clupph Privacy Policy

This Privacy Policy ("Policy") describes how clupph ("clupph", "we", "us", "our"), operator of the online gaming platform accessible at https://clupph.cam ("Platform"), collects, uses, stores, discloses, and otherwise processes the personal data of users ("you", "Player", "User") in connection with your registration for and use of the clupph Platform and all associated services.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission of the Philippines ("NPC"). Where clupph processes the data of users outside the Philippines, we apply equivalent data protection standards consistent with applicable international privacy frameworks.

By registering an account on the clupph Platform or by continuing to use the Platform after this Policy has been published or updated, 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 clupph Platform.

For the purposes of the Philippine Data Privacy Act of 2012 and this Policy, the personal information controller responsible for your personal data is clupph, the operator of the Platform at https://clupph.cam.

As the personal information controller, clupph determines the purposes for which and the means by which your personal data is processed. clupph has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with applicable data protection laws and for handling data subject rights requests. Inquiries regarding this Privacy Policy or the exercise of your data rights may be directed to the clupph Data Protection Officer via the contact details provided in Section 15 of this Policy.

clupph collects personal data that you provide directly, data generated through your use of the Platform, and data obtained from third-party verification services as required for regulatory compliance. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification document
• Date of birth and age verification information
• Residential address in the Philippines (barangay, city/municipality, province)
• Philippine mobile number registered to your account
• Email address registered to your clupph account
• Username and account credentials (passwords are stored in encrypted form only)
• Government-issued identification documents submitted for KYC verification (PhilSys National ID, UMID, SSS ID, Pag-IBIG ID, Philippine Passport, LTO Driver's License)
• Selfie photographs submitted for facial matching during KYC verification

3.2 Financial & Transaction Data

• GCash or Maya wallet identifiers associated with your deposits and withdrawals
• Bank account details for BPI, BDO, UnionBank, or Metrobank transfers
• Cryptocurrency wallet addresses used for USDT TRC20 transactions
• Records of all deposit and withdrawal transactions, including amounts, timestamps, and payment methods
• Wagering history, game results, bonus transactions, and account balance records

3.3 Technical & Usage Data

• IP address and approximate geographic location derived from IP data
• Device type, operating system version, browser type and version
• Session logs, login timestamps, and session duration records
• Pages visited, game categories accessed, and navigation patterns on the Platform
• Cookies and similar tracking technologies as described in Section 7

3.4 Communications Data

• Records of live chat conversations with clupph customer support agents
• Email correspondence with clupph support and compliance teams
• Responses to surveys, feedback forms, and promotional participation

clupph processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing of identity, account, and payment data is necessary to fulfill the contractual obligations between you and clupph under the clupph Terms & Conditions, including account management, game provision, payment processing, and withdrawal handling.
• Legal Obligation: clupph processes identity verification and financial transaction data as required by applicable Philippine laws, including anti-money laundering obligations under the Anti-Money Laundering Act (AMLA) as amended, PAGCOR regulatory requirements, and NPC data governance directives.
• Legitimate Interests: clupph processes technical and usage data to detect and prevent fraud, ensure platform security, and improve the gaming experience for all Filipino players, where such interests are not overridden by your data protection rights.
• Consent: Where clupph sends you optional marketing communications or uses non-essential cookies, we rely on your explicit consent, which you may withdraw at any time without affecting the lawfulness of prior processing.

clupph uses the personal data it collects for the following specific purposes, all of which are necessary for the operation of a licensed online gaming platform serving Filipino players:

• To create, verify, and maintain your clupph account, including identity verification through the KYC process as required for players based in the Philippines
• To process deposits, credit your clupph wallet, process withdrawal requests to your GCash, Maya, or bank accounts, and maintain accurate transaction records
• To detect, investigate, and prevent fraudulent activity, money laundering, underage gambling, bonus abuse, and other violations of the clupph Terms & Conditions
• To fulfill clupph's reporting and record-keeping obligations under Philippine anti-money laundering laws and PAGCOR regulatory requirements
• To provide personalized gaming experiences, including game recommendations and responsible gaming tool suggestions based on your usage patterns
• To send you transaction confirmations, account security alerts, and service notifications that are necessary for your account management
• To send promotional communications, bonus offers, and marketing materials about the clupph Platform, where you have consented to receive such communications
• To provide customer support through live chat and email, including resolving account disputes and processing responsible gaming requests
• To improve Platform performance, identify technical issues, and develop new features that better serve Filipino players

clupph does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. clupph may share your personal data with the following categories of recipients only where necessary and on a need-to-know basis:

