cluph Privacy Policy

This Privacy Policy governs the collection, use, storage, and disclosure of personal data by cluph in connection with the operation of the online casino and sports betting platform available at cluph.net. It applies to all users of the cluph platform, including registered players, prospective registrants who browse cluph.net without an account, and individuals who contact cluph's customer support team.

cluph takes its data privacy obligations seriously. As a PAGCOR-regulated gaming platform serving Filipino players across cities like Manila, Cebu, Davao, Quezon City, and Makati, cluph is subject to both the regulatory requirements of the Philippine Amusement and Gaming Corporation (PAGCOR) and the data protection framework established by the National Privacy Commission (NPC) under the Data Privacy Act of 2012.

This Policy is designed to be transparent and plain-language wherever possible. We want every cluph player to understand exactly what happens to their personal information — not just in legal terms, but in practical, everyday terms that are easy to follow.

cluph is a PAGCOR-regulated online gaming platform operating at cluph.net and serving Filipino players throughout the Philippines. cluph offers a comprehensive range of online casino games — including slots, live dealer tables, bingo, and jackpot titles — as well as sports betting markets covering Philippine Basketball Association (PBA), NBA, UFC, boxing, and other popular sports among Filipino fans.

For the purposes of the Data Privacy Act of 2012, cluph acts as the Personal Information Controller (PIC) in respect of the personal data of registered players and site visitors. This means cluph determines the purposes for which, and the manner in which, your personal data is processed.

Where cluph engages third-party service providers to process data on its behalf — such as payment processors for GCash and bank transfers, or game content providers — those third parties act as Personal Information Processors (PIP) and are bound by data processing agreements that require them to handle your data in accordance with this Policy and applicable Philippine law.

Questions about this Privacy Policy or cluph's data handling practices can be directed to our Data Protection Officer (DPO) via live chat support at any time. Contact details are provided in Section 14 of this Policy.

cluph collects personal data through several channels: directly from you when you register an account or contact support, automatically through your use of the platform, and in limited cases from third-party sources such as payment processors or identity verification services. The categories of data we collect are outlined in the table below:

cluph does not collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. We do not collect biometric data, racial or ethnic origin, religious beliefs, political opinions, or health data except where a player voluntarily discloses health-related information in the context of a responsible gaming support request.

cluph processes your personal data only for specified, legitimate, and proportionate purposes directly related to the operation of the platform and our obligations under Philippine law. The specific purposes for which we use your data are:

• Account Creation and Management: To register your cluph account, verify your identity, and maintain accurate account records throughout your time as a cluph player.
• KYC and Regulatory Compliance: To verify that you meet the eligibility requirements set out in cluph's Terms and Conditions — including the 21+ age requirement — and to fulfill PAGCOR-mandated Know Your Customer obligations.
• Payment Processing: To process your deposits and facilitate withdrawal requests to your registered GCash, PayMaya, BPI, BDO, or Metrobank account in accordance with our 1–2 hour GCash withdrawal commitment.
• Anti-Money Laundering (AML) Compliance: To monitor, detect, and report suspicious transaction activity as required under the Anti-Money Laundering Act (AMLA) and relevant PAGCOR and AMLC directives applicable to Philippine online gaming operators.
• Platform Delivery and Improvement: To provide, maintain, and improve the cluph gaming platform, diagnose technical issues, and personalize your gaming experience where you have consented to personalization features.
• Customer Support: To respond to your inquiries, resolve disputes, and assist with account-related requests via our 24/7 Filipino-speaking live chat support team.
• Responsible Gaming: To administer and monitor deposit limits, loss limits, session reminders, cooling-off periods, and self-exclusion arrangements you have activated on your account, and to identify early indicators of problem gambling behavior for proactive player welfare intervention.
• Security and Fraud Prevention: To protect cluph players and the platform from unauthorized access, fraudulent activity, account takeover attempts, and abuse of bonus promotions.
• Legal Compliance: To comply with applicable Philippine laws, respond to regulatory inquiries, and fulfill reporting obligations to PAGCOR, AMLC, the National Privacy Commission, or other competent Philippine authorities.
• Marketing Communications (with consent): To send you promotional offers, bonus notifications, and platform updates where you have expressly opted in to receive marketing communications. You may withdraw this consent at any time via your account settings or by contacting live chat support.

