1clubph Privacy Policy

1clubph ("1clubph," "we," "us," or "our") is committed to protecting the privacy and personal data of all users ("you," "Player," or "User") who access and use the 1clubph online gaming platform at https://1clubph.com (the "Platform"). This Privacy Policy describes how we collect, use, store, share, and protect your personal information in connection with your use of the Platform.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). By registering an account or using the 1clubph Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read together with our Terms and Conditions, which govern your use of the 1clubph Platform. Capitalized terms not defined in this Privacy Policy have the meanings given to them in the Terms and Conditions.

For the purposes of the Data Privacy Act of 2012, 1clubph is the personal information controller responsible for your personal data collected through the Platform. We determine the purposes and means of processing your personal information.

Our designated Data Protection Officer ("DPO") oversees compliance with data privacy obligations and handles all data subject requests. You may contact our DPO at any time using the contact details provided in Section 15 of this Privacy Policy.

1clubph collects the following categories of personal data from users of the Platform:

We do not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect information relating to racial or ethnic origin, political opinions, religious beliefs, or health data unless specifically required by law.

1clubph collects personal data through the following means:

• Direct interactions: Data you provide when registering your 1clubph account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from accredited KYC providers; fraud prevention data from anti-money laundering screening services; payment data from GCash, PayMaya, BPI, BDO, and Metrobank in connection with your transactions.

1clubph processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

• Account registration and management: To create and maintain your 1clubph account, verify your identity, and provide access to Platform services (legal basis: performance of contract);
• Payment processing: To process deposits, withdrawals, and refunds through your chosen payment method (legal basis: performance of contract);
• Regulatory compliance: To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations under Republic Act No. 9160, and KYC requirements (legal basis: compliance with legal obligation);
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, and unauthorized access to the Platform (legal basis: legitimate interests);
• Customer support: To respond to your inquiries, resolve disputes, and improve our support services (legal basis: performance of contract and legitimate interests);
• Responsible gaming: To monitor gaming behavior, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling (legal basis: legitimate interests and legal obligation);
• Marketing communications: To send you promotional offers, bonuses, and platform updates where you have provided consent (legal basis: consent — you may withdraw consent at any time);
• Platform improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the 1clubph Platform (legal basis: legitimate interests).

1clubph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, solely to facilitate your financial transactions;
• Identity verification providers: Accredited KYC and AML screening services engaged to verify your identity and screen for sanctions or politically exposed persons (PEP) status;
• Technology service providers: Cloud hosting, data analytics, and cybersecurity vendors who process data on our behalf under strict data processing agreements;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies, where disclosure is required by law or regulatory order;
• Law enforcement: Philippine law enforcement agencies where disclosure is required pursuant to a valid legal process, court order, or to protect the rights and safety of 1clubph, its employees, or other users.

All third-party service providers who process personal data on behalf of 1clubph are contractually required to implement appropriate technical and organizational security measures and to process data only in accordance with our instructions.

1clubph primarily stores and processes personal data within the Philippines. In limited circumstances, personal data may be transferred to or accessed from servers located outside the Philippines — for example, where a technology service provider operates internationally.

Any international transfer of personal data will be conducted in compliance with the Data Privacy Act of 2012 and NPC guidelines, including the implementation of appropriate safeguards such as contractual data transfer agreements that provide a level of protection equivalent to that afforded under Philippine law.

1clubph retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AML obligations under Philippine law;
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Customer support communications are retained for three (3) years from the date of the interaction;
• Marketing consent records are retained for the duration of your account and for two (2) years following withdrawal of consent.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

The 1clubph Platform uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login state to provide a more personalized experience.
• Analytics cookies: Help us understand how players interact with the Platform so we can improve performance and usability. Data collected is aggregated and anonymized.
• Marketing cookies: Used to deliver relevant promotional content based on your interests and gaming activity, where you have provided consent.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 1clubph Platform.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 1clubph:

• Right to be informed: You have the right to know what personal data we collect, how it is used, and with whom it is shared;
• Right of access: You may request a copy of the personal data we hold about you at any time;
• Right to rectification: You may request correction of any inaccurate or incomplete personal data in your 1clubph account;
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests;
• Right to data portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: You have the right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified data subject requests within fifteen (15) business days, in accordance with NPC guidelines.

The 1clubph Platform is strictly intended for adults aged twenty-one (21) years and above, as required under Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under the minimum age requirement, we will immediately close the associated account, delete all personal data collected, and return any deposited funds to the payment source. If you believe a minor has registered on the 1clubph Platform, please notify us immediately at the contact details provided in Section 15.

1clubph implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 1clubph Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing of Platform infrastructure;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While we take all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your 1clubph login credentials and for notifying us immediately of any suspected unauthorized access to your account.

The 1clubph Platform may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to the 1clubph Platform and does not govern the privacy practices of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit, as 1clubph has no control over and assumes no responsibility for their content or data practices.

1clubph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email or an in-platform notification prior to the changes taking effect.

The most current version of this Privacy Policy will always be available at https://1clubph.com/privacy-policy. The effective date at the top of this page indicates when the current version was last updated. Your continued use of the 1clubph Platform following any update constitutes your acceptance of the revised Privacy Policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 1clubph, please contact our Data Protection Officer:

Data Protection Officer, 1clubph
Email: [email protected]

General Support: [email protected]

We aim to acknowledge all privacy-related inquiries within two (2) business days and to resolve them within fifteen (15) business days. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.