• Payment Service Providers: GCash (Mynt), Maya (Voyager Innovations), BPI, BDO, UnionBank, Metrobank, and other payment processors receive the minimum data necessary to process your deposits and withdrawals in accordance with their own privacy policies.
• KYC and Identity Verification Partners: Third-party identity verification service providers process your submitted KYC documents and selfie data for the purpose of age and identity verification as required by Philippine law.
• Game Software Providers: Game providers such as Pragmatic Play, Evolution Gaming, PG Soft, and JiLi receive anonymized session and gameplay data necessary for game delivery and audit purposes. Your full identity data is not shared with game providers.
• Regulatory and Law Enforcement Authorities: clupph is required by Philippine law to disclose personal data and transaction records to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities upon receipt of a valid legal demand or as otherwise required by applicable regulation.
• Fraud Prevention Services: clupph shares device fingerprint and behavioral data with fraud detection service providers for the purpose of protecting all clupph players from fraudulent activity and account compromise.
• Professional Advisers: clupph's legal counsel, auditors, and other professional advisers may access personal data as strictly necessary for the provision of their professional services to clupph.

clupph uses cookies and similar tracking technologies to operate the Platform, maintain your authenticated session, analyze Platform performance, and — where you have consented — deliver relevant promotional content. The types of cookies used on the clupph Platform include:

• Strictly Necessary Cookies: These cookies are essential for the clupph Platform to function. They maintain your authenticated login session, remember your language and display preferences, and enable core Platform features. These cookies cannot be disabled without breaking Platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymized information about how players use the clupph Platform — which pages are visited most, how long sessions last, and where technical errors occur. This data helps clupph improve the Platform for all Filipino users.
• Functional Cookies: These cookies remember your optional preferences such as your preferred game categories, betting interface settings, and responsible gaming tool configurations, so you do not need to re-enter them on each visit.
• Marketing Cookies: Where you have consented, these cookies track your activity across the Platform to deliver relevant promotional offers. You may withdraw consent for marketing cookies at any time through your account settings or browser cookie controls.

Most web browsers allow you to control cookies through their settings. Disabling cookies may impair the functionality of the clupph Platform, including the ability to maintain a logged-in session. For detailed instructions on managing cookies in Chrome, Safari, or your preferred browser, consult your browser's help documentation.

clupph retains your personal data for as long as your account remains active and for such additional periods as are required to fulfill the purposes described in this Policy or to comply with applicable legal obligations. Specific retention periods applied by clupph include:

• Account and Identity Data: Retained for the duration of your active clupph account and for a minimum of five (5) years following account closure, as required by Philippine anti-money laundering regulations under the AMLA and PAGCOR record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with Philippine law.
• KYC Verification Documents: Retained for the legally required minimum period following account closure and in accordance with NPC guidelines.
• Customer Support Communications: Retained for three (3) years from the date of the communication, to support dispute resolution and service improvement.
• Technical and Usage Data: Retained for up to two (2) years for analytics and fraud prevention purposes, after which it is anonymized or deleted.
• Marketing Preferences and Consent Records: Retained for the duration of your account plus a reasonable period thereafter for compliance purposes.

Upon expiry of applicable retention periods, clupph will securely delete or anonymize your personal data. In cases where deletion is technically infeasible within normal operational systems, clupph will take steps to isolate and protect the data from further active processing until deletion is possible.

