Privacy Policy

Section 01

Introduction

royalclub is committed to protecting the privacy and personal data of every player who uses our platform. This Privacy Policy has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

This policy applies to all personal data collected by royalclub through the royalclub.one website, mobile platform, customer support channels, and any other touchpoints through which you interact with us. It covers data collected during account registration, identity verification (KYC), deposits and withdrawals, gameplay, and communications with our support team.

royalclub operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). As a PAGCOR-regulated platform, we are subject to specific data collection and retention obligations that may require us to process certain personal data regardless of your preferences. Where this is the case, we will always inform you clearly.

We encourage you to read this Privacy Policy in full. If you have any questions about how royalclub handles your personal data, you may contact our Data Protection Officer (DPO) at any time using the contact details provided in Section 13 of this policy.

Section 02

Personal Data We Collect

royalclub collects personal data through several channels. The categories of data we collect, and the circumstances in which we collect them, are described below.

2.1 Data You Provide Directly

When you register a royalclub account, complete KYC verification, make a deposit or withdrawal, or contact our support team, you provide us with personal data including:

Full legal name (as it appears on your government-issued ID)
Date of birth (to verify you are 21 years of age or older)
Residential address (including barangay, city, province, and ZIP code)
Email address and mobile number
Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's license, UMID)
Proof of address documents (e.g., utility bill, bank statement)
Payment method details (e.g., GCash mobile number, PayMaya account, BPI/BDO/Metrobank account details)
Source of funds information (where required for AML compliance)

2.2 Data Collected Automatically

When you access and use the royalclub platform, we automatically collect certain technical and behavioral data, including:

IP address and approximate geographic location
Device type, operating system, and browser information
Session duration, pages visited, and navigation patterns
Game activity logs, including bets placed, games played, and outcomes
Login timestamps and frequency of access
Cookies and similar tracking technologies (see Section 6)

2.3 Data from Third Parties

In certain circumstances, royalclub may receive personal data about you from third parties, including:

Identity verification service providers used to conduct KYC checks
Payment processors and e-wallet providers (GCash, PayMaya, BPI, BDO, Metrobank) for transaction verification
Fraud detection and anti-money laundering screening services
PAGCOR and other regulatory bodies, where required by law

Sensitive Personal Information: Government-issued ID documents and financial account details are classified as sensitive personal information under RA 10173. royalclub processes this data solely for identity verification and payment processing purposes, under strict access controls, and in compliance with NPC guidelines on sensitive personal information.

Section 03

How We Use Your Personal Data

royalclub uses the personal data we collect for the following specific purposes. We do not use your data for any purpose that is incompatible with the purposes listed below without first obtaining your consent or establishing a separate legal basis.

Purpose	Data Used	Legal Basis
Account registration and management	Name, email, mobile number, date of birth	Contract performance
Identity verification (KYC)	Government ID, date of birth, address	Legal obligation (PAGCOR / AML)
Processing deposits and withdrawals	Payment method details, transaction history	Contract performance
Anti-money laundering (AML) compliance	Transaction data, source of funds, ID documents	Legal obligation (AMLA)
Fraud detection and platform security	IP address, device data, behavioral patterns	Legitimate interest
Customer support	Name, email, account history, support communications	Contract performance
Responsible gaming monitoring	Game activity, deposit history, session data	Legal obligation / Legitimate interest
Platform improvement and analytics	Anonymized/aggregated usage data	Legitimate interest
Promotional communications (opt-in only)	Email address, mobile number	Consent

royalclub will never use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have given explicit consent.

Section 04

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, royalclub must have a lawful basis for processing your personal data. Depending on the specific processing activity, we rely on one or more of the following legal bases:

Contract Performance: Processing is necessary to fulfill our contractual obligations to you as a royalclub player — including account management, game access, and payment processing.
Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself.
Legitimate Interest: Processing is necessary for royalclub's legitimate business interests, such as fraud prevention, platform security, and service improvement — provided these interests are not overridden by your privacy rights.
Consent: For certain processing activities — such as sending you promotional emails or SMS notifications about royalclub offers — we will ask for your explicit consent. You may withdraw this consent at any time by contacting our support team or updating your account communication preferences.

Withdrawing Consent: Where royalclub processes your data on the basis of consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. To withdraw consent for marketing communications, contact our support team or use the unsubscribe link in any royalclub marketing email.

