codph Privacy Policy

Last Updated: June 2026

1. Introduction and Scope

This Privacy Policy ("Policy") describes how codph ("we," "us," or "codph") collects, uses, discloses, and safeguards the personal data of individuals ("you," "Player," or "User") who access or use the codph online gaming platform at codph.club (the "Platform").

This Policy applies to all personal data processed by codph in connection with the Platform, including data collected during account registration, identity verification, deposits and withdrawals, gameplay, customer support interactions, and marketing communications. By registering for or using the codph Platform, you acknowledge that you have read, understood, and agreed to the practices described in this Policy.

codph operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

2. Data Controller Information

codph is the data controller responsible for your personal data collected through the Platform. For all data privacy matters, you may contact our designated Data Protection Officer (DPO) at the email address provided in Section 14 of this Policy.

3. Personal Data We Collect

codph collects the following categories of personal data, depending on how you interact with the Platform:

• Identity Data: Full name, date of birth, nationality, government-issued ID number (e.g., passport, driver's license, PhilSys ID, UMID, SSS/GSIS ID).
• Contact Data: Email address, mobile phone number, residential address (barangay, city/municipality, province, region).
• Financial Data: GCash mobile number, PayMaya account reference, bank account details (BPI, BDO, Metrobank), partial card numbers for Visa/Mastercard, transaction history, deposit and withdrawal records.
• Account Data: Username, password (hashed), account balance, betting history, bonus redemption records, responsible gaming settings.
• Technical Data: IP address, device type and model, browser type and version, operating system, session timestamps, geolocation data (city/region level).
• Usage Data: Pages visited, games played, session duration, promotional content interacted with, search queries within the Platform.
• Communications Data: Records of your interactions with codph customer support, including live chat transcripts, email correspondence, and support ticket content.
• Verification Documents: Copies of government-issued identification and proof of address submitted for KYC compliance.

4. How We Collect Your Data

codph collects personal data through the following channels:

• Direct Provision: Data you provide when registering a codph account, completing KYC verification, making deposits or withdrawals, contacting support, or updating your profile.
• Automated Collection: Technical and usage data collected automatically through cookies, web beacons, and server logs when you access the codph Platform.
• Third Parties: Identity verification data from KYC service providers; fraud screening data from payment processors; geolocation data from IP resolution services.

5. Purposes and Legal Bases for Processing

codph processes your personal data for the following purposes and on the following legal bases:

• Account Management: To create, maintain, and manage your codph account. Legal basis: performance of a contract.
• Identity Verification (KYC): To verify your identity and age (21+) in accordance with PAGCOR guidelines and AML obligations. Legal basis: legal obligation and legitimate interest.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, and bank transfers in PHP. Legal basis: performance of a contract.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, money laundering, and unauthorized account access. Legal basis: legitimate interest and legal obligation.
• Responsible Gaming: To monitor gaming behavior and apply responsible gaming protections, including limit enforcement and self-exclusion. Legal basis: legitimate interest and legal obligation.
• Customer Support: To respond to your inquiries and resolve account issues. Legal basis: performance of a contract and legitimate interest.
• Marketing Communications: To send promotional offers and platform updates where you have provided consent. Legal basis: consent (withdrawable at any time).
• Legal Compliance: To comply with applicable Philippine law, regulatory requirements, court orders, and law enforcement requests. Legal basis: legal obligation.

6. Disclosure of Personal Data to Third Parties

codph does not sell your personal data. We may share your data with the following categories of third parties solely as necessary for the purposes described in this Policy:

• Payment service providers (e.g., GCash, PayMaya, banking partners) for transaction processing.
• KYC and identity verification service providers for regulatory compliance.
• Fraud detection and cybersecurity service providers.
• Game software providers, solely for the purpose of delivering gameplay functionality.
• Regulatory authorities, law enforcement agencies, and courts, where required by Philippine law or PAGCOR regulation.
• Professional advisors (lawyers, auditors) bound by confidentiality obligations.

All third-party service providers engaged by codph are bound by contractual data processing agreements requiring them to handle your data securely and only for the specified purpose.

7. International Data Transfers

Where personal data is transferred outside the Philippines (for example, to cloud hosting or technology service providers), codph ensures that appropriate safeguards are in place, including contractual data protection clauses consistent with the requirements of the Philippine Data Privacy Act and NPC guidelines.

8. Data Retention

codph retains personal data for as long as your account is active and for a period of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and applicable AML regulations. KYC documents may be retained for up to seven (7) years as required by Philippine anti-money laundering law. After the applicable retention period, personal data is securely deleted or anonymized.

9. Cookies and Tracking Technologies

codph uses cookies and similar tracking technologies to operate the Platform efficiently and improve user experience. The types of cookies used include:

• Essential Cookies: Required for the Platform to function. These cannot be disabled without affecting core functionality such as login sessions and account security.
• Analytics Cookies: Used to understand how players navigate the Platform, which games are popular, and where technical issues occur. Data is aggregated and anonymized.
• Preference Cookies: Remember your language, display, and notification preferences to personalize your codph experience.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to access the codph Platform.

10. Security Measures

codph implements technical and organizational security measures proportionate to the sensitivity of the data processed, including: 256-bit SSL/TLS encryption for all data in transit; AES-256 encryption for sensitive data at rest; role-based access controls limiting staff access to personal data on a need-to-know basis; regular penetration testing and vulnerability assessments; two-factor authentication (2FA) available to all account holders; and a documented incident response procedure compliant with NPC breach notification requirements.

11. Your Rights Under Philippine Law

As a data subject under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by codph:

• Right to be Informed: To know how codph collects and processes your personal data.
• Right of Access: To request a copy of the personal data codph holds about you.
• Right to Rectification: To request correction of inaccurate or incomplete personal data.
• Right to Erasure: To request deletion of personal data that is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.
• Right to Object: To object to processing of your data for marketing purposes at any time.
• Right to Data Portability: To receive your personal data in a structured, commonly used format.
• Right to File a Complaint: To lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, submit a written request to codph's Data Protection Officer using the contact details in Section 14. codph will respond to verified requests within 15 business days.

12. Children's Privacy

The codph Platform is strictly prohibited for individuals under 21 years of age. codph does not knowingly collect personal data from minors. If codph becomes aware that personal data has been collected from a person under the age of 21 without verifiable parental consent, that data will be immediately deleted and the associated account terminated. If you have reason to believe a minor has registered a codph account, please contact our support team immediately.

13. Changes to This Privacy Policy

codph may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform functionality. Material changes will be communicated to registered players via email or in-Platform notification at least 7 days prior to taking effect. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Continued use of the codph Platform following the effective date of any revision constitutes your acceptance of the updated Policy.

14. Contact and Complaints

For questions, requests to exercise your data rights, or complaints regarding this Privacy Policy or codph's data practices, contact our Data Protection Officer:

Email: [email protected]

If you are not satisfied with codph's response to a privacy complaint, you may escalate the matter to the National Privacy Commission of the Philippines at privacy.gov.ph.