clupph Privacy Policy
At clupph, we treat your personal information with the same level of seriousness we apply to platform security. This Privacy Policy explains exactly what data we collect, why we collect it, how we use it, and the rights you hold as a registered player on the clupph platform — all in full compliance with the Philippine Data Privacy Act of 2012.
How clupph Protects Your Data
We built our data practices from the ground up with Filipino players in mind — combining PAGCOR regulatory requirements with the standards of the Philippine Data Privacy Act.
End-to-End Encryption
All data transmitted between your device and the clupph platform is secured using industry-standard TLS encryption. Your personal details, financial transactions, and account credentials are protected at every step — from deposit to withdrawal.
KYC & Identity Verification
clupph collects identity documents solely for KYC compliance, PAGCOR regulatory obligations, and anti-money laundering controls. Your ID and verification documents are stored securely and never shared with unaffiliated third parties for commercial purposes.
Secure Data Storage
Player data is stored on servers protected by multi-layered access controls, regular security audits, and strict internal data governance policies. Only authorized clupph personnel with a legitimate business need may access personal player records.
No Data Selling
clupph does not sell, rent, or trade your personal information to any third party for marketing or advertising purposes — full stop. Any data sharing with partners is strictly limited to what is necessary to operate the platform and comply with Philippine law.
Your Controls & Rights
Under the Philippine Data Privacy Act of 2012, you have clear rights over your personal data held by clupph — including the right to access, correct, delete, and object to processing. We make exercising these rights straightforward through our support team.
Transparent Cookie Use
clupph uses cookies strictly to improve your experience — session management, remembering your preferences, and platform analytics. We do not deploy third-party advertising trackers or cross-site profiling cookies on the clupph platform.
Contents
1 Introduction
This Privacy Policy ("Policy") describes how clupph ("clupph," "we," "us," or "our") collects, processes, stores, and protects the personal information of players and visitors who use the clupph platform accessible at clupph.net and all associated subdomains and mobile-optimized versions.
clupph is committed to handling your personal data responsibly and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable guidelines issued by the National Privacy Commission (NPC). As a PAGCOR-regulated online gaming platform, clupph is also subject to data handling obligations under PAGCOR's regulatory framework.
By registering an account on clupph, making a deposit, or otherwise using the platform, you confirm that you have read, understood, and consent to the data practices described in this Privacy Policy. If you do not agree, please do not use the clupph platform.
This Policy should be read together with the clupph Terms & Conditions and the Responsible Gaming Policy, all of which form part of your agreement with clupph. Players must be at least 21 years of age to register and use the platform.
2 Data Controller
For the purposes of the Philippine Data Privacy Act of 2012, clupph is the Personal Information Controller in respect of the personal data you provide when using the clupph platform. This means clupph determines the purposes and means of processing your personal information.
Where clupph engages third-party service providers to process data on its behalf — such as payment processors, identity verification providers, and cloud infrastructure partners — those providers act as Personal Information Processors and are contractually bound to process your data only on clupph's documented instructions, for the purposes stated in this Policy, and in compliance with applicable Philippine data protection law.
If you have any questions about how clupph handles your personal data, or if you wish to exercise any of your data subject rights, please contact our Data Protection Officer (DPO) as described in Section 15 of this Policy.
3 Data We Collect
clupph collects personal data that is necessary, adequate, and not excessive relative to the purposes for which it is collected. The categories of personal information we may collect include the following:
3.1 Identity & Registration Data
- Full legal name (as it appears on government-issued ID)
- Date of birth (used to verify that you are 21 years of age or older)
- Gender
- Nationality and country of residence
- Government-issued ID type and number (Philippine National ID, Passport, Driver's License, SSS/GSIS/Voter's ID, or equivalent)
- Selfie or biometric image submitted during identity verification
3.2 Contact Data
- Email address
- Mobile phone number
- Residential address (province, city/municipality, barangay, postal code)
3.3 Financial Data
- GCash or Maya account details (mobile number associated with the e-wallet)
- Bank account details (bank name, account number, account name — for BPI, BDO, UnionBank, Metrobank withdrawals)
- Cryptocurrency wallet address (for USDT TRC20 transactions)
- Deposit and withdrawal transaction records, including amounts, timestamps, and reference numbers
- Source of funds declarations where required for AML compliance
3.4 Gaming Activity Data
- Game session history (games played, wager amounts, win/loss records, session duration)
- Bonus and promotion redemption history
- Sports betting activity and bet history
- Responsible gaming settings and self-exclusion or deposit limit configurations
3.5 Technical & Device Data
- IP address
- Device type, operating system, and browser type/version
- Device identifiers (where permitted)
- Geolocation data (city/region level, used for fraud prevention and geographic access controls)
- Session logs and platform interaction data
3.6 Communications Data
- Records of live chat, email, and support ticket conversations with the clupph team
- Feedback, complaints, and dispute records
- Survey responses and promotional competition entries (where applicable)
clupph does not collect sensitive personal information (as defined under Section 3(l) of RA 10173) such as health records, religious beliefs, or political affiliations, except where such information is voluntarily disclosed by a player in the course of a responsible gaming self-declaration.