Section 05

Data Sharing & Disclosure

royalclub does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We share your personal data only in the following circumstances and only to the extent necessary for the stated purpose:

PAGCOR and Regulatory Authorities: As a PAGCOR-regulated platform, royalclub is required to share certain player data with PAGCOR upon request, including for audit, compliance, and licensing purposes.
Anti-Money Laundering Council (AMLC): royalclub is required by the Anti-Money Laundering Act (Republic Act No. 9160, as amended) to report covered and suspicious transactions to the AMLC. This may involve sharing your personal and financial data without prior notice to you, as required by law.
Identity Verification Providers: We share your ID documents and personal details with accredited KYC service providers to verify your identity. These providers are contractually bound to process your data only for verification purposes and in accordance with RA 10173.
Payment Processors: Transaction data is shared with GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers as necessary to process your deposits and withdrawals.
IT and Platform Service Providers: royalclub uses third-party technology providers for hosting, security, analytics, and customer support infrastructure. These providers act as data processors under our instruction and are bound by data processing agreements that require them to protect your data.
Law Enforcement: royalclub may disclose your personal data to Philippine law enforcement authorities where required by a valid court order, subpoena, or other lawful legal process.

No Unauthorized Sharing: royalclub will never share your personal data with unauthorized third parties. If you receive any communication purporting to be from royalclub that requests your personal data via an unofficial channel, please report it to our support team immediately — it may be a phishing attempt.

Section 06

Cookies & Tracking Technologies

royalclub uses cookies and similar tracking technologies to operate the platform, improve your experience, and fulfill our security and compliance obligations. A cookie is a small text file placed on your device when you visit the royalclub website. Cookies allow us to recognize your device, maintain your session, and remember your preferences.

The types of cookies used by royalclub are as follows:

Strictly Necessary Cookies: These cookies are essential for the royalclub platform to function. They enable core features such as login session management, security token validation, and fraud detection. These cookies cannot be disabled without impairing platform functionality.
Functional Cookies: These cookies remember your preferences — such as your preferred language, display settings, and responsible gaming limits — so you do not need to re-enter them on each visit.
Analytics Cookies: royalclub uses anonymized analytics data to understand how players use the platform, which games are most popular, and where technical issues occur. This data is aggregated and does not identify individual players.
Security Cookies: These cookies help royalclub detect and prevent fraudulent activity, unauthorized account access, and bot traffic on the platform.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect your ability to log in and use the royalclub platform. royalclub does not use third-party advertising cookies or behavioral tracking cookies for marketing purposes.

Section 07

Data Retention

royalclub retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following retention periods apply:

Account Data: Retained for the duration of your active royalclub account, plus a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements.
KYC and Identity Verification Documents: Retained for a minimum of five (5) years following account closure, as required by PAGCOR and the Anti-Money Laundering Act.
Transaction Records: Retained for a minimum of five (5) years following the date of each transaction, in accordance with AMLA requirements.
Customer Support Communications: Retained for three (3) years following the resolution of the relevant support interaction.
Marketing Consent Records: Retained for the duration of your consent, plus three (3) years following withdrawal of consent, to demonstrate compliance with RA 10173.
Technical Logs (IP addresses, session data): Retained for twelve (12) months, unless a longer retention period is required for an ongoing security investigation or legal proceeding.

Upon expiry of the applicable retention period, royalclub will securely delete or anonymize your personal data in accordance with NPC guidelines on data disposal. Anonymized data (which cannot be used to identify you) may be retained indefinitely for statistical and analytical purposes.

Section 08

Data Security

royalclub implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security framework includes:

SSL/TLS Encryption: All data transmitted between your device and royalclub's servers is encrypted using industry-standard SSL/TLS protocols.
Encryption at Rest: Sensitive personal data stored on royalclub's servers — including ID documents and payment details — is encrypted at rest using AES-256 encryption.
Access Controls: Access to personal data is restricted to royalclub staff and service providers who have a legitimate need to access it for their job functions. All access is logged and audited.
Two-Factor Authentication (2FA): royalclub offers 2FA for player accounts to provide an additional layer of protection against unauthorized access.
Regular Security Audits: royalclub conducts regular internal and third-party security audits and penetration testing to identify and remediate vulnerabilities in our platform.
Staff Training: All royalclub staff who handle personal data receive regular training on data protection obligations under RA 10173 and royalclub's internal data security policies.

