clobph Privacy Policy

clobph ("clobph", "we", "us", "our") is the operator of the online gaming platform available at clobph.net, offering casino games, sports betting, bingo, live dealer games, and related entertainment services to Filipino players aged 21 and above.

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, clobph acts as the Personal Information Controller in respect of the personal data you provide to us when registering for and using the clobph platform. This means clobph determines the purposes and means by which your personal data is processed.

Where clobph engages third-party service providers to process personal data on its behalf — such as KYC verification partners or payment processors — those providers act as Personal Information Processors and are bound by data processing agreements that require them to handle your data only in accordance with clobph's documented instructions and applicable Philippine data privacy law.

clobph collects personal data in several categories depending on how you interact with the platform. The table below summarises the categories of data we collect and the primary purpose for which each category is used.

clobph collects personal data through the following channels and mechanisms:

• Directly from you: When you register a clobph account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in promotions, or update your account profile.
• Automatically through platform use: When you browse or use the clobph website or app, we automatically collect technical data including IP address, device identifiers, browser type, pages visited, and session duration via cookies and server logs.
• From KYC verification partners: Where clobph uses a third-party identity verification service to validate your government-issued ID, that provider may return verification results and risk scores to clobph as part of the verification process.
• From payment processors: Payment providers such as GCash, Maya, BPI, and BDO may share transaction confirmation data with clobph for the purpose of crediting deposits and verifying withdrawal destinations.
• From fraud prevention and AML screening services: clobph may receive risk signals from third-party fraud detection or sanctions screening providers where such checks are required for regulatory compliance.

clobph uses the personal data it collects for the following documented purposes:

• Account creation and management: To register your clobph account, verify your identity, maintain your account profile, and enable you to access the full range of platform features.
• KYC and age verification: To verify that you meet the 21+ minimum age requirement and to confirm your identity as required under applicable gaming and anti-money laundering regulations.
• Payment processing: To process your deposits and withdrawals via your registered payment method (GCash, Maya, BPI, BDO, UnionBank, Coins.ph, or USDT TRC20) and to maintain accurate financial records.
• Platform operation and game provision: To deliver casino games, sports betting markets, bingo, live dealer tables, and all other clobph services you access, and to record game and bet outcomes for audit and dispute resolution purposes.
• Regulatory and legal compliance: To meet our obligations under the Data Privacy Act, the Anti-Money Laundering Act (AMLA), and all other applicable Philippine laws and regulations, including reporting obligations to the Anti-Money Laundering Council (AMLC).
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeover, bonus abuse, and other prohibited conduct on the clobph platform.
• Customer support: To respond to your enquiries, process your complaints, and resolve disputes through our live chat and email support channels.
• Responsible gaming: To monitor gaming patterns that may indicate problem gambling, to apply deposit and loss limits you have set, and to administer self-exclusion requests in accordance with our Responsible Gaming Policy.
• Direct marketing (with your consent): To send you promotional communications about clobph bonuses, new games, special events, and platform updates where you have opted in to receive such communications.
• Platform improvement and analytics: To analyse aggregated, anonymised usage data for the purpose of improving the clobph platform, personalising your user experience, and identifying technical issues.

Under the Data Privacy Act of 2012, clobph relies on the following legal bases for processing your personal data:

• Contractual necessity: Processing that is necessary to fulfil our contract with you — including account management, KYC verification, game provision, and payment processing — is carried out on the basis that it is required to perform the services you have requested.
• Legal obligation: Processing carried out to comply with applicable laws — including AML reporting, age verification, and regulatory record-keeping — is performed on the basis of legal obligation.
• Legitimate interests: Processing for the purposes of fraud prevention, platform security, responsible gaming monitoring, and internal analytics is carried out on the basis of clobph's legitimate business interests, where those interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications is carried out only on the basis of your freely given, specific, and informed consent. You may withdraw this consent at any time with effect from the date of withdrawal.

clobph does not sell, rent, or trade your personal data. We share personal data only in the following limited and documented circumstances:

• KYC and identity verification providers: Authorised third-party identity verification services that process your ID documents and selfie/liveness data solely for the purpose of completing your KYC verification on behalf of clobph.
• Payment processors: GCash, Maya, BPI, BDO, UnionBank, 7-Eleven, Coins.ph, and USDT network infrastructure providers, to the extent necessary to process your deposits and withdrawals.
• Fraud prevention and AML screening services: Third-party providers that assist clobph in detecting fraudulent activity and screening against sanctions and watchlists, as required by the AMLA and its implementing rules.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers that process data on clobph's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: The Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities where disclosure is required by law, court order, or regulatory directive.
• Professional advisers: Legal counsel, auditors, and compliance advisers bound by professional confidentiality obligations, where their services require access to personal data.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all of clobph's assets, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

clobph uses cookies and similar tracking technologies to operate the platform, personalise your experience, and analyse usage patterns. The following categories of cookies are used on clobph.net:

• Strictly necessary cookies: These cookies are essential for the platform to function and cannot be disabled. They include session management cookies, security tokens, and cookies that remember your login state.
• Functional cookies: These cookies remember your preferences — such as your preferred language, display settings, and responsible gaming limits — to provide a personalised experience across sessions.
• Analytics cookies: clobph uses anonymised analytics tools to understand how players interact with the platform, which pages are most visited, and where technical errors occur. This data is aggregated and does not identify individual users.
• Fraud prevention cookies: Certain cookies assist clobph's fraud detection systems by establishing device fingerprints and detecting anomalous login or payment patterns.

