clubph Privacy Policy

1Introduction & Scope

1.1 This Privacy Policy is issued by clubph ("clubph", "we", "us", "our") and applies to all personal data collected, processed, stored, and used in connection with your registration, access, and use of the clubph online gaming platform accessible at clubph.win ("the Platform").

1.2 clubph is committed to protecting the privacy and personal data of all players, visitors, and other individuals who interact with the Platform. This commitment reflects our obligations under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

1.3 This Privacy Policy should be read in conjunction with the clubph Terms & Conditions, which govern your overall use of the Platform. By registering a clubph account, you acknowledge that you have read, understood, and consented to the data practices described in this Privacy Policy.

1.4 This policy applies to data collected through the clubph website, mobile browser interface, live chat support, email communications, and any other channel through which you interact with clubph.

2Data Controller

2.1 For the purposes of the Philippine Data Privacy Act of 2012, clubph (operating at clubph.win) is the Data Controller responsible for personal data collected from users of the Platform.

2.2 As Data Controller, clubph determines the purposes and means of processing your personal data. Where clubph engages third-party service providers to process personal data on its behalf, those parties act as Data Processors and are contractually bound to process data only in accordance with clubph's instructions and applicable data protection law.

2.3 For any data protection queries or to exercise your rights under this policy, contact our Data Protection Officer (DPO) via the support channels described in Section 16 of this policy.

3Categories of Personal Data We Collect

clubph collects the following categories of personal data:

3.1 Identity Data

3.2 Contact Data

3.3 Financial Data

3.4 Account & Activity Data

3.5 Technical Data

3.6 Communications Data

3.7 Sensitive Personal Information

Under the Philippine Data Privacy Act, certain data is classified as Sensitive Personal Information (SPI). clubph processes SPI only as strictly necessary: government ID numbers are collected for KYC and AML compliance; financial account details are collected for payment processing. Such data is subject to heightened security controls.

4How We Collect Personal Data

clubph collects personal data through the following means:

• Direct Registration: Information you provide when creating a clubph account, including name, date of birth, contact details, and chosen credentials.
• KYC Verification: Documents and photographs you submit in response to identity verification requests, processed via clubph's KYC service providers.
• Deposits & Transactions: Payment reference data generated when you make deposits via GCash, PayMaya, BPI, BDO, Metrobank, or 7-Eleven.
• Platform Usage: Activity data generated automatically as you navigate, play games, place bets, and interact with the Platform.
• Cookies & Tracking Technologies: Technical data collected via cookies and similar technologies as described in Section 10.
• Support Interactions: Data shared by you when contacting clubph support via live chat or email.
• Third-Party Verification: Data received from KYC service providers or fraud detection systems that cross-reference the identity information you submit.

5Purposes of Processing & Legal Basis

The table below sets out the purposes for which clubph processes your personal data and the legal basis for each processing activity under the Philippine Data Privacy Act of 2012:

6Data Sharing & Disclosure

6.1 clubph does not sell, rent, or trade your personal data to any third party for commercial purposes.

6.2 We may share your personal data with the following categories of recipients, strictly as necessary:

• PAGCOR and Regulatory Authorities: As required by our gaming license conditions and applicable Philippine law, including mandatory reporting obligations under AML legislation.
• National Privacy Commission (NPC): In response to lawful requests or as required under the Philippine Data Privacy Act of 2012.
• KYC & Identity Verification Providers: Third-party service providers contracted to perform identity document verification and liveness checks on clubph's behalf.
• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to the extent necessary to process your deposits and withdrawals.
• Fraud Detection & Security Services: Third-party providers of fraud monitoring, risk assessment, and cybersecurity services engaged to protect the Platform and its users.
• Legal and Professional Advisers: Where necessary to obtain legal advice or to defend, establish, or exercise legal claims.
• Law Enforcement: Where required by Philippine law or court order to disclose information to law enforcement or government authorities.

6.3 All third-party Data Processors engaged by clubph are contractually required to implement appropriate technical and organizational security measures and to process personal data only on clubph's documented instructions.

7Data Security

7.1 clubph implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, loss, disclosure, alteration, or destruction. These measures include:

• SSL Encryption: All data in transit between your device and the clubph platform is encrypted via Transport Layer Security (TLS/SSL);
• Encrypted Storage: Personal data and sensitive financial information stored in clubph databases is encrypted at rest using industry-standard encryption protocols;
• Access Controls: Access to personal data is restricted to authorized clubph personnel on a strict need-to-know basis, governed by role-based access control policies;
• Session Security: User sessions are secured with tokens and are subject to automatic expiry after defined inactivity periods;
• Security Monitoring: clubph employs continuous security monitoring, intrusion detection systems, and periodic security assessments to identify and address vulnerabilities;
• Staff Training: All clubph staff with access to personal data receive regular data protection and security training.

7.2 In the event of a personal data breach that poses a risk to your rights and freedoms, clubph will notify the National Privacy Commission (NPC) as required by the Philippine Data Privacy Act, and will notify affected individuals without undue delay where required.

