clubphp Privacy Policy

1. About This Privacy Policy

1.1

This Privacy Policy applies to all personal data collected by clubphp through the clubphp website at clubphp.lat, including all games, services, payment processing, and customer support interactions conducted through the platform. It applies to all registered players and visitors to the clubphp platform.

1.2

clubphp operates as a PAGCOR-licensed online gaming platform serving players in the Republic of the Philippines. As a Philippine-based operator, clubphp is subject to the 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.

1.3

By registering an account with clubphp, you consent to the collection and processing of your personal data as described in this Privacy Policy. Where processing is based on consent, you may withdraw your consent at any time by contacting clubphp; however, withdrawal of consent does not affect the lawfulness of processing that occurred prior to the withdrawal.

2. Personal Data We Collect

2.1

Registration Data. When you create a clubphp account, we collect your full legal name, date of birth, nationality, Philippine residential address, mobile phone number, and email address. This information is required to verify your identity, comply with PAGCOR licensing requirements, and fulfil our anti-money laundering (AML) obligations under Philippine law.

2.2

Identity Verification Data. To complete Know Your Customer (KYC) verification, clubphp collects copies of your government-issued identification documents, which may include a Philippine passport, driver's license, SSS ID, PhilHealth ID, or UMID card. We may also collect a selfie photograph for biometric identity confirmation.

2.3

Financial Data. clubphp collects information about your deposits, withdrawals, and transaction history on the platform. We collect the name and identifiers of your payment methods (e.g., GCash mobile number, Maya account, bank account details) for the purpose of processing payments. clubphp does not store full bank account credentials or full card numbers on its servers.

2.4

Gaming Activity Data. We collect records of your gaming activity on clubphp, including games played, bet amounts, outcomes, session durations, and bonus usage. This data is used for account management, dispute resolution, fraud prevention, and responsible gaming monitoring.

2.5

Technical and Usage Data. clubphp automatically collects certain technical information when you access the platform, including your IP address, browser type and version, operating system, device type, screen resolution, referring URLs, and pages visited. This information is collected using cookies and similar technologies and is used for security, analytics, and platform optimisation.

2.6

Communications Data. If you contact clubphp customer support via live chat or email, we retain records of those communications, including the content of your messages and the date and time of contact. This data is used for quality assurance, dispute resolution, and service improvement.

3. How We Use Your Personal Data

clubphp processes your personal data for the following purposes:

• Account creation and management — to register your clubphp account, verify your identity, and manage your account throughout your relationship with us;
• Regulatory compliance — to fulfil our obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws;
• Payment processing — to process your deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, InstaPay, and other supported payment methods;
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, account abuse, and security breaches;
• Responsible gaming — to monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and provide responsible gaming tools;
• Customer support — to respond to your inquiries, resolve disputes, and provide technical assistance;
• Platform improvement — to analyse usage data, test new features, and improve the overall clubphp user experience;
• Marketing and promotions — to send you information about clubphp bonuses, new games, and promotions, where you have not opted out of such communications.

4. Legal Basis for Processing

4.1

Contractual Necessity. Processing your registration data, financial data, and gaming activity data is necessary for the performance of the contract between you and clubphp — specifically, to provide you with the online gaming services you have requested.

4.2

Legal Obligation. Processing for identity verification (KYC), anti-money laundering monitoring, and regulatory reporting to PAGCOR and AMLC is required by Philippine law and our PAGCOR license conditions.

4.3

Legitimate Interests. Processing for fraud prevention, security monitoring, and platform analytics is based on clubphp's legitimate interests in operating a secure, fair, and compliant gaming platform.

4.4

Consent. Processing for marketing communications is based on your consent, which you may withdraw at any time through your account settings or by contacting clubphp support.

5. Disclosure and Sharing of Your Data

5.1

clubphp does not sell or rent your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients for the purposes set out in this Policy:

• PAGCOR and Philippine regulatory authorities — as required by our gaming licence and applicable Philippine law;
• Anti-Money Laundering Council (AMLC) — for mandatory suspicious transaction and covered transaction reporting under the AMLA;
• Payment service providers — GCash, Maya, BPI, BDO, Metrobank, and other payment processors, solely for the purpose of processing your transactions;
• Identity verification and KYC service providers — third-party providers who assist with document verification and biometric identity checks, bound by strict data processing agreements;
• IT and security service providers — cloud hosting, cybersecurity, and fraud detection service providers who process data on clubphp's behalf under data processing agreements;
• Law enforcement and courts — where required by a valid legal order, court order, or applicable Philippine law.

