Privacy Policy — vipph.club

1Overview

This Privacy Policy ("Policy") describes how vipph.club ("we," "us," or "the Company") collects, uses, stores, shares, and protects the personal information of users ("you," "Player," or "User") who access or use the vipph.club website, mobile platform, and associated gaming services (collectively, the "Platform").

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

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

2Data We Collect

vipph.club collects personal data that is necessary and proportionate to the purposes described in this Policy. The categories of personal data we collect include:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (for age verification — you must be 21 or older)
• Philippine mobile number or email address used for registration
• Residential address (required for KYC verification and regulatory compliance)
• Government-issued ID details (e.g., Philippine passport number, driver's license number, UMID)

2.2 Financial Data

• GCash or Maya account details (mobile number associated with the e-wallet)
• Bank account details for bank transfer transactions (BPI, BDO, UnionBank, Metrobank, Landbank, PNB, Security Bank)
• Debit card details (card number, expiry — stored in tokenized form only)
• Transaction history including deposits, withdrawals, and gaming activity

2.3 Technical & Usage Data

• IP address and approximate geographic location
• Device type, operating system, and browser information
• Session duration, pages visited, and features used on the Platform
• Login timestamps and access logs
• Cookies and similar tracking technologies (see Section 9)

2.4 Communications Data

• Records of your communications with our customer support team via live chat or email
• Feedback, complaints, and dispute records
• Responses to surveys or promotional communications (where you have opted in)

3How We Collect Data

vipph.club collects your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, or contacting our support team.
• Automated collection: 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 licensed KYC service providers; fraud detection signals from payment processors; and publicly available information used for compliance screening.

4Purpose of Processing

We process your personal data for the following purposes:

Purpose	Data Used
Account registration & management	Identity, contact, and login data
Age & identity verification (KYC)	Identity data, government ID details
Payment processing	Financial data, identity data
Fraud prevention & security	Technical data, financial data, identity data
Regulatory compliance & AML	Identity data, financial data, transaction history
Customer support	Communications data, account data
Platform improvement	Technical & usage data (anonymized where possible)
Responsible gaming monitoring	Gaming activity, session data, financial data
Marketing communications (opt-in only)	Contact data, gaming preferences

5Legal Basis for Processing

Under the Data Privacy Act of 2012, vipph.club processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) requirements, gaming regulations, and tax obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our legitimate interests are not overridden by your rights.
• Consent: Processing for optional purposes such as marketing communications, where you have provided explicit, informed consent. You may withdraw consent at any time by contacting our support team or updating your account preferences.

6Data Sharing

vipph.club 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 and subject to appropriate data protection safeguards:

6.1 Service Providers

We engage trusted third-party service providers who process personal data on our behalf, including KYC and identity verification providers, payment processors (GCash, Maya, and partner banks), cloud hosting and infrastructure providers, customer support platform providers, and fraud detection and cybersecurity vendors. All service providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

6.2 Regulatory & Law Enforcement Authorities

We may disclose your personal data to Philippine government agencies, regulatory bodies, law enforcement authorities, or courts where we are legally required to do so — for example, in response to a court order, subpoena, or regulatory investigation. We will notify you of such disclosures where permitted by law.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and ensure that the receiving entity is bound by privacy obligations no less protective than those in this Policy.

7Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Data Category	Retention Period	Reason
Account & identity data	Duration of account + 5 years after closure	Regulatory & AML compliance
Financial & transaction records	10 years from transaction date	Philippine AML Act requirements
KYC documents	5 years after account closure	Regulatory compliance
Customer support records	3 years from last interaction	Dispute resolution & quality assurance
Technical & usage logs	12 months on a rolling basis	Security monitoring & fraud prevention
Marketing preferences	Until consent is withdrawn	Consent-based processing

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with any individual. Where anonymization is not technically feasible, data is securely destroyed in accordance with our data disposal procedures.

8Data Security

vipph.club implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption at rest for sensitive personal data stored in our databases, including financial data and government ID details.
• Payment card tokenization — we do not store raw card numbers; debit card details are replaced with secure tokens managed by our payment processor.
• Multi-factor authentication (MFA) available for player accounts and mandatory for all internal staff accessing personal data systems.
• Role-based access controls ensuring that only authorized personnel with a legitimate need can access personal data.
• Regular security audits and penetration testing conducted by independent cybersecurity professionals.
• Incident response procedures — in the event of a data breach affecting your personal data, we will notify you and the National Privacy Commission within the timeframes required by law.

9Cookies & Tracking Technologies

vipph.club uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session state, and gather analytics data that helps us improve our services. The types of cookies we use are described below:

Cookie Type	Purpose	Duration
Strictly Necessary	Required for the Platform to function — session management, login state, security tokens	Session / up to 24 hours
Functional	Remember your preferences such as language, game settings, and responsible gaming limits	Up to 12 months
Analytics	Aggregate, anonymized data on how players use the Platform — used to improve features and performance	Up to 24 months
Security	Fraud detection, bot prevention, and suspicious activity monitoring	Session / up to 30 days

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling strictly necessary cookies may affect the functionality of the Platform, including your ability to log in and play games. We do not use third-party advertising cookies or behavioral tracking cookies for cross-site advertising purposes.

10Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by vipph.club:

• Right to be Informed: You have the right to know what personal data we collect about you, how it is used, and with whom it is shared — as set out in this Policy.
• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is processed.
• 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 or updated.
• 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 have the right to 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, machine-readable format so that you can transfer it to another service provider.
• Right to Lodge a Complaint: If you believe your data rights have been violated, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC).

11Minors

vipph.club is strictly an adult gaming platform. We do not knowingly collect personal data from individuals under the age of 21. Registration on the Platform requires confirmation that you are at least 21 years of age, and we conduct mandatory age verification as part of the KYC process.

12International Data Transfers

Some of our service providers — including cloud infrastructure providers and KYC verification vendors — may process your personal data outside of the Philippines. Where such international transfers occur, vipph.club ensures that appropriate safeguards are in place to protect your data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law.
• Transfers only to jurisdictions or organizations that provide an adequate level of data protection as recognized by the National Privacy Commission.
• Regular review of our international data transfer arrangements to ensure ongoing compliance.

By using the Platform, you acknowledge and consent to the transfer of your personal data to service providers located outside the Philippines, subject to the safeguards described above.

13Changes to This Policy

vipph.club reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email or an in-platform notification at least 7 days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically to stay informed about how we protect your personal data. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised Policy.

14Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way vipph.club handles your personal data, please contact our Data Protection Officer: