starph1 Privacy Policy

1. Scope and Data Controller

This Privacy Policy applies to all personal data collected by starph1 in connection with the operation of the starph1.net online gaming platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and promotional activities.

The data controller responsible for your personal data is the operator of the starph1 platform, a PAGCOR-licensed online gaming operator established and operating within the Republic of the Philippines. For all privacy-related inquiries and data subject requests, the starph1 Data Protection Officer (DPO) can be reached at [email protected] with the subject line "Data Privacy Request."

This Policy covers personal data processed in relation to players physically located within the Philippines, as well as any other individuals whose data starph1 processes in the ordinary course of its licensed gaming operations. It does not apply to third-party websites or services that may be linked from the platform.

2. Categories of Data We Collect

starph1 collects the following categories of personal data, depending on your interaction with the platform:

Category	Examples	Required?
Identity Data	Full legal name, date of birth, nationality, government ID number (PhilSys, passport, UMID, driver's license)	Mandatory (KYC)
Contact Data	Email address, Philippine mobile number (Globe / Smart / DITO), residential address	Mandatory
Financial Data	GCash or Maya account number, bank account details (BPI, BDO, Metrobank), USDT wallet address, deposit and withdrawal history	Mandatory
Transaction Data	Wager amounts, game history, win/loss records, bonus activity, cashier logs	Mandatory
Technical Data	IP address, device type, browser type and version, operating system, session timestamps, geolocation data	Automatic
Usage Data	Pages visited, features accessed, games played, time spent per session, referral source	Automatic
Communications Data	Live chat transcripts, support email correspondence, feedback submissions	Where applicable
Responsible Gaming Data	Self-exclusion status, deposit limits set, session time limits, reality check preferences	Where applicable

starph1 does not intentionally collect sensitive personal information (as defined under Section 3(l) of RA 10173) beyond what is strictly required for identity verification and regulatory compliance. Where such sensitive data is collected (e.g., government ID numbers), it is processed under the lawful bases described in Section 4 below.

3. How We Collect Your Data

3.1 Directly From You

The majority of personal data starph1 holds is provided directly by you during the account registration process, when completing KYC verification, when making deposits or withdrawal requests, when contacting our support team, and when opting into promotions or loyalty programs.

3.2 Automatically Through Platform Use

When you access the starph1 platform, certain technical and usage data is collected automatically through server logs, cookies, and similar tracking technologies. This includes your IP address, device fingerprint, session duration, and gameplay patterns. This automatic collection is necessary for platform security, fraud detection, and service optimization.

3.3 From Third Parties

In limited circumstances, starph1 may receive personal data about you from third parties, including: payment service providers (GCash, Maya, BPI, BDO, Metrobank, Coins.ph) who confirm transaction details; identity verification partners who assist with KYC compliance; and PAGCOR or other Philippine government bodies in connection with regulatory obligations. Any data received from third parties is handled in accordance with this Privacy Policy and the relevant third party's data sharing agreement with starph1.

4. Lawful Basis for Processing

starph1 processes your personal data under one or more of the following lawful bases, as specified under Republic Act 10173 and its implementing rules:

• Contractual Necessity: Processing is necessary to perform the contract between you and starph1 — i.e., to operate your gaming account, process transactions, and deliver the services you have registered for.
• Legal Obligation: Processing is required to comply with applicable Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160), the Data Privacy Act (RA 10173), and tax reporting requirements.
• Legitimate Interests: Processing is necessary for starph1's legitimate interests in operating a secure and compliant gaming platform, detecting and preventing fraud, improving platform performance, and communicating relevant updates to players — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where neither of the above bases applies, starph1 will seek your explicit consent before processing your data. You have the right to withdraw consent at any time, though this will not affect the lawfulness of processing that occurred prior to withdrawal.

5. How We Use Your Personal Data

starph1 uses the personal data it collects for the following specific and declared purposes:

• Account Management: To create, maintain, and manage your starph1 player account, including authentication, password recovery, and account security monitoring.
• KYC and Age Verification: To verify your identity and confirm that you are 21 years of age or older, as required by PAGCOR regulations. Real-money gaming features are not activated until KYC verification is complete.
• Transaction Processing: To process deposits, wagers, winnings payouts, and withdrawal requests via GCash, Maya, BPI, BDO, Metrobank, Coins.ph, and USDT channels.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the platform.
• AMLA Compliance: To fulfill starph1's obligations under the Anti-Money Laundering Act, including transaction monitoring and reporting to the Anti-Money Laundering Council (AMLC) where legally required.
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance via live chat, email, and other support channels.
• Responsible Gaming: To monitor gameplay patterns for signs of problem gambling behavior, administer self-exclusion requests, and enforce deposit and session limits set by the player.
• Promotions and Communications: To notify you of bonuses, promotions, and platform updates relevant to your account — subject to your communication preferences and applicable consent requirements.
• Platform Improvement: To analyze aggregated usage data and improve the functionality, performance, and user experience of the starph1 platform.
• Regulatory Reporting: To fulfill PAGCOR reporting obligations and respond to lawful requests from Philippine regulatory and law enforcement authorities.

