Privacy Policy

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, clubph1 acts as the Personal Information Controller (PIC) in respect of all personal data collected through the clubph1 platform at clubph1.net.

As the Personal Information Controller, clubph1 is responsible for determining the purposes and means of processing your personal data, ensuring that appropriate technical and organisational security measures are in place, and upholding your data subject rights as guaranteed under Philippine law.

All inquiries, data access requests, correction requests, and data deletion requests may be directed to the clubph1 Data Privacy Officer via the contact details provided in Section 12 of this policy.

clubph1 collects the following categories of personal data in the course of providing its online gaming services to registered players in the Philippines:

clubph1 does not collect sensitive personal information as defined under Section 3(l) of RA 10173 (such as health data, political affiliations, or biometric data beyond identity verification photographs) unless strictly required for KYC compliance or specifically requested by a regulatory authority.

clubph1 collects personal data through the following channels and mechanisms:

• Direct Collection: Information you provide voluntarily when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated Collection: Technical data such as IP addresses, device identifiers, and session logs are collected automatically when you access the clubph1 platform. This data is captured via server logs, session management systems, and platform analytics tools.
• Payment Provider Data: When you initiate a deposit or withdrawal via GCash, Maya, BDO, BPI, Metrobank, or UnionBank, clubph1 receives transaction reference data from the respective payment provider sufficient to confirm and reconcile the transaction. Full payment credentials are not transmitted to or stored by clubph1.
• Third-Party Verification: For KYC and fraud prevention purposes, clubph1 may use third-party identity verification services that cross-reference submitted ID documents against Philippine government databases. These services operate under data processing agreements with clubph1 and are bound by equivalent data protection standards.
• Cookies and Session Technology: As described in Section 08, clubph1 uses session cookies and limited analytics tools that automatically collect certain browsing data when you use the platform.

clubph1 processes your personal data only where a lawful basis exists under the Data Privacy Act of 2012. The following table sets out the primary processing purposes and their corresponding legal bases:

clubph1 does not sell, rent, or trade your personal data to third parties. Personal data is shared only in the following limited and controlled circumstances:

• Payment Processors: Transaction data is shared with GCash, Maya, BDO, BPI, Metrobank, and UnionBank solely for the purpose of processing deposits and withdrawals on your behalf. Each payment partner is subject to its own data protection obligations under Philippine law.
• Identity Verification Providers: KYC documents may be shared with accredited third-party identity verification services for the purpose of validating government-issued Philippine IDs. These providers are contractually bound to process data only for the stated purpose and to delete data once verification is complete.
• Game Software Providers: Game activity data (but not financial or identity data) may be shared with clubph1's certified game software providers for the purpose of delivering the game service, resolving technical disputes, and verifying RNG integrity.
• Regulatory and Law Enforcement Authorities: clubph1 may disclose personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), the Philippine National Police, or any other competent Philippine authority where required by law, court order, or lawful regulatory directive.
• Professional Advisers: Legal counsel, auditors, and financial advisers engaged by clubph1 may access personal data on a strictly need-to-know basis and are bound by professional confidentiality obligations.

All third parties with whom personal data is shared are required to implement appropriate technical and organisational security measures equivalent to those maintained by clubph1. clubph1 does not transfer personal data outside of the Philippines except where contractually required for game software delivery, and only with appropriate data transfer safeguards in place.

clubph1 retains personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account and Identity Data: Retained for the duration of the active account relationship, plus a minimum of five (5) years following account closure. This retention period is required to satisfy Anti-Money Laundering Act (AMLA) obligations and potential legal proceedings.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA reporting requirements applicable to online gaming operators in the Philippines.
• KYC Documents: Retained for the duration of the account plus five (5) years post-closure. Physical or digital copies of KYC documents are stored in encrypted form and access is restricted to authorised compliance personnel only.
• Gaming Activity Logs: Retained for a minimum of three (3) years from the date of each session. Aggregated, anonymised gaming statistics may be retained indefinitely for platform analytics purposes.
• Customer Support Communications: Retained for two (2) years from the date of the last communication in any given support interaction, or for the duration of any active dispute.
• Technical and Session Data: Raw server logs and session data are retained for ninety (90) days. Anonymised aggregated technical analytics may be retained for longer periods.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with clubph1's data disposal procedures. Players may request early deletion of their data subject to the limitations described in Section 09.

clubph1 employs a layered approach to data security, combining technical, administrative, and physical safeguards to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Key security measures include:

