clubpho Privacy Policy

clubpho ("we", "us", "our") is committed to protecting the privacy and personal data of every Member and visitor who interacts with our online gaming platform at clubpho.net ("the Platform"). This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, its Implementing Rules and Regulations, and the circulars and advisories issued by the National Privacy Commission (NPC) of the Republic of the Philippines.

This Policy describes in plain, readable English what personal information we collect, why we collect it, how we process and store it, who we may share it with, how long we keep it, and what rights you have as a data subject under Philippine law. By accessing the Platform, registering an account, or continuing to use our services, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy.

If you are accessing the Platform on behalf of another person, you represent that you have the authority to agree to this Privacy Policy on their behalf and that you have made them aware of its contents.

clubpho collects personal information at various points during your interaction with the Platform. The categories of personal data we collect, and the contexts in which we collect them, are described below.

A. Registration & Account Data

When you create a clubpho account, we collect the information you provide directly, including:

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Email address
• Mobile number
• Residential address (city, province, and postal code within the Philippines)
• Username and encrypted password
• Preferred language and currency (Philippine Peso, ₱)

B. Identity Verification (KYC) Data

To comply with anti-money laundering (AML) regulations and responsible gaming obligations, and before processing any withdrawal, we may request:

• A copy of a government-issued photo ID (e.g., Philippine Passport, SSS ID, PhilSys National ID, Voter's ID, or Driver's License)
• A recent proof of address document (utility bill or bank statement dated within the last three months)
• A selfie photograph for identity matching purposes
• Source-of-funds documentation where required by internal AML thresholds

C. Financial & Transaction Data

We record all financial transactions on the Platform, including:

• Deposit and withdrawal amounts, dates, and methods (GCash, PayMaya, BPI, BDO, Metrobank)
• Transaction reference numbers provided by payment processors
• Wallet balance history and bonus credit allocations
• Wagering history (games played, stakes, outcomes)

D. Technical & Device Data

When you access the Platform, our servers automatically collect certain technical data, including:

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Session timestamps, page views, and navigation path
• Referring URL and search terms (where applicable)

E. Communications Data

If you contact clubpho's support team via email or live chat, we retain records of those communications, including the content of your messages and any attachments, for quality assurance, compliance, and dispute-resolution purposes.

clubpho uses the personal data we collect for specific, legitimate purposes directly related to operating the Platform and serving our Filipino Members. We do not process your data in ways that are incompatible with the purposes stated below.

clubpho will only send you marketing communications — such as promotional offers, new game announcements, or VIP program updates — if you have opted in to receive them during registration or through your account settings. You can withdraw consent to marketing at any time by updating your notification preferences in your account or by contacting [email protected].

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, every act of personal data processing must have a lawful basis. clubpho relies on the following legal bases when processing your personal data:

• Contractual necessity: Processing your registration data, financial transactions, and KYC information is necessary for clubpho to perform its obligations under the Membership agreement (the Terms and Conditions) you entered into when you created your account.
• Legal obligation: Certain processing activities — including AML transaction monitoring, regulatory reporting, and age verification — are required by law, including Philippine gaming regulations and the Anti-Money Laundering Act (AMLA) as amended.
• Legitimate interests: clubpho processes technical and device data to operate, secure, and improve the Platform, to detect fraud and abuse, and to conduct internal analytics. We have assessed that these interests do not override your rights and freedoms as a data subject.
• Consent: Where we process your data for marketing communications or optional personalisation features, we do so on the basis of your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

clubpho uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device by a web server. Cookies allow the Platform to recognise your device, remember your preferences, maintain your session, and collect aggregated analytical data.

We use the following categories of cookies:

• Strictly necessary cookies: These are essential for the Platform to function. They enable core features such as account authentication, session management, and security controls. These cookies cannot be disabled without severely impairing the Platform's functionality.
• Functional cookies: These remember your preferences (e.g., language settings, display preferences) and personalise your experience on return visits.
• Analytical cookies: We use aggregated, anonymised analytics data to understand how Members navigate the Platform, identify areas for improvement, and measure the effectiveness of content. No individual Member is personally identifiable from this data.
• Security cookies: These help us identify and prevent fraudulent activity, bot traffic, and unauthorised access attempts.

You can control or delete cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will affect your ability to log in and use the Platform. clubpho does not use advertising or behavioural targeting cookies that track your activity across third-party websites.

clubpho does not sell, rent, or trade your personal data. We share your personal information only in the limited circumstances described below, and always subject to appropriate contractual protections or legal requirements.

