starph Privacy
Policy

starph ("we," "us," "our," or the "Company") is committed to protecting the privacy and personal data of every player who uses the starph online casino platform at starph.xyz. This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you access or use any part of the starph platform, including our website, games, customer support channels, and related services.

This Privacy Policy is issued 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) of the Philippines. It also reflects our obligations under applicable anti-money laundering laws and PAGCOR regulatory requirements.

By registering an account on starph, making a deposit, or otherwise using our platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this policy, please discontinue use of the starph platform immediately.

starph collects personal data from you in several ways — directly when you provide it to us, automatically when you use our platform, and from third parties where permitted by law. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Registration data: Full name, date of birth, gender, nationality, residential address (including city, province, and ZIP code), email address, and mobile number.
• Identity verification (KYC) data: Government-issued ID documents such as Philippine passport, SSS ID, UMID, driver's license, or PhilSys national ID; proof of address documents; and selfie photographs for identity verification purposes.
• Financial data: Payment method details including GCash account numbers, PayMaya account details, BPI, BDO, or Metrobank account information used for deposits and withdrawals. We do not store full card numbers or banking passwords.
• Communications data: Messages, emails, and chat transcripts exchanged with the starph customer support team.
• Responsible gaming data: Self-exclusion requests, deposit limit preferences, cooling-off period requests, and other responsible gaming tool settings.

2.2 Data Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage data: Pages visited, games played, session duration, betting history, wagering patterns, login timestamps, and navigation paths within the starph platform.
• Location data: General geographic location derived from your IP address. We do not collect precise GPS location data.
• Cookie and tracking data: Data collected through cookies, web beacons, and similar technologies as described in Section 6 of this policy.

starph uses the personal data we collect for the following purposes:

starph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

Under the Philippine Data Privacy Act of 2012, starph processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between you and starph — specifically, to provide you with access to the platform, process your transactions, and deliver the services you have requested.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate interests: Processing is necessary for the legitimate interests of starph, including fraud prevention, platform security, responsible gaming monitoring, and business analytics, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications and placing non-essential cookies — starph relies on your freely given, specific, and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Vital interests: In exceptional circumstances, starph may process personal data to protect your vital interests or those of another person, such as in cases involving problem gambling or player welfare concerns.

starph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only where necessary and lawful:

5.1 Service Providers

starph engages trusted third-party service providers to assist in operating the platform. These include payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, customer support software providers, and analytics platforms. All service providers are contractually bound to process your data only on our instructions and to maintain appropriate security standards.

5.2 Regulatory and Law Enforcement Authorities

starph may disclose your personal data to the Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other competent government authorities where required by law, court order, or regulatory directive.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of the starph business, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

5.4 With Your Consent

starph may share your personal data with other third parties where you have given your explicit consent to such sharing.

starph uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and deliver relevant content. A cookie is a small text file placed on your device when you visit the starph website.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may affect the functionality of the starph platform. For optional cookies, you may withdraw your consent at any time by adjusting your browser settings or contacting our support team.

starph retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later, as required by PAGCOR and AMLC regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with Philippine financial record-keeping laws.
• Customer support communications: Retained for up to three (3) years from the date of the last communication, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing preferences and consent records: Retained for the duration of your account and for one (1) year following account closure or withdrawal of consent.
• Analytics and usage data: Retained in anonymized or aggregated form for up to two (2) years for platform improvement purposes.

Upon expiry of the applicable retention period, starph will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

starph 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 measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the starph platform.
• Encryption at rest for sensitive personal data stored on our servers, including KYC documents and financial information.
• Access controls limiting access to personal data to authorized starph personnel on a strict need-to-know basis.
• Multi-factor authentication for internal systems that process personal data.
• Regular security audits and penetration testing of the starph platform and infrastructure.
• Incident response procedures to detect, contain, and respond to data security incidents promptly.
• Staff training on data privacy and security obligations under the Philippine Data Privacy Act.

In the event of a personal data breach that is likely to result in harm to affected individuals, starph will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Philippine Data Privacy Act and its implementing rules.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by starph:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right of access: You have the right to request a copy of the personal data that starph 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. You may update certain information directly through your starph account settings.
• 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 or where processing is based on our legitimate 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 prior processing.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that your data privacy rights have been violated.

To exercise any of these rights, please contact the starph Data Privacy Officer using the contact details provided in Section 13 of this policy. We will respond to all verified requests within thirty (30) days of receipt, in accordance with the requirements of the Philippine Data Privacy Act.

The starph platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. starph does not knowingly collect personal data from individuals under the age of 21.

During the registration process, all applicants are required to confirm that they are at least 21 years of age. starph may require submission of a government-issued ID to verify age before activating an account or processing withdrawals.

If starph discovers or is notified that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be handled in accordance with applicable Philippine law and regulatory guidance.

starph primarily processes and stores personal data within the Philippines. However, some of our third-party service providers — including cloud hosting providers and analytics platforms — may process data in other countries. Where personal data is transferred outside the Philippines, starph ensures that appropriate safeguards are in place to protect your data in accordance with the Philippine Data Privacy Act.

These safeguards may include:

• Transferring data only to countries that the National Privacy Commission has determined provide an adequate level of data protection.
• Entering into standard contractual clauses or data transfer agreements with the recipient that impose data protection obligations equivalent to those under Philippine law.
• Obtaining your explicit consent to the transfer where required by applicable law.

You may request information about the specific safeguards in place for any international transfer of your personal data by contacting the starph Data Privacy Officer.

starph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, we will update the "Last Updated" date at the top of this page.

For significant changes that materially affect how we process your personal data, starph will provide additional notice — such as a prominent notice on the platform or a notification to your registered email address — prior to the changes taking effect.

Your continued use of the starph platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated policy, you must stop using the platform and may request account closure in accordance with the starph Terms & Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how starph protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by starph, please contact our Data Privacy Officer (DPO). The DPO is responsible for overseeing starph's compliance with the Philippine Data Privacy Act and this Privacy Policy.

If you are not satisfied with our response to your privacy inquiry, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Philippine Data Privacy Act.

All privacy-related requests must be submitted in writing and include sufficient information to verify your identity before we can process your request. This is to protect your personal data from unauthorized disclosure.