7.3 While clubph implements robust security measures, no internet-based system is entirely immune to security risks. You are responsible for maintaining the confidentiality of your account login credentials and for reporting any unauthorized account access to clubph immediately.

8Data Retention

8.1 clubph retains personal data for as long as is necessary to fulfil the purposes for which it was collected, and for as long as required by applicable Philippine law and regulatory obligations.

8.2 The following general retention principles apply:

• Active Accounts: Personal data associated with an active clubph account is retained for the duration of the account's active status.
• Closed Accounts: Following account closure, clubph retains account data and transaction records for a minimum of five (5) years, as required under Philippine AML legislation and PAGCOR licensing conditions.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years from the date of the last transaction or account closure, whichever is later.
• Communications Records: Support communications are retained for three (3) years from the date of the last interaction, unless a longer retention period is required by an active dispute or legal proceeding.
• Technical Logs: Server logs and technical activity data are retained for up to twelve (12) months, after which they are either deleted or anonymised.

8.3 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be associated with any identifiable individual.

9Your Data Protection Rights

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

To exercise any of the above rights, contact clubph via live chat or at the email address listed in Section 16. Requests will be acknowledged within five (5) business days and responded to within thirty (30) days. In complex cases, this period may be extended by a further thirty (30) days with notification.

10Cookies & Tracking Technologies

10.1 clubph uses cookies and similar tracking technologies on the Platform to support platform functionality, performance, and security. A cookie is a small text file stored on your device by your browser when you visit the Platform.

10.2 clubph uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during your visit. These cannot be disabled without impairing your ability to use the Platform.
• Performance Cookies: Collect aggregated, anonymised data about how players use the Platform, used to identify technical issues and improve performance. No individual user is identifiable from this data.
• Functional Cookies: Remember your preferences (such as language settings, game layout preferences, and responsible gaming limits) to improve your experience across sessions.
• Security Cookies: Support fraud detection and session security functions, helping to identify unusual access patterns that may indicate unauthorized account access.

10.3 clubph does not deploy third-party advertising or tracking cookies that share your data with commercial advertising networks.

10.4 You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to log in and use the Platform.

11Minors

11.1 The clubph Platform is strictly restricted to individuals aged 21 years and above. clubph does not knowingly collect personal data from individuals under the age of 21.

11.2 Age is verified as part of the mandatory KYC process. Any account found to have been registered by an individual below the age of 21 will be immediately terminated and all data associated with that account will be deleted, subject to any legal retention obligations that may apply.

11.3 If you have reason to believe that a minor has registered a clubph account, please contact us immediately via the support channels in Section 16.

12Third-Party Links

12.1 The clubph Platform may contain references to third-party service providers (such as GCash and PayMaya) in the context of payment methods. If you navigate to any third-party platform or application, that platform's own privacy policy governs the handling of your data from the point of transfer. clubph is not responsible for the privacy practices of third-party platforms.

12.2 We recommend reviewing the privacy policies of any third-party services you use in connection with your clubph account, particularly your chosen payment providers.

13Cross-Border Data Transfers

13.1 Some of the third-party service providers used by clubph — including KYC verification providers, cloud infrastructure providers, and game content providers — may be located or process data outside the Philippines.

13.2 Where personal data is transferred to a jurisdiction outside the Philippines, clubph ensures that appropriate safeguards are in place to protect that data to a standard at least equivalent to that required under the Philippine Data Privacy Act of 2012. These safeguards include contractual data processing agreements incorporating standard data protection clauses.

13.3 By using the clubph Platform, you acknowledge and consent to the transfer of your personal data to third-party service providers outside the Philippines where such transfers are necessary for the operation of the Platform and are subject to appropriate safeguards.

14Automated Decision-Making

14.1 clubph may use automated processes in the following contexts:

• Fraud Detection: Automated systems analyse account and transaction patterns to identify potentially fraudulent activity. Accounts flagged by these systems are subject to human review before any enforcement action is taken.
• Responsible Gaming Monitoring: Automated analysis of gameplay patterns may trigger responsible gaming interventions (such as prompts to set deposit limits) where patterns indicate elevated risk. These interventions support, but do not replace, human oversight by the clubph responsible gaming team.
• AML Transaction Monitoring: Automated screening of transactions against regulatory thresholds. Transactions meeting defined criteria are escalated for human review and, where required, reported to relevant authorities.

14.2 clubph does not make decisions that produce legal effects or similarly significant effects on individuals based solely on automated processing without human review where such effects are material.

15Policy Amendments

15.1 clubph reserves the right to amend this Privacy Policy at any time. Changes will take effect upon publication of the revised policy at clubph.win/privacy-policy. The "Last Reviewed" date at the top of this policy will be updated accordingly.

15.2 Where changes are material, clubph will endeavour to notify registered players via email or a prominent platform notice in advance of the changes taking effect.

15.3 Your continued use of the Platform following the effective date of any amended Privacy Policy constitutes your acceptance of the revised policy. If you do not accept the amended policy, you should cease using the Platform and close your account.

16Contact & Complaints

For any questions, requests, or concerns relating to this Privacy Policy or the processing of your personal data by clubph, please contact us using the following channels: