codph Privacy Policy

This Policy applies to all personal information processed by codph in connection with the operation of its online gaming platform, including information collected through the codph website at codph.vip, any related mobile-optimized interfaces, live chat and customer support interactions, payment processing activities, and promotional or marketing communications directed at registered players.

This Policy does not govern the data practices of third-party game providers, payment processors, or other service partners who may have their own independent privacy policies. Where codph engages third parties to process personal data on its behalf, codph requires those parties to maintain appropriate data protection standards consistent with applicable Philippine law.

For the purposes of the Data Privacy Act of 2012 and applicable data protection law, codph is the personal information controller responsible for your data. codph determines the purposes and means of processing personal data collected through the codph.vip platform and associated services.

codph has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection legislation. Contact details for the DPO are provided in Section 14 of this Policy.

codph collects personal information through multiple touchpoints during your interaction with the platform. The categories of personal data we collect are described below:

A. Information You Provide Directly

• Registration Data: Full legal name, date of birth, Philippine mobile number, email address, username, and password (stored in hashed form)
• Identity Verification Documents: Government-issued ID (e.g., PhilSys National ID, passport, driver's licence, SSS/GSIS card), selfie or video verification data submitted in compliance with Know Your Customer (KYC) requirements
• Financial Information: GCash mobile number, Maya account details, bank account numbers (BPI, BDO, Metrobank, etc.), and Visa/Mastercard information used for deposits and withdrawals — processed through PCI-DSS compliant payment channels
• Address Information: Residential or mailing address in the Philippines (required for enhanced verification)
• Support Communications: Chat logs, email correspondence, and records of disputes or complaints submitted to the codph support team

B. Information Collected Automatically

• Device & Technical Data: IP address, device type and model, operating system, browser type and version, screen resolution, and mobile network provider
• Usage Data: Pages visited, game sessions initiated, bet amounts, game outcomes, session durations, login timestamps, and navigation paths within the codph platform
• Location Data: Approximate geographic location derived from IP address (country and city level) for regulatory compliance and fraud detection purposes
• Cookie & Tracking Data: Data collected via cookies, pixel tags, and similar technologies as described in Section 7

C. Information from Third Parties

• Identity verification data from licensed KYC service providers operating in the Philippines
• Fraud risk scores and device reputation data from fraud prevention service providers
• Payment verification data from GCash, Maya, and banking partners solely for transaction authentication

codph processes your personal information for the following purposes:

• Account Registration & Management: Creating and maintaining your codph player account, authenticating your identity at login, and managing account settings and preferences
• Identity & Age Verification: Verifying that you meet the minimum age requirement of 21 years in compliance with PAGCOR regulations and applicable Philippine gaming law
• Payment Processing: Facilitating deposits and withdrawals via GCash, Maya, bank transfer, and other accepted payment methods, and maintaining accurate transaction records
• Regulatory & Legal Compliance: Fulfilling obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Terrorism Financing Prevention and Suppression Act, and the Data Privacy Act of 2012
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, unauthorized access, collusion, bonus abuse, and other prohibited conduct on the codph platform
• Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance through the codph live chat and email support channels
• Responsible Gaming: Monitoring gaming behaviour to identify patterns associated with problem gambling, enforcing self-imposed limits and self-exclusion requests, and providing responsible gaming interventions where appropriate
• Platform Improvement: Analysing aggregated usage data to improve the codph platform's performance, stability, and user experience for Filipino players
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have provided their consent to receive marketing communications. You may withdraw consent at any time by updating your account communication preferences

Under the Data Privacy Act of 2012, codph processes your personal information on the basis of one or more of the following lawful criteria:

• Consent: Where you have given clear and specific consent to the processing of your personal data for a particular purpose, including marketing communications and optional enhanced features. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.
• Contractual Necessity: Processing is necessary for the performance of the contract between you and codph — specifically, the Terms & Conditions you accepted upon registration — including account management, transaction processing, and customer support.
• Legal Obligation: Processing is necessary for codph to comply with applicable Philippine law, including PAGCOR licensing requirements, AMLA reporting obligations, and RA 10173 compliance requirements.
• Legitimate Interests: Processing is necessary for the legitimate interests of codph or third parties, including fraud detection, platform security, responsible gaming monitoring, and the prevention of illegal activity, provided those interests are not overridden by your data protection rights.

codph does not sell, rent, or trade your personal information to third parties for their own marketing or commercial purposes. Your personal data may be shared with third parties only in the following limited circumstances:

• Service Providers & Processors: Third-party vendors engaged by codph to provide services on its behalf, including payment processors (GCash, Maya, banking partners), KYC verification providers, fraud prevention services, cloud infrastructure providers, customer support platform providers, and analytics services. These providers are contractually bound to process your data only on codph's documented instructions and to maintain appropriate security standards.
• Game Providers: Licensed game studios and live casino operators whose games are hosted on the codph platform may receive limited technical and gameplay data necessary to operate their games correctly. Game providers are required to comply with applicable data protection obligations.
• Regulatory & Law Enforcement Authorities: PAGCOR and other Philippine government bodies, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies, where disclosure is required by law, court order, or regulatory directive.
• Business Transfers: In the event of a merger, acquisition, or transfer of codph's business or assets, your personal data may be transferred to the successor entity, subject to equivalent privacy protections.
• With Your Consent: Any other sharing of your personal information will only occur with your prior explicit consent.

codph uses cookies and similar tracking technologies on its website to enhance platform functionality, maintain user sessions, and collect usage analytics. Below is a summary of the types of cookies used:

• Strictly Necessary Cookies: Required for the platform to function correctly, including session authentication, security tokens, and load balancing. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, game volume, and display preferences to personalise your codph experience across sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate and use the codph platform, used solely to improve platform performance and user experience.
• Security Cookies: Support fraud detection, device fingerprinting for login anomaly detection, and session integrity verification.

You may manage cookie preferences through your browser settings. Disabling certain categories of cookies may affect platform functionality. codph does not use third-party advertising cookies or share cookie data with advertisers.

codph retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention guidelines apply:

• Active Account Data: Retained for the duration of your active player relationship with codph
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of transaction, as required under Philippine AMLA regulations
• KYC & Identity Documents: Retained for a minimum of five (5) years from account closure or the last transaction date, consistent with PAGCOR and AMLC requirements
• Support Communications: Customer support records are retained for three (3) years from the date of the last interaction
• Marketing Data: Retained until you withdraw consent for marketing communications or request erasure, subject to overriding legal requirements
• Closed Account Data: Data associated with closed accounts is retained for the legally required periods outlined above, after which it is securely deleted or anonymised

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

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

• Encryption in Transit: All data transmitted between your device and codph's servers is protected by 256-bit SSL/TLS encryption
• Encryption at Rest: Sensitive personal data stored on codph servers is encrypted using industry-standard encryption protocols
• Access Controls: Personal data is accessible only to codph staff and authorised service providers on a strict need-to-know basis, enforced through role-based access control policies
• Password Security: Account passwords are stored using one-way cryptographic hashing; codph staff cannot view your password in plain text
• Two-Factor Authentication: Optional SMS-based two-factor authentication is available to all registered codph players to protect account access
• Fraud & Intrusion Detection: Automated security monitoring systems operate continuously to detect and respond to unauthorised access attempts and suspicious account activity
• PCI-DSS Compliance: Payment card data is processed through PCI-DSS compliant payment infrastructure; codph does not store full card numbers on its own servers

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by codph. To exercise any of these rights, please contact codph's Data Protection Officer using the contact details in Section 14.

The codph platform is strictly for adults aged 21 years and older in accordance with Philippine gaming regulations. codph does not knowingly collect personal information from individuals under 21 years of age. Age verification is performed during the registration process and may be subject to additional documentary verification at any time.

If codph discovers or is notified that it has inadvertently collected personal data from a person under the age of 21, it will immediately suspend the associated account, return any deposited funds (less any bonuses claimed), delete the personal data in question, and report the matter to PAGCOR as required by applicable regulation. If you believe that a minor has registered an account on codph, please contact our support team immediately via live chat.

Some of codph's service providers, including cloud infrastructure, game providers, and certain fraud prevention services, may be located outside the Philippines. Where personal data is transferred to a third country, codph ensures that:

• The recipient country provides an adequate level of data protection comparable to RA 10173 standards, or
• Appropriate contractual safeguards are in place between codph and the third-party recipient, including standard data processing agreements that bind the recipient to obligations equivalent to those applicable in the Philippines

By using the codph platform, you acknowledge that your personal data may be processed in countries outside the Philippines. codph takes all reasonable steps to ensure such transfers are conducted lawfully and securely.

codph reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Where changes are material, codph will notify registered players via email or a prominent in-platform notification prior to the changes taking effect.

The date of the most recent update to this Policy is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how codph handles your personal information. Your continued use of the codph platform following the posting of changes constitutes your acceptance of the updated Policy.

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the codph Data Protection Officer through the following channels:

• Live Chat: Available 24/7 directly from the codph platform — the fastest way to reach our team for privacy-related inquiries
• Email: [email protected] — please include "Privacy Request" or "Data Subject Request" in the subject line for prioritised routing
• Response Timeline: The DPO will acknowledge receipt of your request within 3 business days and provide a substantive response within 15 business days

If you are not satisfied with codph's handling of your privacy concern after raising it with the DPO, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through its official channels. codph cooperates fully with NPC investigations and inquiries.