6. Data Sharing and Disclosure

6.1 With Whom We Share Your Data

starph1 does not sell your personal data. We share your data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment Service Providers: GCash, Maya, BPI, BDO, Metrobank, Coins.ph, and USDT processing partners — to facilitate deposits and withdrawals.
• Game Content Providers: Licensed game studios whose games are available on the starph1 platform — to deliver game functionality and maintain fair play records.
• KYC and Identity Verification Partners: Third-party identity verification services used to confirm player identity and age for PAGCOR compliance.
• IT and Security Service Providers: Cloud hosting, data storage, cybersecurity, and anti-fraud technology providers engaged by starph1 to support platform operations under appropriate data processing agreements.
• Regulatory and Legal Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and Philippine law enforcement agencies — where disclosure is required by law, court order, or regulatory mandate.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by starph1, who are bound by confidentiality obligations.

6.2 Business Transfers

In the event of a merger, acquisition, or transfer of starph1's business operations, personal data held by starph1 may be transferred to the acquiring entity as part of the transaction. Affected players will be notified prior to any such transfer, and the acquiring entity will be required to honor the commitments made in this Privacy Policy.

7. Cookies and Tracking Technologies

The starph1 platform uses cookies and similar tracking technologies to ensure the correct functioning of the platform, enhance security, and improve the player experience. The following types of cookies may be placed on your device when you access starph1.net:

• Strictly Necessary Cookies: These are required for the platform to function. They maintain your login session, store your language preference, and ensure platform security. These cookies cannot be disabled.
• Performance and Analytics Cookies: These collect anonymized data about how players navigate the platform — which pages are visited, how long sessions last, and which features are most used. This data helps starph1 identify areas for improvement.
• Functional Cookies: These remember your preferences and personalization settings — such as your preferred game lobby layout and responsible gaming tool configurations.
• Security Cookies: These assist in fraud detection by helping starph1 recognize patterns consistent with unauthorized account access or automated bot activity.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the starph1 platform. starph1 does not use third-party advertising or behavioral targeting cookies.

8. Data Security

starph1 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• TLS 1.3 encryption for all data in transit between your device and starph1 servers.
• AES-256 encryption for personal and financial data stored in starph1 databases.
• Multi-factor authentication (MFA) options for all player accounts.
• Role-based access controls limiting internal staff access to personal data strictly on a need-to-know basis.
• Regular independent security audits and penetration testing of the starph1 platform.
• Dedicated intrusion detection systems (IDS) and 24/7 security monitoring.
• PCI-DSS compliant handling of all payment card and e-wallet data through certified payment partners.

9. Data Retention

starph1 retains personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• KYC and Identity Records: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and the Anti-Money Laundering Act.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with AMLA record-keeping requirements.
• Communication Records: Live chat transcripts and email correspondence retained for two (2) years from the date of the interaction, unless longer retention is required for an ongoing dispute or legal proceeding.
• Responsible Gaming Records: Self-exclusion records and problem gambling intervention logs retained for five (5) years to prevent re-registration during active exclusion periods and to support regulatory reporting.
• Technical Logs: Server access logs and security event logs retained for ninety (90) days, unless required for an active security investigation.

Upon expiry of the applicable retention period, personal data will be securely deleted or rendered permanently anonymous. Players who request account closure may submit a data deletion request; however, starph1 is obligated to retain certain records for the minimum periods specified above regardless of the closure request.

10. Your Data Subject Rights

Under Republic Act 10173 (Data Privacy Act of 2012) and its implementing rules and regulations, you have the following rights with respect to your personal data held by starph1:

To exercise any of the above rights, please contact the starph1 Data Protection Officer at [email protected] with the subject line "Data Privacy Request." starph1 will respond within fifteen (15) business days of receiving a valid and complete request, as required by NPC regulations.

11. Children and Minors

If starph1 becomes aware that personal data belonging to a person under 21 years of age has been collected, that data will be immediately deleted, the associated account will be permanently closed, and any deposited funds will be returned to the original payment source. All winnings generated by an underage player are forfeited in full.

If you believe that a minor has registered an account on the starph1 platform, please notify our support team immediately at [email protected] so that appropriate action can be taken without delay.

12. Cross-Border Data Transfers

starph1 is a Philippines-based operator and processes personal data primarily within the Philippines. However, certain technical service providers and game content partners may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that afforded by RA 10173, starph1 will ensure that appropriate safeguards are in place — such as contractual data protection clauses approved by the National Privacy Commission — before any such transfer takes place.

starph1 will not transfer personal data internationally in ways that would compromise your rights as a data subject under Philippine law.

13. Changes to This Privacy Policy

starph1 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or platform operations. The most current version of this Policy will always be published at starph1.net/privacy-policy, with the effective date updated accordingly.

For material changes that substantially affect how your personal data is collected or used, starph1 will notify registered players via the email address associated with their account at least seven (7) days before the updated Policy takes effect. Your continued use of the platform following such notification constitutes your acceptance of the revised Privacy Policy.

14. Contact and Complaints

For all privacy-related inquiries, data subject access requests, or formal complaints regarding starph1's data handling practices, please contact:

• Data Protection Officer (DPO): [email protected] — use subject line "Data Privacy Request"
• Live Chat: Available 24/7 on the starph1 platform — for general privacy questions and guidance on exercising your rights

If you are not satisfied with starph1's response to your privacy complaint, you have the right to escalate your concern to the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC): 5th Floor, Delegation Building, PICC Complex, Pasay City, Metro Manila, Philippines
• NPC Complaints Portal: Available through the official NPC website at privacy.gov.ph