cluph does not use automated decision-making processes — including profiling — that produce legal or similarly significant effects on players without human review. Where data analytics are used to personalize your gaming experience or to flag responsible gaming concerns, a cluph support agent will be involved in any decision that materially affects your account.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, cluph relies on the following legal bases for processing your personal data:

• Contractual Necessity: Processing your identity, contact, financial, and gaming activity data is necessary for the performance of cluph's Terms and Conditions — the contract between you and cluph — including account management, payment processing, and the delivery of gaming services.
• Legal Obligation: Processing for KYC verification, AML compliance, age verification, PAGCOR reporting, and responses to lawful regulatory requests is required to fulfill cluph's obligations under Philippine law, including the AMLA, Republic Act No. 9287, and PAGCOR-issued circulars.
• Legitimate Interests: Processing for platform security, fraud prevention, technical diagnostics, and responsible gaming monitoring is carried out on the basis of cluph's legitimate interest in operating a safe, fair, and compliant gaming platform for Filipino players. These processing activities do not override your privacy rights.
• Consent: Processing for direct marketing communications is carried out only where you have given express, informed, and freely withdrawable consent. You may withdraw marketing consent at any time without affecting the lawfulness of prior processing or your ability to use the cluph platform.

cluph does not sell, rent, or trade your personal data to any third party for commercial purposes. We share your personal data only in the limited circumstances described below, and only to the extent necessary for the stated purpose:

• Payment Processors: Your financial data is shared with GCash (Mynt — Globe Fintech Innovations, Inc.), PayMaya Philippines, BPI, BDO, and Metrobank solely to process your deposit and withdrawal transactions. These institutions are bound by their own regulatory obligations under Bangko Sentral ng Pilipinas (BSP) supervision.
• Identity Verification Providers: During KYC, cluph may engage a licensed third-party identity verification service to cross-reference the documents you submit against government databases. Data shared for this purpose is limited to what is strictly required for verification.
• Game Content Providers: Certain game-specific session data (e.g., your in-game actions, bet values, and outcomes) is processed by the third-party game studios whose titles are hosted on cluph. These studios are contractually bound to process this data only for game delivery and auditing purposes.
• Regulatory Authorities: cluph is required by law to disclose data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government agencies upon receipt of a lawful request, court order, or as mandated by applicable regulation.
• Professional Advisors: cluph's legal counsel, auditors, and compliance consultants may access personal data on a strictly confidential, need-to-know basis in the course of providing professional services to cluph.
• Business Transfers: In the event of a merger, acquisition, or transfer of cluph's business operations, player data may be transferred to the successor entity. Players will be notified of any such transfer and their rights in connection with it in accordance with the Data Privacy Act of 2012.

All third parties with whom cluph shares personal data are required to handle that data in accordance with applicable Philippine data protection law and are subject to appropriate contractual safeguards. cluph remains responsible for the onward transfer of your personal data and will take reasonable steps to ensure its continued protection.

cluph uses cookies and similar tracking technologies on cluph.net to deliver a functional, secure, and personalized experience. A cookie is a small text file placed on your device when you visit a website. cluph uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the operation of cluph.net. They enable core functions such as user authentication, session management, and security features. These cookies cannot be disabled without impairing your ability to use the platform.
• Functional Cookies: These cookies remember your preferences — such as your language settings, preferred game categories, and responsible gaming tool configurations — to provide a more personalized experience on subsequent visits.
• Analytics Cookies: cluph uses privacy-compliant analytics tools to understand how players navigate and use the platform. This helps us identify areas for improvement and optimize the cluph gaming experience. Analytics data is aggregated and anonymized wherever possible.
• Security Cookies: These cookies assist cluph's fraud detection and account security systems by identifying unusual login patterns, detecting bot activity, and flagging suspicious account behavior for review.

