codph Privacy Policy
How codph Protects Your Privacy
These highlights summarise our key privacy commitments. They do not replace the full Privacy Policy below. All codph players should read the complete document to fully understand how their data is handled.
Philippine DPA Compliance
codph processes all personal data strictly in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and the regulations of the National Privacy Commission (NPC). Your rights under Philippine law are fully respected.
Bank-Grade Encryption
All data transmitted between your device and the codph platform is protected using TLS 1.3 encryption. Sensitive data at rest — including financial records and identification documents — is stored using AES-256 encryption standards.
No Data Selling
codph does not sell, rent, or trade your personal data to third-party marketers or data brokers under any circumstances. Your information is used only for platform operations, legal compliance, and improving your codph experience.
Your Data Rights
As a codph player and a data subject under Philippine law, you have the right to access, correct, delete, object to processing, and port your personal data. All requests are handled within 15 business days by our dedicated Data Protection Officer.
Minimal Data Collection
codph collects only the personal data that is strictly necessary for account operation, KYC verification, regulatory compliance, and service delivery. We do not collect data beyond what is required for a legitimate, documented purpose.
PAGCOR & NPC Obligations
As a PAGCOR-licensed operator, codph shares specific player data with PAGCOR and the Anti-Money Laundering Council (AMLC) as required by Philippine gaming law. All regulatory disclosures are made under strict legal authority only.
About This Policy: This Privacy Policy ("Policy") describes how codph ("we," "us," "our," "the Platform") collects, uses, discloses, retains, and protects the personal data of individuals ("you," "Player," "User," "Data Subject") who access or use the codph online gaming platform at codph.cam. By creating a codph account or using any service on this platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.
1 Introduction
codph is a PAGCOR-regulated online gaming platform operating in the Philippines. We are committed to protecting the privacy and personal data of all players and visitors who interact with our platform. This Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission (NPC).
This Policy applies to all personal data processed by codph in connection with the operation of the codph platform, including data collected through the codph.cam website, mobile-optimised interfaces, customer support channels, and promotional communications. It covers players located in the Philippines and applies to all processing activities conducted by codph directly or through authorised third-party service providers acting on our behalf.
Reading this Policy in full is strongly encouraged before registering a codph account or submitting any personal information to the platform. If you have any questions, our Data Protection Officer (DPO) can be reached at the contact details provided in Section 14 of this Policy.
2 Data Controller
codph is the personal information controller ("PIC") for all personal data collected and processed through the codph platform. As the PIC, codph determines the purposes and means of processing your personal data and is responsible for ensuring that all processing activities comply with the Philippine Data Privacy Act and applicable PAGCOR data governance requirements.
codph has appointed a Data Protection Officer (DPO) who oversees data governance, manages Data Subject Access Requests (DSARs), and acts as the primary point of contact with the National Privacy Commission. The DPO's contact information is provided in Section 14 of this Policy.
codph's registration as a Personal Information Controller with the National Privacy Commission (NPC) is maintained in accordance with NPC Circular No. 17-01. PAGCOR as the licensing authority may also access relevant player data in its regulatory capacity.
3 Personal Data We Collect
codph collects only the personal data necessary to operate the platform, comply with legal obligations, and deliver the gaming services offered. The categories of personal data we collect include:
3.1 Identity & Contact Data
- Full legal name as it appears on your government-issued Philippine identification document
- Date of birth (used to verify the 21+ age requirement under PAGCOR regulations)
- Philippine mobile number used for account registration and OTP verification
- Residential address within the Philippines
- Email address (where provided)
- Government-issued Philippine ID number and a copy of the ID document for KYC verification
3.2 Financial & Transaction Data
- GCash or Maya account number linked to your codph wallet
- Philippine bank account details (BPI, BDO, Metrobank, or other accepted banks) where used for deposits or withdrawals
- Transaction history including deposit amounts, withdrawal requests, and game wagering records
- Source-of-funds documentation where requested for high-value transactions under PAGCOR AML requirements
3.3 Technical & Usage Data
- IP address and general geographic location derived from it
- Device type, browser type, operating system, and screen resolution
- Login timestamps, session durations, and navigation patterns within the codph platform
- Game play history, betting amounts, and gaming session data
- Communications with codph customer support, including chat transcripts and email records
3.4 Sensitive Personal Information
In limited circumstances, codph may process sensitive personal information as defined under the Philippine Data Privacy Act, specifically where required for KYC compliance. This may include government ID numbers (e.g., PSA-issued UMID, PhilSys National ID, or TIN). Such data is processed only under explicit legal authority and is subject to heightened security controls.
