How clubeph Protects Your Privacy
These six commitments form the foundation of how clubeph handles your personal data. Read the full policy below for the complete legal details.
Encrypted Data Storage
All personal data stored on the clubeph platform is protected using AES-256 encryption at rest and TLS 1.3 in transit. Your account credentials, payment details, and KYC documents are never stored in plain text.
No Data Selling — Ever
clubeph does not sell, rent, or trade your personal information to third-party advertisers or data brokers. Your data is used solely for the purposes described in this Privacy Policy — nothing more, nothing less.
RA 10173 Compliance
clubeph operates in full compliance with the Republic Act No. 10173, known as the Data Privacy Act of 2012 of the Philippines. We are committed to upholding your rights as a data subject under Philippine law.
You Control Your Data
You have the right to access, correct, and request deletion of your personal data at any time. clubeph provides a straightforward process for exercising your data subject rights through our support team.
Minimal Data Collection
We only collect the personal data that is strictly necessary for account registration, identity verification, payment processing, fraud prevention, and regulatory compliance. We do not collect data speculatively.
Marketing Opt-Out Respected
If you opt out of marketing communications from clubeph, we honour that preference immediately. You will not receive promotional emails, SMS messages, or push notifications after unsubscribing — with no hassle.
Your Data, Your Rights — Play With Confidence at clubeph
Every Filipino player on clubeph deserves to know exactly how their personal information is handled. Read our full policy below, and if you have any concerns, our 24/7 support team is always ready to help. 21+ only.
- 1.Introduction
- 2.Data We Collect
- 3.How We Collect Data
- 4.How We Use Your Data
- 5.Legal Basis for Processing
- 6.Data Sharing & Disclosure
- 7.Cookies & Tracking
- 8.Data Retention
- 9.Data Security
- 10.Your Rights
- 11.Children & Minors
- 12.Third-Party Services
- 13.Cross-Border Transfers
- 14.Policy Amendments
- 15.Contact & Complaints
This Privacy Policy describes how clubeph ("Platform", "we", "us", "our") collects, uses, stores, shares, and protects personal information provided by users ("Player", "you", "your") when accessing or using the clubeph website, games, betting services, payment systems, and related features at clubeph.net. By creating a clubeph account or using any part of our platform, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. This Policy should be read alongside our Terms & Conditions.
Introduction
clubeph is an online casino and sports betting platform serving Filipino players. As part of operating this platform responsibly, we collect and process certain personal data from our registered players and website visitors. We take our obligations under the Republic Act No. 10173 — the Data Privacy Act of 2012 of the Philippines — extremely seriously, and this Privacy Policy reflects our commitment to transparency and lawful data handling.
This Privacy Policy applies to all personal data collected through the clubeph website, mobile browser interface, customer support channels, and any other interaction you have with us. It does not apply to third-party websites or services that may be linked to or referenced on our platform.
Personal Data We Collect
clubeph collects only the personal data necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of data we may collect include:
| Category | Data Elements | Purpose |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, government ID type and number | Account registration, KYC verification, age verification (21+) |
| Contact Data | Email address, mobile number, residential address (city/province/barangay) | Account communication, support, fraud alerts, withdrawal notifications |
| Financial Data | GCash account reference, bank account name/number (masked), transaction history | Deposit processing, withdrawal processing, AML compliance |
| KYC Documents | Scanned government ID (e.g., Philippine Passport, UMID, LTO licence), proof of address documents | Identity verification, regulatory compliance, fraud prevention |
| Gaming Activity Data | Game sessions, bet amounts, win/loss history, bonus usage, wagering records | Account management, responsible gaming monitoring, dispute resolution |
| Technical Data | IP address, device type, browser type and version, operating system, session timestamps | Security monitoring, fraud detection, platform optimisation |
| Communication Data | Live chat transcripts, email correspondence, support ticket content | Customer support, quality assurance, dispute evidence |
| Marketing Preferences | Email/SMS opt-in or opt-out status, preferred communication channel | Promotional communications (only where consent has been given) |
We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, biometric data (other than government ID photos required for KYC), or health information unless specifically required by law or regulatory instruction.
How We Collect Your Data
clubeph collects personal data through the following channels:
- Direct registration: When you create a clubeph account, you provide your name, date of birth, contact details, and preferred payment method.
- KYC submission: When you submit identity verification documents through our secure upload portal.
- Deposit and withdrawal transactions: Payment providers such as GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay share transaction reference data with us to confirm payment status.
- Platform usage: Automatically collected technical data (IP address, device, session activity) is logged by our systems during every visit to clubeph.net.