• Encryption in Transit: All data transmitted between your device and the clubph1 platform is encrypted using TLS 1.2 or higher. This applies to all account interactions, financial transactions, and KYC document uploads.
• Encryption at Rest: Sensitive data stored on clubph1 servers — including KYC documents, financial data, and account credentials — is encrypted at rest using AES-256 encryption standards.
• Access Controls: Access to personal data is restricted to clubph1 employees and authorised third parties on a strict need-to-know basis. All staff with access to personal data undergo background screening and are bound by confidentiality obligations.
• Multi-Factor Authentication (MFA): Internal systems containing personal data require multi-factor authentication for all staff access. Players are encouraged to enable MFA on their clubph1 accounts for additional personal security.
• Intrusion Detection and Monitoring: clubph1 platforms are monitored continuously for suspicious activity, anomalous login patterns, and potential security incidents. Automated alerts trigger immediate review by the security team.
• Regular Security Audits: clubph1 conducts periodic internal security reviews and engages third-party security assessors to perform penetration testing and vulnerability assessments.

clubph1 uses the following categories of cookies and similar tracking technologies when you access the platform:

• Essential Session Cookies: These cookies are strictly necessary for the platform to function. They maintain your login session, preserve your account security state, and ensure that game sessions are correctly attributed to your account. These cookies cannot be disabled without impairing your ability to use the platform.
• Functional Cookies: These cookies remember your preferences — such as language settings, display preferences, and responsible gaming tool configurations — to provide a personalised and consistent experience across sessions.
• Analytics Cookies: clubph1 uses limited, privacy-respecting analytics tools to understand aggregate platform usage patterns. Analytics data is collected in anonymised or pseudonymised form and is used solely for the purpose of improving platform performance and user experience. No identifiable personal data is shared with analytics providers.

clubph1 does not use third-party advertising cookies, behavioural tracking pixels, or cross-site tracking technologies. You will not be profiled for advertising purposes based on your clubph1 activity.

You may manage or delete cookies through your browser's settings at any time. Please note that disabling essential session cookies will prevent you from maintaining a logged-in session on the platform. For specific instructions on managing cookies in your browser, refer to your browser's help documentation.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by clubph1. These rights may be exercised by contacting the clubph1 support team or Data Privacy Officer using the details in Section 12:

clubph1 will respond to all data subject rights requests within thirty (30) calendar days of receipt. Where a request is complex or numerous, this period may be extended by up to an additional sixty (60) days, with notification provided to you within the initial thirty-day period explaining the reason for the extension.

Please note that certain data subject rights — particularly the right to erasure — may be limited where clubph1 is required to retain data to fulfil legal obligations under the AMLA, PAGCOR regulations, or ongoing dispute resolution processes. In such cases, clubph1 will explain the specific legal basis for the limitation.

If you believe clubph1 has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

The clubph1 platform is strictly intended for persons aged twenty-one (21) years and older, in accordance with Philippine gaming regulations. clubph1 does not knowingly collect personal data from individuals under the age of 21.

If clubph1 becomes aware that personal data has been collected from a person under the age of 21, the relevant account will be suspended immediately, all associated personal data will be deleted from clubph1 systems as soon as reasonably practicable, and any deposits made by the minor will be returned to the payment method of origin following identity verification.

If you believe that a minor may have registered an account on the clubph1 platform, please contact the support team immediately via live chat so that the matter can be investigated and resolved without delay.

clubph1 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. The effective date at the top of this document will be updated accordingly whenever the policy is revised.

For material amendments — those that significantly alter the way your personal data is collected, used, or shared — clubph1 will notify registered players via the email address associated with their account at least fourteen (14) days prior to the changes taking effect. Minor amendments, such as clarifications of existing practices, may be made without prior notice beyond the publication of the updated policy on the platform.

Your continued use of the clubph1 platform following the publication of any amendment constitutes your acceptance of the updated Privacy Policy. If you do not agree with any amendment, you may close your account by contacting the support team, and any remaining Real Money Balance will be returned to you following completion of applicable verification requirements.

For all privacy-related inquiries, data subject rights requests, or complaints regarding clubph1's handling of your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the clubph1 platform. This is the fastest channel for urgent privacy concerns.
• Email (plain text): [email protected] — responses within 24 hours for standard inquiries, and within 72 hours for formal data subject rights requests.

If you are not satisfied with clubph1's response to your privacy complaint, you may escalate the matter to the National Privacy Commission of the Philippines, which serves as the independent supervisory authority for data protection matters under RA 10173.