4 How We Collect Your Data
clupph collects your personal data through the following channels:
4.1 Directly From You
The majority of personal data clupph holds is provided directly by you during the registration process, KYC verification, deposit and withdrawal transactions, live chat interactions, email correspondence, and when you configure responsible gaming settings on your account. You are not legally required to provide this information, but failure to do so may prevent you from creating or maintaining an active clupph account.
4.2 Automatically Through Platform Use
When you access and use the clupph platform, certain technical and behavioral data is collected automatically via server logs, cookies, and similar technologies. This includes your IP address, device information, session timing, pages visited, games accessed, and clickstream data. This automated data collection is necessary for platform security, fraud detection, and service improvement.
4.3 From Third-Party Verification Providers
To fulfill our KYC and AML obligations, clupph works with authorized identity verification and document authentication providers. These providers may supply us with verification results, risk scores, and document authenticity flags based on the documents you submit. Their data processing is governed by their own privacy policies and by the data processing agreements they hold with clupph.
4.4 From Payment Processors
When you make a deposit or request a withdrawal, our payment processing partners (e.g., GCash, Maya, BPI payment gateways) share transaction confirmation data with clupph necessary to credit your account and fulfill your withdrawal request. clupph does not receive or store full payment instrument credentials directly.
5 How We Use Your Personal Data
clupph processes your personal data only for the purposes listed below. We do not use your data for purposes that are incompatible with those stated at the time of collection.
| Purpose | Description |
|---|---|
| Account Registration | Creating and managing your clupph player account, verifying your identity, and confirming you meet the 21+ age requirement. |
| KYC & AML Compliance | Verifying identity documents and transaction histories as required by PAGCOR regulations and the Anti-Money Laundering Act (AMLA). |
| Payment Processing | Facilitating deposits via GCash, Maya, BPI, BDO, UnionBank, and other supported methods, and processing withdrawal requests. |
| Platform Operation | Running the games, sports betting, bingo, and live dealer services on the clupph platform, including calculating outcomes and settling bets. |
| Fraud & Security | Detecting and preventing fraud, account takeovers, multi-accounting, bonus abuse, and other prohibited activities. |
| Customer Support | Responding to inquiries, resolving disputes, managing complaints, and providing account assistance via live chat and email. |
| Responsible Gaming | Managing deposit limits, cool-off periods, self-exclusion requests, and reality check settings on your account. |
| Regulatory Reporting | Fulfilling mandatory reporting obligations to PAGCOR, the AMLC, and other competent Philippine regulatory authorities. |
| Service Improvement | Analyzing aggregated usage patterns to improve the clupph platform, optimize game offerings, and enhance the player experience. |
| Marketing Communications | Sending you promotional offers, bonus notifications, and platform updates — only where you have consented to receive such communications and subject to your unsubscribe rights. |
6 Legal Basis for Processing
Under the Philippine Data Privacy Act of 2012, clupph processes your personal data on the following lawful bases:
- Contractual Necessity: Processing required to fulfill our obligations under the clupph Terms & Conditions — including account creation, payment processing, and game provision.
- Legal Obligation: Processing required to comply with applicable Philippine law — including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and tax reporting requirements.
- Legitimate Interests: Processing carried out to pursue clupph's legitimate business interests — such as fraud prevention, platform security, abuse detection, and service improvement — where such interests are not overridden by your data protection rights.
- Consent: Processing based on your freely given, specific, informed, and unambiguous consent — principally for marketing communications and optional platform personalization features. You may withdraw consent at any time by contacting [email protected] or using the unsubscribe link in any marketing email.