- Customer support interactions: When you contact us via live chat or email, the content of those communications is recorded and stored.
- Cookies and tracking technologies: As described in Section 7 of this Policy, we use cookies and similar technologies to collect usage and preference data.
- Third-party verification services: In some cases, we may verify identity data through authorised third-party KYC service providers operating under data processing agreements.
How We Use Your Personal Data
clubeph uses your personal data for the following specific purposes:
- Account creation and management: To register your account, verify your identity, and maintain your player profile on the clubeph platform.
- Age and eligibility verification: To confirm that you are at least 21 years of age and eligible to participate in online gaming under Philippine law.
- Payment processing: To facilitate deposits via GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay, and to process withdrawal requests to your verified payment method.
- Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeover attempts, and other security threats.
- Regulatory compliance: To meet our obligations under Philippine gaming regulations, the Data Privacy Act of 2012, and anti-money laundering (AML) laws including Republic Act No. 9160.
- Responsible gaming: To monitor gaming activity for signs of problem gambling behaviour and to administer responsible gaming tools such as deposit limits, cool-off periods, and self-exclusion requests.
- Customer support: To respond to your enquiries, resolve disputes, process complaints, and provide technical assistance.
- Platform improvement: To analyse aggregated usage patterns (in anonymised form) to improve our games, payment flows, and user experience.
- Marketing communications: To send promotional offers, bonus notifications, and platform updates — only where you have given explicit consent or where permitted under applicable law. You may withdraw consent at any time.
Legal Basis for Processing
Under the Data Privacy Act of 2012 (RA 10173) and general data protection principles, clubeph processes your personal data on the following legal bases:
- Contractual necessity: Processing your identity, contact, and financial data is necessary to provide the services described in our Terms & Conditions — including account registration, deposits, gameplay, and withdrawals.
- Legal obligation: We are required by Philippine law — including gaming regulations, AML laws, and the Data Privacy Act — to collect and retain certain personal data. This includes KYC documentation, transaction records, and gaming activity logs.
- Legitimate interest: We process technical and usage data to maintain platform security, prevent fraud, improve our services, and ensure fair play — where this interest is not overridden by your privacy rights.
- Consent: Where we rely on consent as our legal basis (primarily for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
Data Sharing & Disclosure
clubeph does not sell, rent, or trade your personal data. We share personal data only in the following limited and controlled circumstances:
- Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay receive only the transaction reference data required to process deposits and withdrawals. These providers maintain their own privacy policies and are independently regulated.
- KYC and identity verification providers: Authorised third-party KYC verification services may receive copies of your identification documents solely for the purpose of identity verification. These providers operate under strict data processing agreements.
- Regulatory and law enforcement authorities: We are required by law to disclose certain player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other lawful authorities upon valid legal request or court order.
- Fraud prevention networks: In cases of suspected fraud or criminal activity, we may share relevant data with industry-standard fraud prevention databases to protect the platform and its players.
- Technology and hosting providers: Our platform infrastructure providers process data on our behalf under data processing agreements that require them to maintain confidentiality and security standards equivalent to those described in this Policy.
All third parties with whom clubeph shares personal data are required to handle that data in accordance with applicable Philippine data protection law and to use it only for the purposes for which it was shared.
Cookies & Tracking Technologies
clubeph uses cookies and similar tracking technologies to operate, secure, and improve the platform. A cookie is a small text file stored on your device by your browser when you visit a website. We use the following types of cookies:
- Strictly necessary cookies: Required for the platform to function — including session management, login authentication, and security tokens. These cannot be disabled without breaking core platform functionality.
- Functional cookies: Remember your preferences such as language settings, preferred game categories, and UI customisations to personalise your experience.
- Analytics cookies: Collect anonymised data about how users interact with the clubeph platform (pages visited, time on page, click paths) to help us improve usability and performance.
- Security cookies: Used to detect and mitigate fraudulent login attempts, bot activity, and account takeover risks.
You may manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the clubeph platform. clubeph does not use advertising or cross-site tracking cookies.
Data Retention
clubeph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are:
- Account and identity data: Retained for the duration of your active account and for a minimum of 5 years following account closure, as required by Philippine AML regulations.
- Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, in compliance with AMLC requirements under RA 9160.
- KYC documents: Retained for a minimum of 5 years following account closure or the last transaction date, whichever is later.
- Gaming activity logs: Retained for 3 years from the date of each session, used for dispute resolution and responsible gaming monitoring.
- Customer support communications: Retained for 2 years from the date of each interaction.