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to use the clobph platform. clobph does not use third-party advertising or behavioural tracking cookies.

clobph retains your personal data only for as long as is necessary for the documented purpose for which it was collected, or as required by applicable law. The following retention guidelines apply:

• Account data and KYC documents: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements under the AMLA.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with applicable financial record-keeping regulations.
• Gaming and betting history: Retained for the duration of your active account and for a minimum of three (3) years following account closure, for audit and dispute resolution purposes.
• Customer support communications: Retained for a period of three (3) years from the date of the last communication in a support thread.
• Marketing consent records: Retained for the duration of your account and for two (2) years following account closure or consent withdrawal, as evidence of consent status.
• Technical and log data: Retained for a rolling period of twelve (12) months for security monitoring and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with clobph's internal data destruction procedures. Where data is anonymised rather than deleted, it may be retained indefinitely for aggregate analytics purposes.

Under the Data Privacy Act of 2012, as a data subject you are entitled to exercise the following rights in respect of your personal data held by clobph. To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 15.

clobph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption in transit: All data transmitted between your device and clobph servers is encrypted using 256-bit SSL/TLS protocols. clobph enforces HTTPS across all platform endpoints.
• Encryption at rest: Sensitive personal data — including KYC document files, payment details, and identity information — is encrypted at rest using AES-256 encryption in clobph's data storage infrastructure.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. clobph employees and contractors are granted access to personal data only to the extent required for their specific job function, and all access is logged and audited.
• Two-factor authentication: All internal clobph staff accounts with access to personal data systems are protected by mandatory two-factor authentication.
• Security monitoring: clobph employs continuous security monitoring, intrusion detection, and anomaly alerting systems to identify and respond to potential security incidents promptly.
• Penetration testing: clobph conducts periodic third-party penetration testing of its platform infrastructure to identify and remediate vulnerabilities before they can be exploited.

The clobph platform is strictly intended for individuals who are 21 years of age or older. clobph does not knowingly collect personal data from individuals under the age of 21. The 21+ minimum age requirement is a mandatory condition of registration and is actively enforced through our KYC verification process.

If clobph discovers that it has inadvertently collected personal data from a person under the age of 21, that data will be deleted as promptly as possible and the associated account will be suspended in accordance with our Terms & Conditions. If you are a parent or guardian and believe your child has registered for a clobph account, please contact our Data Protection Officer immediately using the contact details in Section 15.

clobph's primary data processing infrastructure is located within the Philippines. Where clobph engages third-party service providers — such as cloud infrastructure providers, KYC verification platforms, or fraud detection services — that operate servers outside the Philippines, personal data may be transferred internationally.

Where such international transfers occur, clobph ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses in data processing agreements that require recipient parties to apply data protection standards equivalent to those mandated by the Data Privacy Act of 2012.
• Transfers only to jurisdictions or organisations that provide an adequate level of data protection as recognised under applicable Philippine data privacy regulations.
• Regular due diligence reviews of international data processing partners to verify ongoing compliance with agreed data protection standards.

The clobph platform may contain links to third-party websites or services — for example, links to payment provider portals such as GCash or Maya to complete a transaction. This Privacy Policy applies solely to data processed by clobph and does not extend to third-party websites or services that you access via links on the clobph platform.

clobph is not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of any third-party services you visit, particularly before providing personal data to those services.

clobph reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, platform features, or applicable legal requirements. Where a change is material — meaning it significantly affects how we collect or use your personal data — clobph will provide advance notice via email to your registered address or by a prominent notice on the platform prior to the change taking effect.

The "Last Updated" date at the top of this document reflects the date of the most recent revision. Your continued use of the clobph platform after the effective date of any update constitutes your acknowledgement of the revised Privacy Policy. We recommend reviewing this page periodically to stay informed about how clobph protects your data.

clobph has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the clobph platform after login. For data subject rights requests, please state "Data Privacy Request" at the start of your message.
• Email: [email protected]
• Operating Hours: 24 hours a day, 7 days a week, Philippine Standard Time (PST, UTC+8).

When submitting a data subject rights request, please include your full registered name, account username, the email address associated with your clobph account, and a clear description of your request. This information helps us verify your identity and process your request as efficiently as possible.

If you are not satisfied with clobph's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.