5.2

All third-party service providers who process personal data on behalf of clubphp are contractually required to process such data only in accordance with clubphp's instructions and to maintain appropriate security measures.

6. Cookies and Tracking Technologies

6.1

clubphp uses cookies, web beacons, and similar tracking technologies on the clubphp platform. Cookies are small text files placed on your device that help us recognise you, remember your preferences, keep your session active, and analyse how the platform is used.

6.2

The following categories of cookies are used by clubphp:

• Strictly Necessary Cookies — required for the platform to function. These enable your login session, PHP wallet access, and security features. They cannot be disabled.
• Performance and Analytics Cookies — collect anonymised data about how players use the clubphp platform to help us improve functionality and identify errors.
• Preference Cookies — remember your language, game display preferences, and other personalisation settings.
• Marketing Cookies — used to deliver relevant promotions and to measure the effectiveness of our marketing activities. You may opt out of these via your browser settings.

6.3

You can control and manage cookies through your browser settings. Please note that disabling cookies other than strictly necessary cookies may affect your experience on the clubphp platform.

7. Data Retention

7.1

clubphp retains your personal data for as long as your account is active and for a period of at least five (5) years after account closure, as required by PAGCOR licensing conditions and Philippine AML regulations.

7.2

Transaction records and gaming activity logs are retained for a minimum of five (5) years for regulatory compliance purposes. Identity verification documents are retained for a minimum of five (5) years after the end of the customer relationship.

7.3

After the applicable retention period has expired, clubphp will securely delete or anonymise your personal data in accordance with our internal data destruction procedures.

8. Security Measures

8.1

clubphp implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction, including:

• SSL/TLS encryption for all data transmitted between your device and the clubphp platform;
• Encryption of sensitive data at rest on our servers;
• Role-based access controls ensuring only authorised personnel access player data;
• Multi-factor authentication for internal access to production systems;
• Regular security audits and penetration testing;
• Real-time fraud monitoring and anomaly detection systems.

8.2

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, clubphp will notify you and the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

9. Your Data Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules, you have the following rights in relation to your personal data held by clubphp:

• Right to be Informed — you have the right to be informed of how your personal data is collected and processed, as set out in this Privacy Policy;
• Right of Access — you may request a copy of the personal data clubphp holds about you, including your account data, transaction history, and KYC records;
• Right to Rectification — you may request correction of inaccurate or incomplete personal data held by clubphp;
• Right to Erasure or Blocking — in certain circumstances, you may request deletion or blocking of your personal data, subject to clubphp's regulatory retention obligations;
• Right to Object — you may object to processing of your data for marketing purposes at any time;
• Right to Data Portability — you may request a copy of your personal data in a structured, machine-readable format;
• Right to Lodge a Complaint — you have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact clubphp via live chat or at [email protected]. We will respond to verified requests within a reasonable timeframe and no later than 30 days.

10. Children's Privacy

The clubphp platform is strictly for persons aged 21 years and older. clubphp does not knowingly collect personal data from individuals under 21 years of age. If clubphp becomes aware that personal data has been collected from a person under 21, that account will be immediately closed and the data will be deleted, except where retention is required for regulatory reporting purposes. Parents or guardians who believe a minor has registered with clubphp should contact support immediately.

11. Third-Party Links

The clubphp platform may contain references to third-party services (such as payment providers). This Privacy Policy applies only to the clubphp platform. clubphp is not responsible for the privacy practices of third-party services. We encourage you to read the privacy policies of any third-party services you use in connection with your clubphp account, particularly your GCash or Maya app.

12. Changes to This Privacy Policy

clubphp reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform operations. The updated policy will be published on this page with a revised effective date. For material changes, clubphp will notify registered players via email or in-platform notification where practicable. Your continued use of the clubphp platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

13. Contact and Data Privacy Officer

For questions, concerns, or requests relating to this Privacy Policy or your personal data rights, please contact the clubphp support and data privacy team:

• Live Chat: Available 24/7 via the chat button on clubphp.lat
• Email: [email protected] (plain text — not a clickable link)
• Languages: English and Filipino (Tagalog)

clubphp is committed to resolving all privacy-related inquiries promptly and in compliance with the Data Privacy Act of 2012. If your concern is not resolved to your satisfaction, you may escalate the matter to the National Privacy Commission of the Philippines through their official channels.