cluph Privacy Policy

1 Introduction

cluph Casino ("cluph," "we," "us," or "our") is committed to protecting the privacy and security of personal data provided by members ("you," "your," or "Member") of the cluph platform accessible at https://cluph.cam (the "Platform").

This Privacy Policy sets out the types of personal data we collect, the purposes for which we process that data, the legal basis for processing, how we protect your data, your rights as a data subject, and how to contact us with privacy-related questions or concerns.

cluph operates in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as applicable PAGCOR regulations governing online gaming operations in the Philippines.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, cluph Casino acts as the data controller responsible for the personal data you provide through the Platform.

Data Protection Officer Contact:
Email: [email protected]
Alternatively, you may contact our general support team at [email protected], and your inquiry will be forwarded to the Data Protection Officer.

3 Data We Collect

cluph collects and processes various categories of personal data in order to operate the Platform, comply with legal and regulatory obligations, and provide you with a secure gaming experience. The types of data collected include:

• Full legal name (as it appears on government-issued identification)
• Date of birth (to verify age eligibility — minimum 21 years)
• Email address
• Philippine mobile phone number
• Username and encrypted password
• Preferred currency (PHP)
• Marketing communication preferences

• Government-issued photo identification (Philippine passport, SSS ID, PhilSys National ID, UMID, driver's license)
• Proof of address documents (utility bills, bank statements, barangay certificates)
• Selfie photographs for identity verification purposes
• Source of funds declarations where required by anti-money laundering regulations

• Payment method type (GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard)
• Partial payment account identifiers (last four digits of card numbers, masked e-wallet account numbers)
• Transaction history (deposits, withdrawals, wagers, winnings)
• Deposit and withdrawal amounts, dates, and times
• Bonus history and wagering progress

• Game session logs (game titles played, bet amounts, session durations, win/loss outcomes)
• Sports betting selections and outcomes
• Responsible gaming tool usage (deposit limits, self-exclusion status, session reminders)
• VIP tier status and loyalty point accumulation

• IP address and approximate geolocation (country and city level)
• Device type, operating system, and browser type
• Screen resolution and language settings
• Referring URLs and clickstream data
• Login timestamps and session durations
• Cookies and similar tracking technologies (see Section 7)

• Live chat transcripts with cluph support agents
• Email correspondence sent to or received from cluph
• Feedback survey responses
• Complaint or dispute records

4 How We Use Your Data

cluph processes your personal data for the following purposes:

• Account Creation & Management: To register your cluph account, maintain your Member profile, authenticate your login sessions, and enable you to access Platform features.
• Age Verification & Eligibility: To confirm that you meet the minimum age requirement (21+) and are legally permitted to engage in online gaming activities in the Philippines.
• KYC & Regulatory Compliance: To verify your identity and comply with Know Your Customer, anti-money laundering (AML), and counter-terrorist financing (CTF) obligations imposed by PAGCOR and Philippine law.
• Payment Processing: To process deposits, execute withdrawal requests, reconcile transactions, and prevent payment fraud.
• Game Provision & Session Management: To deliver game content, track wagers and winnings, apply bonus terms, and maintain accurate transaction logs.
• Fraud Prevention & Platform Security: To detect and prevent fraudulent activity, collusion, bonus abuse, account takeover, an d multiple account use by the same individual.
• Responsible Gaming Obligations: To implement deposit limits, loss limits, session reminders, and self-exclusion tools; to monitor gameplay patterns that may indicate problem gambling; and to fulfill cluph's duty of care under the PAGCOR responsible gaming framework.
• Customer Support: To respond to inquiries, resolve disputes, investigate complaints, and provide technical assistance via live chat and email.
• Marketing Communications (with consent): To send promotional offers, bonus notifications, VIP tier upgrades, and Platform updates to Members who have opted in to receive marketing communications.
• Platform Improvement & Analytics: To analyze usage patterns, improve user experience, optimize game selection, and develop new features based on aggregated and anonymized behavioral data.
• Legal Compliance & Dispute Resolution: To comply with legal obligations, respond to lawful requests from regulatory authorities, enforce our Terms & Conditions, and defend legal claims.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, cluph processes your personal data on the following legal grounds:

• Consent: You provide explicit consent when you register a cluph account, accept these terms, and opt in to optional processing activities such as marketing communications.
• Contractual Necessity: Processing is necessary to perform the contract between you and cluph (the Terms & Conditions), including account management, payment processing, and game provision.
• Legal Obligation: Processing is required to comply with Philippine law, including KYC requirements, AML/CTF regulations, PAGCOR reporting obligations, and tax law.
• Legitimate Interests: Processing is necessary for cluph's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided such interests do not override your fundamental rights and freedoms.

6 Data Sharing & Disclosure

cluph does not sell, rent, lease, or trade your personal data to third parties for marketing purposes. We may, however, share your data with the following categories of recipients under strict confidentiality and data protection obligations:

cluph engages trusted third-party service providers to perform functions on our behalf, including payment processing (GCash, PayMaya, bank payment gateways), game content delivery, hosting infrastructure, customer support tools, email delivery services, and KYC verification platforms. These processors access personal data only to the extent necessary to perform their contracted services and are contractually bound to protect your data in accordance with this Privacy Policy and applicable law.

cluph may disclose personal data to PAGCOR, the National Privacy Commission, law enforcement agencies, tax authorities, or other government bodies when required by Philippine law, court order, subpoena, or regulatory demand. We will notify affected Members of such disclosures where legally permitted to do so.