7 Data Sharing & Disclosure
7.1 Service Providers
clupph shares personal data with carefully selected third-party service providers who process data on our behalf under binding data processing agreements. These include: identity verification providers, payment gateway operators, cloud hosting and infrastructure providers, customer support platform providers, and fraud detection services. All processors are required to implement appropriate technical and organizational security measures consistent with the Data Privacy Act.
7.2 Regulatory & Law Enforcement Authorities
clupph is legally required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other competent Philippine government authorities when required by law, court order, or valid regulatory demand. clupph cooperates fully with official investigations and will not notify the account holder of such disclosures where prohibited by applicable law.
7.3 Business Transfers
In the event of a merger, acquisition, restructuring, or sale of all or part of clupph's business, personal data held by clupph may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.
No Data Selling: clupph does not sell, rent, or trade your personal data to any third party for their own marketing, advertising, or commercial purposes. Any data disclosed to third parties is strictly limited to what is necessary for the purposes described in this Policy.
8 Data Retention
clupph retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations.
- Account and KYC Data: Retained for the duration of your active account, and for a minimum of 5 years after account closure, as required by PAGCOR and AMLA record-keeping obligations.
- Transaction Records: Retained for a minimum of 5 years from the date of each transaction, in compliance with AMLA reporting requirements.
- Gaming Activity Data: Retained for 2 years from the date of each session for operational and dispute resolution purposes, unless a longer period is required by regulation.
- Support & Communications Records: Retained for 2 years from the date of the last interaction, unless the communication is related to an unresolved dispute or regulatory matter.
- Marketing Consent Records: Retained for the duration of your marketing consent, plus 1 year following withdrawal of consent for audit trail purposes.
When personal data is no longer required for any legitimate purpose, clupph securely destroys or anonymizes it in a manner that prevents reconstruction of the original data.
9 Cookies & Tracking Technologies
9.1 What Are Cookies
Cookies are small text files placed on your device by the clupph platform when you visit. They allow the platform to recognize your browser, remember your preferences, maintain your login session, and analyze how you interact with the site. Cookies are not programs and cannot carry viruses or access files on your device.
9.2 Types of Cookies Used by clupph
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly Necessary | Maintain your login session, remember your language preference, and ensure the platform functions correctly. Cannot be disabled. | Session / 24 hours |
| Functional | Remember your game preferences, display settings, and responsible gaming configuration between sessions. | 30 days |
| Analytics | Collect aggregated, anonymized data about how players use the platform to help clupph improve performance and the user experience. | Up to 1 year |
| Security | Detect fraudulent activity, identify suspicious login patterns, and protect player accounts from unauthorized access. | Session / 7 days |
9.3 Managing Cookies
You can manage or delete cookies through your browser settings at any time. Note that disabling strictly necessary cookies will prevent the clupph platform from functioning correctly and you will not be able to log in or place bets. For guidance on managing cookies in your browser, refer to your browser's help documentation. clupph does not deploy third-party advertising or cross-site tracking cookies.
10 Data Security
clupph implements comprehensive technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:
- TLS 1.2 / 1.3 encryption for all data in transit between your device and clupph servers
- AES-256 encryption for sensitive data at rest, including identity documents and financial records
- Multi-factor authentication requirements for internal staff access to player data systems
- Role-based access controls ensuring staff access only the data their job function requires
- Regular third-party penetration testing and security audits of the platform infrastructure
- 24/7 automated intrusion detection and security monitoring
- Comprehensive employee data protection training and confidentiality obligations
- Incident response procedures aligned with NPC breach notification requirements
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, clupph will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay as required by the Data Privacy Act.
While clupph takes every reasonable precaution to protect your data, no system can be guaranteed to be 100% secure. You also play a role in keeping your account safe — use a strong, unique password for your clupph account, enable any available two-factor authentication, and never share your login credentials with anyone.
11 Your Data Subject Rights
Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by clupph. You may exercise these rights at any time by contacting our Data Protection Officer as described in Section 15.
Your Rights Under the Data Privacy Act
The Philippine Data Privacy Act of 2012 gives you meaningful control over the personal information clupph holds about you. Here's what you can request at any time.
Right to Be Informed
You have the right to know whether clupph holds personal data about you, the purposes for which it is being processed, and to whom it has been disclosed.
Right of Access
You may request a copy of the personal data clupph holds about you, including the specific categories of data, how it was collected, and how it is being used.
Right to Rectification
If any personal data clupph holds about you is inaccurate or incomplete, you have the right to request that we correct or update it without undue delay.