4 How We Collect Your Data
codph collects personal data through the following channels:
- Direct Registration: When you create a codph account, you provide identity, contact, and date-of-birth information directly through the registration form
- KYC Submission: When you submit identification documents to complete the Know Your Customer verification process prior to withdrawal processing
- Payment Transactions: Financial data is collected when you make deposits or withdrawal requests through GCash, Maya, or bank transfer channels
- Platform Use: Technical and usage data is collected automatically as you navigate and interact with the codph platform through cookies, server logs, and analytics tools
- Customer Support: When you contact codph via email or live chat, the contents of those communications are retained as part of your account record
- Third-Party Verification: codph may receive data from identity verification service providers engaged to assist with KYC, age verification, and fraud prevention
5 Purposes & Legal Basis for Processing
codph processes your personal data only where there is a lawful basis for doing so under the Philippine Data Privacy Act. The following table sets out the primary purposes for which your data is processed and the corresponding legal basis under RA 10173:
| Purpose of Processing | Legal Basis |
|---|---|
| Account registration and management | Performance of contract (your codph account agreement) |
| Age verification (21+ PAGCOR requirement) | Legal obligation (PAGCOR regulations) |
| KYC identity verification | Legal obligation (PAGCOR and AMLC requirements) |
| Processing deposits and withdrawals | Performance of contract |
| Anti-money laundering monitoring | Legal obligation (Anti-Money Laundering Act, RA 9160) |
| Regulatory reporting to PAGCOR and AMLC | Legal obligation |
| Fraud detection and account security | Legitimate interests of codph and player protection |
| Responsible gaming monitoring | Legal obligation (PAGCOR responsible gaming requirements) and legitimate interests |
| Promotional communications (opt-in only) | Consent |
| Platform analytics and improvement | Legitimate interests of codph |
| Customer support services | Performance of contract and legitimate interests |
Where processing is based on your consent — specifically for marketing communications — you have the right to withdraw that consent at any time by contacting codph support at the email address in Section 14. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
6 Data Sharing & Disclosure
codph does not sell, rent, or commercially transfer your personal data to third parties. However, in the course of operating a PAGCOR-licensed online gaming platform and fulfilling legal obligations under Philippine law, your data may be shared with the following categories of recipients:
6.1 Regulatory Authorities
codph shares player data with the Philippine Amusement and Gaming Corporation (PAGCOR) and the Anti-Money Laundering Council (AMLC) as required under our operating license and applicable Philippine law. This includes player registration data, transaction records, and suspicious activity reports. Such disclosures are made under strict legal authority and are not subject to your prior consent.
6.2 Identity Verification Providers
codph engages third-party KYC and identity verification service providers to assist with document verification and age confirmation. These providers act as personal information processors under written data processing agreements that obligate them to process your data only on codph's instructions and in compliance with the Philippine Data Privacy Act.
6.3 Payment Service Providers
Transaction data is shared with GCash, Maya, and Philippine bank partners to the extent necessary to process deposits and withdrawals. These providers operate their own privacy policies and are governed by Bangko Sentral ng Pilipinas (BSP) regulations.
6.4 Game Content Providers
Anonymised or pseudonymised gameplay data (such as session duration and wager amounts) may be shared with game software providers — including JILI, PG Soft, Pragmatic Play, and Evolution Gaming — for the purpose of game performance analytics, RTP auditing, and responsible gaming monitoring. Personal identity data is not disclosed to game providers.
6.5 Law Enforcement
codph will disclose personal data to Philippine law enforcement agencies, the National Bureau of Investigation (NBI), or other competent government bodies where required by a valid court order, subpoena, or other lawful demand, or where disclosure is necessary to protect the safety of players or third parties.
No Cross-Border Transfers Without Safeguards: codph does not transfer your personal data outside the Philippines unless appropriate safeguards are in place, including standard contractual clauses approved by the NPC or where the transfer is to a country with an adequate level of data protection as determined by the NPC.
7 Data Retention
codph retains your personal data only for as long as is necessary to fulfil the purposes set out in this Policy, or as required by law, whichever is longer. The following retention periods apply:
- Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR and the Anti-Money Laundering Act
- Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLC record-keeping requirements
- Customer support records: Retained for three (3) years from the date of the last support interaction
- Marketing consent records: Retained for the duration of consent validity plus two (2) years following consent withdrawal
- Technical and server log data: Retained for a maximum of twelve (12) months, unless retention is required for an active investigation or legal proceeding
Upon expiry of the applicable retention period, personal data will be securely deleted, anonymised, or destroyed in a manner that renders it unrecoverable. Where data cannot be immediately deleted due to ongoing legal proceedings or regulatory requirements, it will be restricted from active processing pending deletion.
8 Security Measures
codph implements comprehensive technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security programme includes:
- TLS 1.3 encryption for all data in transit between your device and the codph platform
- AES-256 encryption for sensitive data at rest, including financial records and ID document scans
- Two-factor authentication (2FA) available for all codph player accounts
- Role-based access controls ensuring codph staff access only the data required for their specific function
- Regular penetration testing and vulnerability scanning of the codph platform infrastructure
- 24/7 automated fraud and anomaly detection systems monitoring for suspicious account activity
- Secure data centre hosting with physical access controls, CCTV monitoring, and environmental protections
- Regular staff training on data privacy obligations and the handling of sensitive personal information
Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in risk to the rights and freedoms of Data Subjects, codph will notify the NPC within 72 hours of becoming aware of the breach and will notify affected players within a reasonable timeframe, as required by the Philippine Data Privacy Act.
