18club Privacy Policy

1. Overview and Scope

This Privacy Policy ("Policy") describes how 18club ("18club," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "your," or "Player") who access or use the 18club online gaming platform, including our website at 18club.org, any associated mobile applications, and all related services (collectively, the "Platform").

18club is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. We comply with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

By registering an account, accessing the Platform, or otherwise interacting with 18club, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

2. Data Controller Information

For the purposes of applicable data protection legislation, 18club acts as the data controller in respect of the personal data you provide when using the Platform. As data controller, 18club determines the purposes and means of processing your personal data.

If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact our designated Data Protection Officer (DPO) using the contact details provided in Section 16 of this Policy.

3. Personal Data We Collect

18club collects the following categories of personal data from players and prospective players:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth and age verification documentation;
• Residential address (including city, province, and postal code);
• Email address;
• Mobile phone number;
• Government-issued identification numbers (e.g., Philippine passport number, driver's license number, UMID number) — collected solely for KYC/AML compliance purposes.

3.2 Account and Transaction Data

• 18club username and encrypted password;
• Account registration date and history;
• Deposit and withdrawal records, including amounts, dates, and payment method references;
• Bonus and promotion history;
• Wagering history, game session records, and bet outcomes;
• Account balance and transaction logs.

3.3 Technical and Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, login timestamps, and activity logs;
• Pages visited, features used, and navigation patterns within the Platform;
• Cookies and similar tracking technology data (see Section 8).

3.4 Communications Data

• Records of communications between you and 18club customer support, including live chat transcripts and email correspondence;
• Feedback, survey responses, and complaints submitted to 18club.

3.5 Responsible Gaming Data

• Self-exclusion requests and status;
• Deposit limit, loss limit, and session limit settings;
• Responsible gaming assessment responses where voluntarily provided.

4. How We Collect Your Data

18club collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and usage data collected automatically when you access and use the Platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC/AML service providers; fraud detection data from security partners; payment verification data from payment processors such as GCash and Maya.

5. How We Use Your Data

18club processes your personal data for the following purposes:

18club will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

6. Legal Basis for Processing

18club processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC/AML obligations, PAGCOR licensing requirements, and NPC guidelines;
• Legitimate interests: Processing necessary for 18club's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing and Disclosure of Data

18club does not sell your personal data to third parties. 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:

• Payment processors: GCash, Maya, and partner banks, for the purpose of processing deposits and withdrawals;
• KYC/AML service providers: Third-party identity verification and anti-money laundering screening services;
• Fraud prevention partners: Security and fraud detection service providers;
• Game software providers: Licensed game studios and software providers whose games are available on the Platform, to the extent necessary for game operation;
• Regulatory authorities: PAGCOR, the National Privacy Commission, and other Philippine government authorities, where required by law or regulatory obligation;
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where disclosure is necessary to prevent or investigate criminal activity;
• Professional advisers: Legal, accounting, and auditing firms, subject to professional confidentiality obligations.

All third-party service providers who process personal data on behalf of 18club are bound by data processing agreements that require them to process personal data only on 18club's instructions and in accordance with applicable data protection law.

8. Cookies and Tracking Technologies

18club uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather analytics data. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session authentication, security tokens, and load balancing. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences such as language settings, display options, and previously entered information to improve your experience.
• Analytics cookies: Collect aggregated, anonymised data about how players use the Platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Marketing cookies: Used only with your prior consent to deliver relevant promotional content. You may withdraw consent at any time via your account settings or browser controls.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. For a full list of cookies used by 18club, please contact our support team.

9. Data Retention

18club retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 18club's data disposal procedures.

10. Data Security

18club implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and financial information;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While 18club takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 18club will notify you and the National Privacy Commission in accordance with applicable legal requirements.

11. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 18club:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data 18club holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have the right to 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 at any time, and to object to processing based on legitimate interests where your rights override those interests.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 16. We will respond to all verified requests within thirty (30) days, or within such extended period as permitted by applicable law, and will notify you if an extension is required.

12. Children and Minors

The 18club Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with Philippine gambling regulations. 18club does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on the Platform, please contact our support team immediately.

13. International Data Transfers

In the course of providing the Platform and associated services, your personal data may be transferred to and processed in countries outside the Philippines. Where such transfers occur, 18club ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission;
• Implementing standard contractual clauses or binding corporate rules with recipient organisations;
• Obtaining your explicit consent for transfers where required by applicable law.

By using the 18club Platform, you acknowledge and consent to the transfer of your personal data to other countries as described in this section, subject to the safeguards outlined above.

14. Third-Party Services

The 18club Platform may contain links to or integrations with third-party services, including payment processors and game software providers. This Privacy Policy applies solely to data processed by 18club and does not cover the privacy practices of any third-party services.

18club is not responsible for the privacy practices or content of third-party services. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the Platform. All third-party processors engaged by 18club are contractually required to handle your data in compliance with applicable data protection law.

15. Changes to This Policy

18club reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email and by posting a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is indicated at the top of this page. We encourage you to review this Policy periodically to stay informed of how 18club protects your personal data. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 18club, please contact our Data Protection Officer through the following channels:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data protection rights have not been adequately addressed by 18club.