Right to Erasure
You may request the deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to clupph's legal retention obligations under PAGCOR and AMLA.
Right to Object
You may object to the processing of your personal data for marketing communications or where processing is based on clupph's legitimate interests, and we will stop that processing unless we have compelling grounds to continue.
Right to Block
You may request that clupph suspend, withdraw, or restrict the processing of your personal data pending investigation of a complaint or clarification of the accuracy of your data.
Right to Data Portability
Where technically feasible, you may request that clupph provide your personal data in a structured, commonly used, machine-readable format so you can transfer it to another service provider.
Right to Complain
If you believe clupph has not handled your personal data in accordance with the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.
12 Minors & Age Restriction
The clupph platform is strictly restricted to individuals who are 21 years of age or older, in accordance with Philippine law governing casino-style online gambling. clupph does not knowingly collect personal data from individuals below the age of 21.
21+ Only. If clupph 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, void any pending bets or bonuses, and securely delete or anonymize all personal data associated with the account in accordance with our data retention obligations. Any balance remaining on such an account will be handled in line with our Terms & Conditions and applicable PAGCOR guidelines.
Parents and guardians who believe their child may have registered on the clupph platform are encouraged to contact our support team immediately at [email protected] so the matter can be investigated and resolved without delay.
clupph uses date-of-birth verification at registration and document-based KYC checks to screen out underage applicants. We reserve the right to request additional age verification documents at any point during a player's lifecycle on the platform if we have any doubt about a player's age.
13 International Data Transfers
Some of clupph's service providers and infrastructure partners may be located outside the Philippines. Where personal data is transferred to a country that may not offer the same level of data protection as the Philippines, clupph ensures that appropriate safeguards are in place to protect your information.
These safeguards include contractual data processing agreements that require the recipient to handle the transferred data in accordance with the standards of the Philippine Data Privacy Act, implement appropriate technical security measures, and allow clupph to audit compliance. clupph does not transfer personal data internationally except where strictly necessary for the purposes described in this Policy and subject to appropriate contractual protections.
In all cases, international transfers of personal data by clupph are conducted in accordance with the cross-border data transfer rules established by the National Privacy Commission. If you have questions about the specific safeguards applicable to any international transfer involving your personal data, please contact our DPO as described in Section 15.
14 Changes to This Privacy Policy
clupph reserves the right to update, amend, or revise this Privacy Policy at any time to reflect changes in our data practices, new regulatory requirements, or developments in the clupph platform. The "Last Updated" date at the top of this page will always reflect the date of the most recent revision.
When we make material changes to this Policy — meaning changes that significantly affect how we collect, use, or share your personal data, or that affect your rights as a data subject — we will notify registered players by email to the address on file and/or by displaying a prominent notice on the clupph platform for a period of at least 7 days before the changes take effect.
For non-material changes (such as clarifications of existing language, correction of typographical errors, or reorganization of content without substantive change), the updated Policy will take effect immediately upon publication. We encourage you to review this Policy periodically to stay informed about how clupph protects your personal data.
Your continued use of the clupph platform following the effective date of any changes to this Privacy Policy constitutes your acknowledgment of the updated Policy. If you do not agree with any revised terms, you may close your account by contacting [email protected] prior to the effective date of the changes.
15 Contact & Data Protection Officer
clupph has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or the contents of this Policy, please contact our DPO through any of the following channels:
- Email: [email protected] (subject line: "Data Privacy Request")
- Live Chat: Available 24/7 on the clupph platform — request to speak with the Data Privacy team
- Response Time: clupph aims to acknowledge all data subject requests within 5 business days and to resolve them within 30 calendar days, in accordance with NPC guidelines
If you are not satisfied with clupph's response to your data privacy request or complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines. The NPC may be contacted at privacy.gov.ph or through its official complaint channels. clupph cooperates fully with NPC investigations and will provide all information required to resolve data privacy complaints in a fair and transparent manner.
clupph is committed to the responsible handling of your personal data. We treat every data subject request with respect, professionalism, and urgency — because your privacy is not just a regulatory checkbox for us, it is a core part of the trust Filipino players place in the clupph platform.
Ready to Play on the Philippines' Most Trusted Casino?
Now that you know how clupph protects your personal information, explore our full game library — JILI slots, live dealer tables, sports betting, bingo, and more — all under PAGCOR regulation, fully denominated in Philippine Peso. Must be 21+.
21+ Only · PAGCOR Regulated · Data Privacy Act Compliant · T&Cs Apply