawals.
• Regulatory sources: Data received from PAGCOR or law enforcement agencies in the context of regulatory compliance obligations.

4. How We Use Your Personal Data

clubph uses your personal data for the following purposes:

• To create, maintain, verify, and manage your clubph account;
• To process deposits and withdrawals in Philippine Peso via your selected payment method;
• To verify your age (21+) and identity as required by PAGCOR regulations and Philippine law;
• To comply with Anti-Money Laundering Act (AMLA) obligations, including transaction monitoring and suspicious activity reporting;
• To personalise your gaming experience — including game recommendations and relevant promotional offers;
• To provide customer support and respond to your enquiries;
• To detect and prevent fraud, account abuse, and prohibited conduct as defined in the clubph Terms & Conditions;
• To send you service communications (account notifications, security alerts, and transaction confirmations);
• To send promotional communications, where you have consented or where permitted by applicable law, and subject to your right to opt out at any time;
• To comply with our obligations to PAGCOR and other regulatory bodies.

5. Legal Basis for Processing

clubph processes your personal data on the following legal bases under the Data Privacy Act of 2012 (RA 10173):

• Contractual necessity: Processing required to provide you with the clubph service under the account agreement you enter upon registration;
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, tax reporting requirements, and other applicable Philippine laws;
• Consent: Processing for marketing communications and optional features, where your explicit consent has been obtained;
• Legitimate interests: Processing for fraud prevention, security, and platform improvement, where these interests are not overridden by your data protection rights.

6. Data Sharing & Third-Party Disclosure

clubph does not sell your personal data. We share data only in the following circumstances:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other payment service providers receive only the transaction data necessary to process your deposits and withdrawals;
• Game providers: Third-party gaming providers receive your account identifier and session data necessary to deliver game services. They do not receive your full identity or financial data;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies, as required by Philippine law;
• KYC/identity verification providers: Third-party identity verification services that assist in confirming your identity and age during the KYC process;
• Customer support platforms: Secure, contracted platforms used to manage live chat and support ticket interactions.

All third-party recipients of your data are bound by contractual confidentiality obligations consistent with RA 10173.

7. Cookies & Tracking Technologies

clubph uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies used include:

• Strictly necessary cookies: Required for the platform to function, including maintaining your login session and processing transactions. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and game lobby filters.
• Analytics cookies: Collect anonymised data about how Members use the platform to help clubph improve the user experience. No personally identifiable information is included in analytics data.

You may manage non-essential cookies through your browser settings. Disabling strictly necessary cookies will impair platform functionality including account access.

8. Data Retention

clubph retains personal data for the following periods:

• Active accounts: For the full duration of your account with clubph, plus five (5) years after account closure, as required by PAGCOR regulations and AMLA record-keeping obligations.
• KYC documents: Retained for five (5) years from the date of verification or from account closure, whichever is later.
• Transaction records: Retained for five (5) years in accordance with AMLA requirements.
• Support communications: Retained for two (2) years after the close of each support interaction.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised.

9. Security Measures

clubph implements the following technical and organisational measures to protect your personal data:

• 256-bit SSL/TLS encryption for all data in transit;
• Encryption of sensitive data fields (passwords, financial data, ID document images) at rest;
• Role-based access controls limiting staff access to personal data to those with a legitimate operational need;
• Regular security audits and penetration testing of the platform;
• Two-factor authentication available on all Member accounts;
• Secure data centres with physical access controls located within or serving the Philippines.

No security measure is infallible. Members are encouraged to use strong unique passwords and enable two-factor authentication to further protect their clubph accounts.

10. Your Data Rights Under RA 10173

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

• Right to be informed: The right to know what personal data clubph holds about you and how it is used — as set out in this Privacy Policy.
• Right to access: The right to request a copy of the personal data clubph holds about you.
• Right to correction: The right to have inaccurate or incomplete personal data corrected.
• Right to erasure: The right to request deletion of your personal data, subject to clubph's legal retention obligations under PAGCOR regulations and AMLA.
• Right to object: The right to object to processing of your personal data for direct marketing purposes at any time.
• 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 file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, contact the clubph Data Protection Officer using the details in Section 14. Requests will be responded to within 15 business days.

11. Children's Privacy

clubph is strictly an adult platform. We do not knowingly collect, process, or store personal data of individuals under the age of 21. If we become aware that personal data has been submitted by or on behalf of an individual under 21, that data will be immediately deleted and the associated account closed. If you believe a minor has registered on clubph, contact our support team immediately.

12. Cross-Border Data Transfers

Where personal data is transferred to or processed by service providers located outside the Philippines (for example, internationally hosted game providers or cloud infrastructure), clubph ensures that such transfers are made only to recipients that provide an adequate level of data protection consistent with RA 10173 requirements, through contractual data processing agreements incorporating the applicable data protection standards.

13. Updates to This Privacy Policy

clubph may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or regulatory guidance. Material updates will be communicated to Members via email or platform notification prior to taking effect. The effective date at the top of this page will be updated accordingly. Continued use of clubph after the effective date of any update constitutes acceptance of the revised policy.

14. Contact & Data Protection Officer

For data rights requests, privacy enquiries, or concerns about this Privacy Policy, you may contact the clubph Data Protection Officer at: [email protected]

Please include "Privacy Request" or "DPO Enquiry" in the subject line of your email. All privacy-related requests are handled by the DPO within 15 business days. For urgent security concerns, 24/7 live chat support is available on the clubph platform.

Complaints that cannot be resolved directly with clubph may be escalated to the National Privacy Commission (NPC) of the Philippines.