Data Breach Notification: In the event of a personal data breach that is likely to result in serious harm to affected players, royalclub will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players as soon as reasonably practicable, in accordance with NPC Circular No. 16-03.

Section 09

Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by royalclub. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13.

Right to Be Informed: You have the right to be informed about how royalclub collects, uses, and processes your personal data — which is the primary purpose of this Privacy Policy.
Right of Access: You have the right to request a copy of the personal data that royalclub holds about you, along with information about how it is being processed.
Right to Rectification: If any personal data that royalclub holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to royalclub's legal retention obligations under PAGCOR regulations and the AMLA.
Right to Object: You have the right to object to the processing of your personal data where royalclub relies on legitimate interest as the legal basis, or where your data is being processed for direct marketing purposes.
Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
Right to Lodge a Complaint: If you believe that royalclub has violated your privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

royalclub will respond to all privacy rights requests within thirty (30) days of receipt. In complex cases, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it.

Identity Verification for Rights Requests: To protect your privacy, royalclub will verify your identity before processing any privacy rights request. You may be asked to provide a copy of a government-issued ID to confirm that the request is being made by the account holder.

Section 10

Children & Minors

royalclub is strictly an adult gaming platform. In accordance with Philippine law and PAGCOR's licensing requirements, royalclub does not permit any person under the age of 21 years to register an account, access the platform, or participate in any gaming activity.

royalclub 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 21, we will immediately suspend the relevant account, delete the personal data in question, and handle any funds in the account in accordance with PAGCOR's guidelines on underage gambling.

If you are a parent or guardian and believe that your child under the age of 21 has registered an account on royalclub, please contact our Data Protection Officer immediately using the contact details in Section 13. We will investigate and take appropriate action promptly.

21+ Age Requirement: All royalclub players must be at least 21 years of age. This is a strict legal requirement under Philippine law. royalclub conducts mandatory KYC age verification on all accounts. Accounts that cannot be verified as belonging to a player aged 21 or above will be suspended immediately.

Section 11

International Data Transfers

royalclub's primary operations and data storage are based in the Philippines. However, some of our technology service providers — including cloud hosting providers, KYC verification services, and platform software vendors — may process or store data in servers located outside the Philippines.

Where personal data is transferred outside the Philippines, royalclub ensures that appropriate safeguards are in place to protect your data in accordance with RA 10173 and NPC guidelines on cross-border data transfers. These safeguards include:

Contractual clauses in data processing agreements that require overseas processors to maintain data protection standards equivalent to those required under Philippine law.
Transfers only to countries or organizations that have been assessed as providing an adequate level of data protection.
Regular review of overseas data processors to ensure ongoing compliance with our data protection standards.

royalclub will not transfer your personal data to any overseas recipient that cannot demonstrate adequate data protection safeguards, except where required by Philippine law or where you have given explicit consent to the transfer.

Section 12

Updates to This Privacy Policy

royalclub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When we make material changes to this policy, we will notify registered players via the email address associated with their account and/or by posting a prominent notice on the royalclub platform.

The updated Privacy Policy will take effect on the date specified in the notice. Your continued use of the royalclub platform after the effective date of the updated policy constitutes your acknowledgment of the changes. If you do not agree with the updated policy, you must cease using the platform and may request account closure in accordance with our Terms & Conditions.

The most current version of this Privacy Policy will always be available at royalclub.one/privacy-policy. We recommend reviewing this policy periodically to stay informed of how royalclub protects your personal data.

Section 13

Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or royalclub's handling of your personal data, please contact our Data Protection Officer (DPO). Our DPO is responsible for overseeing royalclub's compliance with the Philippine Data Privacy Act and is your primary point of contact for all privacy-related matters.

Data Protection Officer — royalclub
Email: [email protected]
Response time: Within 30 days of receipt of your request.

If you are not satisfied with royalclub's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for enforcing the Data Privacy Act of 2012 in the Philippines.

royalclub is fully committed to cooperating with the NPC in the resolution of any complaint and to upholding the privacy rights of all Filipino players on our platform.

How royalclub Protects Your Data

SSL Encryption

Minimal Data Collection

No Third-Party Selling

RA 10173 Compliance

Your Rights, Respected

Defined Retention Periods

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