• Payment processors: We share the financial data necessary to process your deposits and withdrawals with our licensed payment partners, including GCash (G-Xchange, Inc.), PayMaya Philippines, Inc., and Philippine banking institutions (BPI, BDO, Metrobank). These partners process your data only as required to complete the transaction and are bound by their own privacy and data security obligations.
• KYC and AML service providers: Identity verification and anti-money laundering screening may be performed with the assistance of specialist third-party compliance technology providers acting as data processors under contractual data processing agreements.
• Game technology providers: Third-party game suppliers and live casino operators who power specific games on the Platform may receive limited session and wagering data necessary to deliver the game. These providers operate under licences and data processing contracts that restrict how they may use your information.
• Regulatory and law enforcement authorities: We are required by law to disclose certain data to Philippine gaming regulators, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement authorities when lawfully directed to do so. We will always verify the legality of such requests before disclosing data.
• Legal proceedings: Where necessary to defend or assert legal rights in connection with a dispute, clubpho may share relevant personal data with legal counsel, courts, or arbitration bodies.

clubpho retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following general retention periods apply:

• Account data: Retained for the duration of your active Membership and for a minimum of five (5) years after account closure, as required by Philippine AML regulations and the NPC's recommended retention standards for financial services.
• KYC documents: Retained for a minimum of five (5) years from the date of account closure or the date of the last transaction, whichever is later, in accordance with AMLA obligations.
• Transaction records: Financial and wagering transaction logs are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications: Retained for two (2) years from the date of the interaction, or longer if related to an unresolved dispute or regulatory matter.
• Technical and device logs: Retained for up to twelve (12) months, after which they are anonymised or deleted.
• Marketing consent records: Retained for the duration of your active consent and for one (1) year after withdrawal of consent, as evidence of the consent given.

When personal data is no longer required under our retention schedules, it is securely deleted or anonymised so that it can no longer be linked back to any identifiable individual.

clubpho implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• Encryption in transit: All data transmitted between your device and the Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. This includes account login, financial transactions, and KYC document uploads.
• Encryption at rest: Sensitive personal data stored on clubpho's servers — including passwords (which are hashed and salted, not stored in plaintext), KYC documents, and financial records — is encrypted at the storage level.
• Access controls: Access to personal data within clubpho's internal systems is restricted on a strict need-to-know basis. Staff who handle Member data are subject to confidentiality obligations and undergo data privacy training consistent with NPC guidelines.
• Fraud and anomaly detection: Automated monitoring systems flag unusual account activity, including atypical login patterns, multiple failed authentication attempts, and transaction anomalies, triggering security review procedures.
• Vulnerability management: The Platform undergoes regular security assessments and penetration testing. Critical vulnerabilities are addressed on a priority basis in accordance with our internal security incident response procedures.
• Data breach response: In the event of a personal data breach that poses a real risk of serious harm to data subjects, clubpho will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and affected Members will be notified without undue delay, as required by NPC Circular No. 16-03.

While clubpho takes all reasonable steps to protect your data, no system is completely impenetrable. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect any unauthorised use of your account.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by clubpho. You may exercise these rights at any time by contacting us at [email protected]. We will respond to verified requests within a reasonable time and in accordance with the timelines prescribed by the NPC.

To exercise any of these rights, please submit a written request to [email protected]. We may need to verify your identity before processing your request in order to protect the security of your account and personal data. clubpho will not charge a fee for reasonable access or rectification requests.

clubpho is strictly an adult platform. In accordance with Philippine gaming law applicable to casino-style wagering, only persons aged 21 years and above are permitted to register and hold an account on the Platform. We do not knowingly collect personal data from individuals under the age of 21.

During registration, we collect date of birth information and we may request documentary proof of age as part of the KYC process. If clubpho discovers or has reasonable grounds to believe that a registered account belongs to a person under 21 years of age, we will:

• Immediately suspend the account pending investigation
• Withhold any funds in the account pending review
• Delete personal data relating to the underage individual to the extent permitted by any applicable legal obligations
• Report the matter to relevant Philippine regulatory authorities where required by law

If you are a parent or guardian and you believe that a minor has provided personal data to clubpho or created an account on the Platform, please contact us immediately at [email protected]. We take age verification seriously and will act promptly on any such report.

The clubpho Platform integrates with a number of third-party service providers to deliver its full range of features. These include game content providers, payment processors, identity verification platforms, and infrastructure and hosting services. Each of these providers is engaged under a contractual data processing agreement that restricts their use of your personal data to the scope strictly necessary to deliver their service to clubpho.

Please be aware that third-party game providers whose games are hosted within the clubpho Platform may operate their own data practices governed by their own privacy policies. To the extent that any such provider processes your data independently of clubpho's instructions, that processing is governed by the provider's own privacy policy, which we encourage you to review.

clubpho is not responsible for the data practices of any website, service, or platform that is not operated by clubpho. Links to third-party services accessible from within the Platform (such as payment gateway interfaces) are provided for your convenience, and clubpho makes no representations or warranties regarding the privacy practices of those services.

clubpho reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory guidance issued by the National Privacy Commission. When we make material changes to this Policy, we will notify you by one or more of the following methods:

• A prominent notice on the Platform upon your next login
• An email notification to your registered email address
• An in-app notification within your clubpho account

The "Last updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically, particularly before providing us with any additional personal information. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Privacy Policy.

If you have any concerns about changes to this Policy, please contact our support team before continuing to use the Platform. If you do not accept the amended Policy, you may request account closure in accordance with the Terms and Conditions.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how clubpho has handled your personal data, please reach out to our dedicated privacy support channel:

This Privacy Policy was last reviewed and updated on 1 January 2026. It applies to all personal data processed by clubpho in connection with the Platform and supersedes all prior versions of this Privacy Policy.