Privacy Policy

For the purposes of this Privacy Policy, the following terms carry the meanings defined below:

• "Personal Data" — Any information that directly or indirectly identifies a natural person, including name, contact details, identification document numbers, financial account information, device identifiers, and behavioral data generated through use of the starph.com Platform.
• "Processing" — Any operation performed on Personal Data, including collection, recording, storage, organization, retrieval, use, disclosure, or deletion.
• "Data Controller" — The entity that determines the purposes and means of processing Personal Data. starph.com is the Data Controller in respect of all Personal Data collected from Users of the Platform.
• "Data Subject" — The natural person to whom Personal Data relates — in this context, you as a registered user or visitor of starph.com.
• "Data Privacy Act" — Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines, including its Implementing Rules and Regulations.
• "NPC" — The National Privacy Commission of the Philippines, the regulatory authority responsible for overseeing compliance with the Data Privacy Act.
• "Platform" — The starph.com website, Wallet system, game lobby, and all related services accessible at starphcom.vip.
• "User" / "You" — Any individual who visits, registers on, or uses the starph.com Platform.

2.1 Identity. The Data Controller for all Personal Data processed in connection with your use of starph.com is the operator of the Platform, which operates the website accessible at starphcom.vip and provides the gaming, wallet, and related services described therein.

2.2 Data Protection Officer. starph.com has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act. Requests relating to your Personal Data, privacy inquiries, and complaints may be directed to the DPO through the contact methods specified in Section 14 of this Policy.

2.3 Registration with NPC. In accordance with the Data Privacy Act and NPC registration requirements, the Company has registered its data processing systems with the National Privacy Commission of the Philippines as required by applicable regulations.

3.1 Registration Data. When you create an Account on starph.com, we collect the information you provide during registration, which includes:

• Full legal name as it appears on your government-issued Philippine ID;
• Date of birth (to verify that you meet the 21+ age requirement);
• Philippine mobile number;
• Email address;
• Preferred username and encrypted password;
• City or province of residence within the Philippines.

3.2 Identity Verification (KYC) Data. To comply with anti-money laundering obligations and to verify your eligibility to play for real money, we collect:

• Copies of government-issued Philippine identification documents (e.g., PhilSys National ID, Passport, Driver's License, UMID, SSS Card, PRC ID);
• A real-time selfie or photograph for liveness verification;
• Proof of address (utility bill, bank statement, or similar document issued within the preceding three months) where required for enhanced verification.

3.3 Financial Data. In connection with deposits and withdrawals, we collect:

• GCash or PayMaya registered mobile number linked to the transaction;
• Bank account name and account number where bank transfer is used (BPI, BDO, Metrobank);
• Partial card details (last four digits, card type) for Visa and Mastercard transactions — full card numbers are not stored by starph.com and are processed solely by PCI-DSS-compliant payment processors;
• Transaction histories including deposit amounts, withdrawal amounts, game wager amounts, and timestamps, all in Philippine Peso (PHP).

3.4 Technical and Usage Data. When you access and use the Platform, our systems automatically collect certain technical information:

• IP address and approximate geolocation at the time of access;
• Device type, operating system, and browser type and version;
• Session duration, pages or game sections visited, and click-path data;
• Error logs and technical diagnostics generated during gameplay;
• Cookie identifiers and tracking pixel data (detailed in Section 9).

3.5 Communications Data. We retain records of your communications with starph.com, including live chat transcripts, support tickets, email correspondence, and complaint submissions, for service quality, dispute resolution, and regulatory compliance purposes.

starph.com collects Personal Data through the following channels:

starph.com processes your Personal Data for the following purposes, each supported by a lawful basis under the Data Privacy Act:

6.1 General Principle. starph.com does not sell, rent, or trade your Personal Data to third parties for their independent marketing purposes. We disclose Personal Data only in the circumstances described in this Section.

6.2 Service Providers and Data Processors. We engage carefully selected third-party service providers who process Personal Data on our behalf, strictly to support the operation of the Platform. These include:

• Payment processors — GCash (GXI), Maya Philippines, Bancnet, Visa, Mastercard, and partner Philippine banks processing your financial transactions;
• Identity verification providers — Third-party KYC technology providers who verify your government-issued ID and process liveness checks;
• Cloud infrastructure providers — Hosting and database services that store Platform data in secure, access-controlled environments;
• Customer support software — Live chat and ticketing platforms used to manage support interactions;
• Analytics providers — Aggregated, anonymized Platform usage analysis tools used to improve the User experience.

All third-party processors are bound by data processing agreements requiring them to maintain confidentiality, implement adequate security, and process Personal Data only on starph.com's documented instructions.

6.3 Legal and Regulatory Disclosure. starph.com will disclose Personal Data to authorized Philippine government authorities, regulatory bodies, or law enforcement agencies where required to do so by applicable law, court order, or regulatory direction — including disclosures to PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC).