To detect and prevent fraud, account takeover, bonus abuse, and money laundering, cluph may share limited personal data (such as IP addresses, device identifiers, and transaction patterns) with specialized fraud detection and risk management platforms. These partners operate under strict data protection agreements.

cluph may share personal data with legal counsel, auditors, and other professional advisors in connection with legal proceedings, regulatory audits, or business transactions, subject to confidentiality obligations.

In the event that cluph undergoes a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer, and the acquiring entity will be required to honor this Privacy Policy.

7 Cookies & Tracking Technologies

cluph uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform, remember your preferences, authenticate your sessions, and analyze Platform usage.

• Essential Cookies: Required for the Platform to function properly. These cookies enable core features such as login authentication, session management, and security. They cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences (such as language, currency, and game filters) to provide a personalized experience.
• Analytics Cookies: Collect aggregated, anonymized data about how Members use the Platform, which pages are visited most frequently, and where users encounter errors. This data helps cluph improve Platform performance and user experience.
• Marketing Cookies (with consent): Track your interaction with promotional campaigns and enable targeted advertising. These cookies are set only with your explicit consent and can be disabled at any time via your browser settings or the cluph cookie preference panel.

You may control or delete cookies through your browser settings. Note that disabling essential or functional cookies may impair your ability to access certain Platform features. Most modern browsers provide tools to view, manage, and delete cookies. Consult your browser's help documentation for specific instructions.

8 Data Security

cluph implements industry-standard technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These measures include but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and cluph servers;
• Secure storage of passwords using cryptographic hashing algorithms with salting;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Multi-factor authentication for administrative access to sensitive systems;
• Regular security audits, vulnerability assessments, and penetration testing;
• Comprehensive logging and monitoring of data access events;
• Data backup and disaster recovery procedures to ensure business continuity;
• Employee training on data privacy, confidentiality, and security best practices.

9 Data Retention

cluph retains your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by applicable Philippine law.

• Active Accounts: Personal data is retained for the duration of your active membership and for a reasonable period thereafter to allow for account reactivation and dispute resolution.
• Closed Accounts: Following voluntary account closure, most personal data is deleted within ninety (90) days, except for data that must be retained to comply with legal obligations.
• Regulatory Retention: KYC documents, transaction records, and gameplay logs are retained for a minimum period as mandated by PAGCOR regulations, anti-money laundering law, and tax law — typically five (5) to seven (7) years from the date of the last transaction.
• Marketing Data: If you withdraw consent for marketing communications, your contact details are suppressed from marketing lists immediately and deleted from marketing databases within thirty (30) days, except where retention is required for legal compliance.

After the applicable retention period expires, personal data is securely deleted or anonymized such that it can no longer identify you as an individual.

10 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights as a data subject:

• Right to be Informed: You have the right to be informed about the collection and processing of your personal data, as set out in this Privacy Policy.
• Right to Access: You may request a copy of the personal data cluph holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure (Right to be Forgotten): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent (subject to legal retention obligations).
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format for transmission to another service provider.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time (though this will not affect the lawfulness of processing prior to withdrawal).
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission of the Philippines if you believe cluph has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to valid requests within fifteen (15) business days in accordance with Philippine data privacy regulations.

11 International Data Transfers

cluph operates primarily within the Philippines and stores Member data on servers located in secure data centers within Philippine territory or in jurisdictions with adequate data protection standards as recognized by the National Privacy Commission.

In limited circumstances, personal data may be transferred to trusted service providers located outside the Philippines for purposes such as cloud hosting, payment processing, or game content delivery. Where such transfers occur, cluph ensures that appropriate safeguards are in place, including:

• Standard contractual clauses approved by the National Privacy Commission;
• Certification of the recipient under internationally recognized data protection frameworks;
• Explicit consent from the data subject where required by law.

cluph remains responsible for ensuring that any third party to whom personal data is transferred provides an adequate level of protection consistent with this Privacy Policy and Philippine law.

12 Children's Privacy

The cluph Platform is strictly intended for individuals aged twenty-one (21) years and above in accordance with PAGCOR regulations governing online gaming in the Philippines. cluph does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from an individual under the minimum age, we will take immediate steps to delete that data and permanently close the associated account. If you believe that cluph has inadvertently collected data from an underage individual, please contact us immediately at [email protected].

13 Policy Updates

cluph 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. Material changes will be communicated to Members via email or a prominent in-platform notification prior to the changes taking effect.

The effective date of the current Privacy Policy is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how cluph protects your personal data.

Continued use of the cluph Platform following the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms.

14 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or how cluph handles your personal data, please contact us using the details below:

• Data Protection Officer: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 within the cluph Platform after login
• Support Hours: 24 hours a day, 7 days a week — Philippine Standard Time (PHT, GMT+8)

cluph is committed to resolving privacy complaints fairly and promptly. If you are not satisfied with our response, you have the right to file a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission
• 5th Floor, Philippines International Convention Center (PICC), Vicente Sotto Street, Pasay City, Metro Manila, Philippines
• Website: privacy.gov.ph