Privacy Policy

1 Introduction

1.1 clubphp.com is committed to protecting the privacy and personal data of every Filipino player who uses our platform. We understand that trust is the foundation of any good relationship — and that trust starts with being completely transparent about how we handle your information.

1.2 This Policy applies to all personal data collected through the clubphp.com website, mobile application, customer support channels, and any other touchpoint through which you interact with us. It applies to all registered players, visitors, and prospective users of the Platform.

1.3 By registering an account or using the clubphp.com Platform, you acknowledge that you have read and understood this Privacy 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.

1.4 This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, which together form the complete framework governing your use of clubphp.com.

2 Personal Data We Collect

2.1 clubphp.com collects the following categories of personal data from players and users:

2.2 Sensitive Personal Information. Where required for identity verification or regulatory compliance, clubphp.com may collect sensitive personal information as defined under the Philippine Data Privacy Act, including government ID numbers. Such data is handled with the highest level of care and is subject to additional security controls.

2.3 Voluntary Provision. You are not legally obligated to provide your personal data to clubphp.com. However, certain data is necessary for the provision of our services. Failure to provide required data may prevent you from registering an account or accessing specific features of the Platform.

3 How We Collect Your Data

3.1 clubphp.com collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated technologies: Data collected automatically when you use the Platform, including cookies, web beacons, log files, and similar tracking technologies;
• Third-party sources: Data received from payment processors (e.g., GCash, Maya, banks), identity verification services, and fraud prevention partners, strictly for the purposes described in this Policy.

4 How We Use Your Personal Data

4.1 clubphp.com uses your personal data only for legitimate, specified purposes. The primary purposes for which we process your data include:

• Account management: Creating, maintaining, and securing your clubphp.com account;
• Service delivery: Providing access to games, processing transactions, and delivering customer support;
• Identity and age verification: Confirming that you meet the minimum age requirement of 21 years and verifying your identity in compliance with KYC obligations;
• Financial processing: Facilitating deposits and withdrawals via GCash, Maya, bank transfer, and debit card;
• Legal and regulatory compliance: Meeting obligations under Philippine law, including anti-money laundering (AML) requirements and PAGCOR-related regulations;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, cheating, and unauthorized access;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior and applying responsible gaming tools where appropriate;
• Platform improvement: Analyzing usage data to improve the performance, features, and user experience of the clubphp.com Platform;
• Marketing communications: Sending you relevant promotions, bonuses, and updates — only where you have provided your consent and subject to your opt-out rights.

4.2 clubphp.com 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 required by law.

5 Legal Basis for Processing

5.1 Under the Philippine Data Privacy Act of 2012, clubphp.com processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., to provide the gaming services you have registered for;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML, KYC, and gaming regulatory requirements;
• Legitimate interests: Processing necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and non-essential cookies. You may withdraw consent at any time.

6 Data Sharing & Disclosure

6.1 clubphp.com does not sell, rent, or trade your personal data to any third party for their own marketing purposes. We may share your data only in the following limited circumstances:

• Payment processors: GCash, Maya, and banking partners require certain data to process your transactions securely;
• Identity verification providers: Third-party KYC and fraud prevention services used to verify your identity and protect the Platform;
• Technology and hosting providers: Cloud infrastructure and software vendors who process data on our behalf under strict data processing agreements;
• Regulatory and law enforcement authorities: Where required by Philippine law, court order, or regulatory directive, including reporting obligations under AML regulations;
• Professional advisors: Legal, accounting, and auditing firms, subject to professional confidentiality obligations;
• Business transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to equivalent privacy protections.

6.2 All third parties with whom clubphp.com shares personal data are required to handle such data in accordance with applicable data privacy laws and our contractual requirements. We do not permit third parties to use your data for their own purposes beyond what is strictly necessary.

7 Data Retention

7.1 clubphp.com retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction;
• KYC documents: Retained for the period required by applicable Philippine regulations, typically five (5) years from the end of the business relationship;
• Support communications: Retained for up to three (3) years from the date of the interaction;
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.

7.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

8 Data Security

8.1 clubphp.com implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data at rest, including financial information and government ID details;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, clubphp.com will notify the National Privacy Commission (NPC) and affected individuals in accordance with the requirements of the Philippine Data Privacy Act.

9 Cookies & Tracking Technologies

9.1 clubphp.com uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support our security and fraud prevention efforts. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled;
• Functional cookies: Remember your preferences and settings to provide a more personalized experience on clubphp.com;
• Analytics cookies: Help us understand how players use the Platform so we can improve performance and content;
• Marketing cookies: Used to deliver relevant promotions and measure the effectiveness of our marketing campaigns. These are only set with your consent.

9.2 You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the clubphp.com Platform.

10 Your Data Privacy Rights

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

• Right to be informed: The right to know what personal data we collect, how we use it, and with whom we share it;
• Right of access: The right to request a copy of the personal data we hold 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 our legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• 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 privacy rights have been violated.

10.2 To exercise any of the above rights, please contact our Data Protection Officer (DPO) using the details provided in Section 13. We will respond to all verified requests within thirty (30) days, as required by applicable law.

10.3 Marketing Opt-Out. You may opt out of receiving marketing communications from clubphp.com at any time by following the unsubscribe instructions in any marketing email, or by contacting our support team directly.

11 Children's Privacy

11.1 The clubphp.com Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

11.2 If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the Platform, please contact us immediately at the details provided in Section 13.

12 Updates to This Privacy Policy

12.1 clubphp.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform features. The date of the most recent revision is indicated at the top of this page.

12.2 Where changes are material, we will notify registered players via email or in-platform notification prior to the changes taking effect. Your continued use of the clubphp.com Platform following the effective date of any update constitutes your acceptance of the revised Policy.

12.3 We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

13 Contact Us & Data Protection Officer

13.1 clubphp.com has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data privacy laws. If you have any questions, concerns, or requests relating to your personal data, please contact us through any of the following channels:

13.2 You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that your data privacy rights have been violated. The NPC can be reached through their official government channels.