9 Cookies & Tracking Technologies
codph uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit codph.cam. The following categories of cookies are used:
- Strictly Necessary Cookies: Essential for platform functionality — these include session authentication tokens, security cookies, and load-balancing identifiers. These cannot be disabled without impairing platform use.
- Performance & Analytics Cookies: Collect anonymised data about how players navigate the codph platform to help us identify performance issues and improve user experience. No personally identifiable information is collected by these cookies.
- Functionality Cookies: Remember your preferences — such as language settings and game lobby configuration — to provide a more personalised codph experience.
- Responsible Gaming Cookies: Track session duration and activity patterns to trigger responsible gaming alerts and cooling-off reminders as required by PAGCOR.
codph does not use third-party advertising cookies or permit behavioural advertising networks to track players across the platform. You may manage cookie preferences through your browser settings, noting that disabling strictly necessary cookies will affect platform functionality. Continued use of codph after notification of our cookie use constitutes consent to the use of cookies as described in this section.
10 Your Privacy Rights Under Philippine Law
As a Data Subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by codph:
| Right | What It Means at codph |
|---|---|
| Right to Be Informed | You have the right to be told what personal data codph holds about you, how it is used, and with whom it is shared — which this Policy provides. |
| Right of Access | You may request a copy of the personal data codph holds about your account. We will respond to access requests within 15 business days. |
| Right to Rectification | You may request correction of inaccurate or incomplete personal data. Some corrections (e.g., name changes) require supporting documentation. |
| Right to Erasure | You may request deletion of your personal data where it is no longer necessary, subject to overriding legal retention obligations (e.g., AMLC 5-year records). |
| Right to Object | You may object to processing based on legitimate interests, including direct marketing. Objections to marketing are processed immediately upon receipt. |
| Right to Data Portability | You may request your personal data in a structured, commonly used machine-readable format for transfer to another service where technically feasible. |
| Right to File a Complaint | You have the right to file a complaint with the National Privacy Commission (NPC) at privacy.gov.ph if you believe codph has violated your data privacy rights. |
To exercise any of the rights above, submit a written request to codph's Data Protection Officer at the contact details provided in Section 14. Please include your codph account username and a copy of a valid Philippine government-issued ID to verify your identity before your request is processed. codph will not charge a fee for reasonable Data Subject Access Requests.
11 Children & Minors
codph does not knowingly collect personal data from individuals under 21 years of age. The platform is strictly restricted to adults aged 21 and above in compliance with PAGCOR's minimum age requirements for casino-style gaming in the Philippines. Age verification is conducted at registration and again prior to withdrawal processing.
If codph becomes aware that personal data has been collected from an individual under the age of 21, the relevant account will be immediately suspended, the data will be securely deleted to the extent not required for regulatory reporting, and any deposits will be refunded where practicable. If you believe a minor has registered a codph account, please notify our Data Protection Officer immediately at the contact details in Section 14.
12 Third-Party Links
The codph platform may contain references to third-party services — such as payment providers GCash and Maya — in the context of transaction processing. codph does not operate those third-party platforms and is not responsible for their privacy practices. Each third-party service is governed by its own privacy policy. codph encourages all players to review the privacy policies of any third-party service they interact with in connection with their codph account.
No third-party advertising networks are embedded in the codph platform, and codph does not permit third parties to collect personal data about codph players through the platform without explicit authorisation and appropriate data processing agreements.
13 Amendments to This Policy
codph reserves the right to amend this Privacy Policy at any time to reflect changes in legal requirements, PAGCOR directives, NPC guidance, or our data processing practices. Material amendments will be communicated to registered players via a platform notification displayed upon next login and, where appropriate, via SMS to your registered Philippine mobile number.
The effective date at the top of this Policy will be updated to reflect the date of the most recent revision. If you do not agree with a material amendment to this Policy, you have the right to close your codph account and request deletion of your personal data, subject to applicable legal retention periods. Continued use of the codph platform following notice of an amendment constitutes acceptance of the revised Policy.
14 Contact Us & Data Protection Officer
All privacy-related enquiries, Data Subject Access Requests (DSARs), complaints, and concerns regarding codph's data processing practices should be directed to the codph Data Protection Officer. The email address below is provided for written correspondence only and is not a clickable link:
Data Protection Officer: codph Data Protection Office
DPO Email: [email protected]
Response Time: Within 15 business days of receiving a complete DSAR
Jurisdiction: Republic of the Philippines — governed by RA 10173 and PAGCOR regulation
If you are not satisfied with codph's response to your privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines. General enquiries about your codph account may also be directed to our customer support team, available 24 hours a day, seven days a week.
For responsible gaming concerns, self-exclusion requests, or deposit limit adjustments, please refer to our Responsible Gaming page.
Your Data Is Safe at codph
We take your privacy seriously — that's why codph is built on Philippine DPA compliance, PAGCOR regulation, and bank-grade security from day one. Ready to explore the platform?