You can manage your cookie preferences through your browser settings. Please be aware that disabling strictly necessary cookies may prevent certain features of cluph.net from functioning correctly. cluph does not use third-party advertising cookies or behavioral tracking cookies for the purpose of serving targeted advertisements on external websites.

cluph retains 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 regulation. The following retention periods apply:

Upon expiry of the applicable retention period, cluph will securely delete or anonymize your personal data in accordance with recognized data destruction standards. Anonymized, aggregated data that cannot be used to identify you may be retained indefinitely for statistical and platform improvement purposes.

cluph implements a comprehensive, layered security framework to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include, but are not limited to:

• Transport Layer Security (TLS 1.3): All data transmitted between your device and cluph.net is encrypted using TLS 1.3, the current industry standard for secure web communications.
• AES-256 Encryption at Rest: All personal and financial data stored on cluph's servers is encrypted using AES-256 symmetric encryption.
• Access Controls: Access to player personal data is strictly limited to cluph personnel who require it to perform their job functions. Role-based access controls and multi-factor authentication are enforced for all internal systems holding personal data.
• Regular Security Audits: cluph's platform and data infrastructure undergo regular penetration testing and security audits conducted by independent third-party specialists.
• Intrusion Detection: cluph operates continuous network monitoring and intrusion detection systems to identify and respond to potential security incidents in real time.
• Incident Response Plan: In the event of a personal data breach, cluph has a documented incident response plan that includes notifying affected players and the National Privacy Commission within the timeframes required by the Data Privacy Act of 2012.

While cluph takes all reasonable and proportionate measures to protect your data, no internet-based system is entirely immune to security risks. You play an important role in keeping your account secure by maintaining a strong, unique password and enabling two-factor authentication (2FA). cluph strongly recommends activating 2FA on your account via the account security settings.

As a data subject under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights in relation to the personal data cluph holds about you. These rights may be exercised by contacting cluph's Data Protection Officer via the live chat support channel:

cluph will respond to all verified data privacy rights requests within 15 business days of receipt. In complex cases where a longer period is required, cluph will notify you of the extension and the reason for it within the initial 15-day window. cluph reserves the right to verify your identity before fulfilling a data subject rights request to protect against fraudulent requests.

Please note that some rights are subject to limitations where cluph is required to retain data to comply with PAGCOR regulations, the AMLA, or other applicable Philippine law. Where this is the case, cluph will clearly explain the basis for any limitation on your request.

cluph is strictly an adult gaming platform. In accordance with PAGCOR regulations and Philippine law, the minimum age for participation in real-money gaming on cluph is 21 years of age. cluph does not knowingly collect personal data from individuals under 21 years of age.

cluph's registration process includes mandatory age verification, and all accounts are subject to KYC procedures that include documentary confirmation of date of birth. If cluph discovers that personal data has been collected from a minor — whether through misrepresentation at registration or any other means — that account will be immediately suspended, all associated transactions will be voided, and the personal data will be deleted as promptly as applicable law permits.

cluph.net may contain links to third-party websites, resources, or services — for example, links to PAGCOR's official website for regulatory information or to game provider support pages. These links are provided for informational convenience only. cluph does not operate, control, or endorse the content or privacy practices of any third-party website.

When you leave cluph.net and visit a third-party site, your interactions on that site are governed by the third party's own privacy policy and terms of use. cluph strongly recommends that you review the privacy policy of any third-party site you visit before providing any personal information. cluph accepts no responsibility or liability for the privacy practices or content of third-party websites.

cluph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data handling practices, updates to applicable Philippine law or PAGCOR regulations, or improvements to our platform. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this page;
• Display a prominent notice on cluph.net informing players that the Privacy Policy has been updated; and
• Where required by law or where the changes materially affect how we process your personal data, notify registered players directly via the contact details associated with their cluph account.

Your continued use of cluph.net following the posting of a revised Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree with any changes to this Policy, you should discontinue use of the platform and may request closure of your account by contacting live chat support.

cluph encourages all players to review this Privacy Policy periodically to stay informed about how we are protecting your personal data. The current version will always be accessible at cluph.net/privacy-policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or cluph's data handling practices, you may contact our Data Protection Officer (DPO) through any of the following channels:

If you are not satisfied with cluph's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent government body responsible for administering and enforcing the Data Privacy Act of 2012. Information on how to file a complaint with the NPC is available on the NPC's official government website.

cluph is committed to working constructively with both players and the NPC to resolve any data privacy concerns promptly and in good faith.