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

• TLS/SSL encryption for all data transmitted between your device and the clupph Platform
• Encryption at rest for sensitive personal data including KYC documents and payment information stored in clupph's systems
• Strict access controls limiting personal data access to clupph employees and contractors who have a legitimate business need to process that data
• Regular security assessments and penetration testing of the clupph Platform and supporting infrastructure
• Two-factor authentication (2FA) options available to all clupph account holders to protect account access
• Automated monitoring for unusual login patterns and suspicious transaction activity that may indicate account compromise

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by clupph. To exercise any of these rights, please contact the clupph Data Protection Officer using the contact details in Section 15:

• Right to Be Informed: You have the right to be informed about how clupph collects and processes your personal data, as described in this Policy.
• Right of Access: You may request a copy of the personal data that clupph holds about you, together with information about how it is processed.
• Right to Rectification: If any personal data clupph holds about you is inaccurate or incomplete, you have the right to request correction or completion. You may update basic account information directly through your clupph account settings.
• Right to Erasure (Right to Be Forgotten): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to clupph's legal retention obligations under Philippine law.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests where your specific situation warrants it.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format, where technically feasible.
• Right to File a Complaint: If you believe clupph has processed your personal data in violation of applicable law, you have the right to file a complaint with the National Privacy Commission of the Philippines.

The clupph Platform is strictly restricted to individuals who are at least twenty-one (21) years of age, in accordance with Philippine regulations applicable to online gaming. clupph does not knowingly collect personal data from persons under 21 years of age.

Age verification is conducted as a mandatory component of the clupph KYC process. In the event that clupph discovers or has reasonable grounds to suspect that personal data has been submitted by or on behalf of a person under 21 years of age, clupph will: immediately suspend the relevant account; delete the personal data collected in connection with that account to the extent permitted by law; and report the matter to relevant regulatory authorities where required.

If you are a parent or guardian and believe that your child has registered on the clupph Platform, please contact us immediately using the details in Section 15 so that we can take prompt action.

The clupph Platform integrates third-party services including game software providers, payment processors, and analytics tools to deliver a complete gaming experience to Filipino players. Each third-party service provider that processes personal data on behalf of or in conjunction with clupph is bound by data processing agreements that require them to maintain appropriate security standards and to process personal data only in accordance with clupph's instructions and applicable law.

clupph is not responsible for the privacy practices of third-party services that operate independently with their own privacy policies, including GCash, Maya, BPI, BDO, and other payment service providers. Players are encouraged to review the privacy policies of their chosen payment providers, as those providers' data practices are governed by their own terms and applicable regulations.

In connection with the provision of gaming and related services, some of your personal data may be processed by third-party service providers located outside the Philippines. Where such international transfers occur, clupph ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that impose data protection obligations on the overseas recipient equivalent to those required under Philippine law, or confirmation that the recipient jurisdiction maintains an adequate level of data protection.

Any international transfer of personal data by clupph is conducted in accordance with Section 21 of the Philippine Data Privacy Act of 2012 and relevant NPC guidelines on cross-border data flows. clupph will not transfer personal data to an overseas recipient unless satisfied that the transfer is compliant with applicable Philippine data protection requirements.

clupph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements, or the development of new Platform features. When material changes are made to this Policy, clupph will provide advance notice via email to your registered email address and/or through a prominent notice on the Platform, at least fourteen (14) days before the amended Policy takes effect.

Your continued use of the clupph Platform after the effective date of any amended Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically. The current version of this Privacy Policy, along with its effective date, is always available at https://clupph.cam/privacy-policy. If you have any concerns about any change to this Policy, please contact our Data Protection Officer before the effective date of the amendment.

For any questions, concerns, or formal data rights requests relating to this Privacy Policy or clupph's processing of your personal data, please contact the clupph Data Protection Officer through one of the following channels:

• Live Chat: Available 24/7 on the clupph Platform. For urgent data security concerns, live chat provides the fastest response from a trained clupph support agent. Filipino-speaking staff are available during Philippine business hours (8:00 AM – 10:00 PM PHT).
• Email: Contact us at the support email address displayed in the footer of this page. Please include your full registered name, account username, and a detailed description of your inquiry or data rights request. The clupph DPO will respond within two (2) Philippine business days for privacy-related matters.

If you are not satisfied with clupph's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about filing a complaint with the NPC is available on the NPC's official website. clupph is committed to cooperating fully with the NPC in the resolution of any complaint regarding our data processing practices.