- Marketing consent records: Retained for the duration of your active consent status, plus 1 year following withdrawal of consent as evidence of compliance.
Once the applicable retention period expires, personal data is securely deleted or anonymised in accordance with our data destruction procedures. Where legal proceedings or regulatory investigations are ongoing, data may be retained beyond standard periods until those proceedings are fully resolved.
Data Security
clubeph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Our security measures include:
- AES-256 encryption for all personal data stored at rest on our servers.
- TLS 1.3 encryption for all data transmitted between your device and the clubeph platform.
- Two-factor authentication (2FA) available on all player accounts and mandatory for all internal staff accounts.
- Role-based access controls ensuring that only authorised personnel with a legitimate operational need can access player data.
- Regular penetration testing and independent security audits conducted by qualified cybersecurity professionals.
- 24/7 security monitoring with automated alerting for suspicious access patterns or data breach indicators.
- Secure document storage for KYC documents, with access restricted to compliance and verification teams only.
In the event of a personal data breach that poses a risk to your rights and freedoms, clubeph will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where the breach is likely to result in significant harm.
Your Data Subject Rights
Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by clubeph. You may exercise any of these rights by contacting our support team at [email protected].
- Right to be informed: You have the right to be informed about how your personal data is collected and used — which is the primary purpose of this Privacy Policy.
- Right of access: You may request a copy of all personal data we hold about you, including your account information, transaction history, and KYC records.
- Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. Some corrections may require re-submission of identity documents.
- Right to erasure ("right to be forgotten"): You may request deletion of your personal data. Note that this right is subject to our legal data retention obligations — we may be required to retain certain data even after an erasure request.
- Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our legal obligations.
- Right to data portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
- Right to lodge a complaint: If you believe clubeph has not handled your personal data in accordance with RA 10173, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.
We will respond to all valid data subject requests within 15 business days. Complex requests may require an extension of up to an additional 15 business days, in which case we will notify you of the extension and the reason for it.
Children & Minors
The clubeph platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. The 21+ age requirement is enforced through mandatory KYC identity verification during the account registration process.
If clubeph becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend that account, delete all associated personal data in accordance with our data destruction procedures, and return any deposited funds to the originating payment source.
If you are a parent or guardian and you believe that your child has registered on the clubeph platform, please contact us immediately at [email protected]. We will take prompt action to investigate and resolve the matter.
Third-Party Services
The clubeph platform integrates with a number of third-party service providers to deliver payment processing, identity verification, game content, and platform infrastructure. When you interact with these third-party services — for example, by initiating a GCash deposit — your data may also be processed by those providers under their own privacy policies.
clubeph selects third-party service providers carefully and requires all providers to maintain data security and privacy standards consistent with RA 10173 and this Privacy Policy. All third-party integrations are governed by written data processing agreements.
clubeph is not responsible for the privacy practices of third-party providers operating under their own independent platforms. We encourage you to review the privacy policies of any payment provider (such as GCash or your bank) that you use in connection with your clubeph account.
Cross-Border Data Transfers
In the course of operating the clubeph platform, certain personal data may be transferred to or processed in jurisdictions outside the Philippines — for example, by cloud hosting providers or game content licensors whose servers are located abroad.
Whenever personal data is transferred outside the Philippines, clubeph ensures that appropriate safeguards are in place to protect the data in accordance with RA 10173. These safeguards may include contractual data transfer clauses, adequacy assessments, or other legally recognised transfer mechanisms.
By using the clubeph platform and accepting this Privacy Policy, you consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, provided that such transfers are subject to appropriate protective measures.
Amendments to This Privacy Policy
clubeph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. All amendments will be published on this page with an updated "Last Updated" date at the top of the Policy.
Where changes to this Privacy Policy are material — meaning they significantly affect your rights or how your data is used — clubeph will provide advance notice via your registered email address or via an in-platform notification, with a minimum of 14 days' notice before the changes take effect.
Your continued use of the clubeph platform after the effective date of any amended Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to any amendment, you should stop using the platform and contact support to discuss voluntary account closure.
Contact Us & Complaints
If you have any questions, concerns, or requests relating to this Privacy Policy or how clubeph handles your personal data, please contact our Data Protection Officer through the following channels:
- Email: [email protected]
- Live Chat: Available 24/7 within your logged-in clubeph account dashboard.
- Address: Manila, Philippines
We aim to respond to all privacy-related enquiries within 5 business days. For formal data subject access requests or erasure requests, our response time is up to 15 business days as noted in Section 10.
If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines, which is the independent regulatory authority responsible for enforcing RA 10173. The NPC can be reached through their official government channels.