ClubPH Privacy Policy: How We Handle Your Data

1 Introduction

This Privacy Policy applies to all users of the ClubPH platform, accessible at clubph.vu. It covers how we handle personal information collected through the website, the ClubPH app, and any related account interactions.

By registering an account or continuing to use ClubPH, you acknowledge that you have read and understood this policy. If you do not agree with how we handle your data, please do not use the platform.

This policy should be read alongside the Terms and Conditions, which govern the overall use of the platform. Together, they form the agreement between you and ClubPH.

2 Data We Collect

When you use ClubPH, we collect personal information in the following categories:

We do not collect sensitive personal information such as religious affiliation, political views, or health data. Financial information collected is limited to transaction records — we do not store full bank account numbers or full e-wallet credentials on our servers.

3 Why We Collect It

Every piece of data we collect serves a specific purpose. The main reasons we process your personal information are:

• Account management: To create, maintain, and secure your ClubPH account, including password resets and OTP verification.
• Identity verification (KYC): To confirm your identity before processing withdrawals and to comply with applicable requirements around age verification and account authenticity.
• Transaction processing: To handle deposits and withdrawals in Philippine Peso through supported local payment channels.
• Platform operation: To deliver games, track account balances, apply bonuses correctly, and keep the platform running properly for all users.
• Customer support: To respond to your queries and resolve account issues efficiently.
• Security and fraud prevention: To detect unusual activity, prevent unauthorised access, and protect both you and the platform from fraud.
• Responsible gaming: To monitor gaming patterns where relevant and support players who use tools like deposit limits or self-exclusion on the Responsible Gaming page.
• Platform improvement: To understand how the platform is used so we can improve the experience over time.

We do not use your personal data to make automated decisions that have legal or similarly significant effects on you without human review.

4 Who We Share It With

ClubPH does not sell your personal information. We share data only where necessary and only with parties that have a legitimate role in delivering the platform or complying with applicable requirements:

• Payment processors: Local payment providers and e-wallet operators involved in processing your deposits and withdrawals. These parties receive only the information needed to complete each transaction.
• Identity verification providers: Third-party KYC services that help confirm your identity when required. They operate under confidentiality obligations and use data only for verification purposes.
• Game providers: Some games on ClubPH are supplied by third-party studios. Technical session data may be shared with them to deliver the game correctly, but this does not include your full personal profile.
• IT and hosting providers: Infrastructure and cloud service partners who host and maintain the platform under strict data processing agreements.
• Legal and regulatory bodies: Where required by law or in response to a valid legal request, we may disclose information to relevant authorities.

Any third party that receives data from ClubPH is required to handle it in a manner consistent with this policy and to use it only for the stated purpose.

5 Cookies and Tracking

ClubPH uses cookies and similar technologies to keep the platform working correctly and to understand how it is being used. Cookies are small text files stored on your device when you visit the site.

The types of cookies we use include:

• Essential cookies: Required for the platform to function. These handle things like keeping you logged in during a session and maintaining your account state. The site cannot work properly without them.
• Analytics cookies: Help us understand which pages are visited most often, how long sessions last, and where users encounter issues. This data is aggregated and not tied to your identity.
• Preference cookies: Remember settings you have chosen, such as language preferences or notification options.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using ClubPH, but some features may behave differently without them.

6 How We Protect Your Data

ClubPH applies a range of technical and organisational measures to protect your personal information:

• All data transmitted between your device and ClubPH is encrypted using SSL (Secure Sockets Layer) technology.
• Account access is protected by password hashing and OTP (one-time password) verification for sensitive actions such as withdrawals and password changes.
• Internal access to personal data is restricted to team members who need it to perform their specific role. Access logs are maintained.
• Our hosting infrastructure is maintained with regular security reviews and update cycles.
• In the event of a data breach that affects your personal information in a way that carries significant risk, we will notify affected users within a reasonable timeframe.

No system is completely immune to risk, but we take reasonable steps to keep your data safe. You also play a role — keep your ClubPH password confidential and update it if you suspect your account has been compromised.

7 How Long We Keep Your Data

We retain personal information for as long as your account is active or as long as required to fulfil the purposes described in this policy. Specific retention periods depend on the type of data:

• Account data: Kept for the duration of your active account and for a period after closure as required to meet legal obligations or resolve outstanding disputes.
• Transaction records: Financial transaction logs are retained for a minimum period in line with applicable recordkeeping requirements.
• KYC documents: Identity verification documents are kept for the period required by the verification process and applicable rules, then securely deleted.
• Support communications: Chat and email records with support are retained for a reasonable period to allow follow-up on related issues.

When data is no longer needed, it is either permanently deleted or anonymised so it can no longer be linked back to you.

8 Your Rights Over Your Data

As a ClubPH user, you have the following rights in relation to your personal information:

• Access: You can request a copy of the personal data we hold on you.
• Correction: If any information we hold is inaccurate or out of date, you can ask us to correct it. You can also update basic contact details directly from your account settings.
• Deletion: You can request the deletion of your personal data. We will action this where we are not required by law or legitimate obligation to retain it. Note that deletion requests for active accounts will trigger account closure.
• Restriction: In certain circumstances, you may ask us to limit how we use your data while a concern is being reviewed.
• Objection: You can object to specific types of data processing, such as the use of analytics cookies, where applicable.

To exercise any of these rights, contact ClubPH support through the Help section in your account or by email at [email protected]. We will respond within a reasonable timeframe and may need to verify your identity before acting on the request.

9 Minors

ClubPH is strictly for players aged 21 and above. We do not knowingly collect personal information from anyone under 21. If you believe a minor has registered an account, please contact support immediately so we can investigate and take appropriate action.

Accounts found to belong to users under 21 will be closed and any associated data handled in line with applicable rules and this privacy policy.

10 Changes to This Policy

ClubPH may update this Privacy Policy from time to time to reflect changes in how the platform operates, changes in applicable requirements, or improvements in how we explain our practices. When updates are made, the revised policy will be published here with an updated date at the top.

For material changes — meaning changes that significantly affect how your data is used — we will provide advance notice through your registered account or a notice on the platform. Continuing to use ClubPH after a revised policy is published means you accept the updated terms.