6.4 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or part of the business, your Personal Data may be transferred to the successor entity, subject to that entity assuming the obligations of this Privacy Policy in respect of your data.

6.5 Consent-Based Sharing. Outside of the above circumstances, your Personal Data will not be shared with any third party without your prior express consent.

7.1 Retention Principle. starph.com retains 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, whichever is longer.

7.2 Account Data. Personal Data associated with your Account is retained for the duration of your Account's active status and for a minimum period of five (5) years following Account closure. This retention period reflects obligations under Philippine anti-money laundering regulations and gaming licensing requirements.

7.3 Transaction Records. Financial transaction records, including deposit and withdrawal histories, are retained for a minimum of five (5) years from the date of each transaction, in accordance with applicable financial record-keeping obligations.

7.4 KYC Documents. Identity verification documents submitted for KYC purposes are retained for the period required by AMLC regulations and applicable PAGCOR licensing conditions, typically five (5) years from the date of submission.

7.5 Anonymization. Where Personal Data is no longer required for any lawful purpose, we will either securely delete it or anonymize it so that it can no longer be associated with you as an individual. Anonymized data may be retained for statistical and analytical purposes without limitation.

8.1 Technical Safeguards. starph.com implements industry-standard technical security measures to protect your Personal Data from unauthorized access, alteration, disclosure, or destruction, including:

• 256-bit TLS/SSL encryption for all data in transit between your device and starph.com servers;
• Encryption at rest for sensitive data categories including KYC documents and financial records;
• Multi-factor authentication for administrative access to systems holding Personal Data;
• Regular vulnerability scanning and penetration testing of Platform infrastructure;
• Access controls implementing the principle of least privilege — staff can only access Personal Data that is necessary for their specific function.

8.2 Organizational Safeguards. Technical measures are complemented by organizational controls, including: staff data privacy training, confidentiality agreements for all personnel with access to Personal Data, documented data handling procedures, and a data breach response protocol.

8.3 Breach Notification. In the event of a Personal Data breach that is reasonably likely to result in serious harm to Data Subjects, starph.com will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03. Affected Users will be notified without undue delay where the breach poses a high risk to their rights and freedoms.

8.4 User Responsibility. While starph.com implements robust security measures, Users share responsibility for their Account security. You are advised to use a strong, unique password, enable two-factor authentication, and report any suspected unauthorized Account access to support immediately.

9.1 What We Use. starph.com uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file stored on your device by your browser when you visit the Platform.

9.2 Managing Cookies. You may control cookie settings through your browser preferences. Disabling strictly necessary cookies will impair your ability to use the Platform. Disabling functional and analytics cookies will not prevent Platform use but may affect your experience. Your cookie preferences can also be managed through the Platform's cookie settings banner on first visit.

Under the Data Privacy Act of the Philippines (Republic Act No. 10173), you have the following rights with respect to your Personal Data held by starph.com. To exercise any of these rights, contact our Data Protection Officer through the channels in Section 14.

11.1 Age Restriction. starph.com is strictly prohibited for use by persons under the age of twenty-one (21) years, in accordance with Philippine gaming law. The Platform does not knowingly collect Personal Data from persons below this age.

11.2 Discovery of Minor's Data. If we discover or receive credible notice that Personal Data has been submitted by or on behalf of a person under 21 years of age, we will immediately:

• Suspend the associated Account;
• Permanently delete all Personal Data associated with that Account;
• Report the matter to relevant authorities as required by Philippine law;
• Refund any real-money deposits made to the Account, net of any processing fees, to the source payment method.

11.3 Parental Guidance. Parents and legal guardians who believe their child has created an Account on starph.com are urged to contact our support team immediately. We will take prompt action to verify the matter and close the Account.

12.1 Primary Processing Location. The Personal Data of starph.com Users is primarily processed and stored on servers located within or servicing the Republic of the Philippines. starph.com prioritizes infrastructure providers with Philippine data center presence or strong regional APAC infrastructure to minimize cross-border data flows.

12.2 Transfers to Third Countries. Certain service providers — including cloud infrastructure components and KYC verification technology partners — may process data in jurisdictions outside the Philippines. Where such transfers occur, starph.com ensures that appropriate safeguards are in place, including:

• Contractual data transfer agreements requiring the recipient to maintain protections equivalent to those required by the Data Privacy Act;
• Transfer to jurisdictions recognized by the NPC as providing adequate levels of data protection;
• Binding corporate rules or standard contractual clauses where applicable.

12.3 Your Consent. By creating and using an Account on starph.com, you acknowledge and consent to the transfer of your Personal Data to third-party processors in accordance with this Section, subject always to the safeguards described above.

13.1 Right to Update. starph.com may update this Privacy Policy periodically to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or Platform features. The effective date at the top of this document will be updated each time a new version is published.

13.2 Notification of Material Changes. Where changes are material — meaning they significantly affect how we process your Personal Data or affect your rights as a Data Subject — we will provide notice to registered Users through at least one of the following channels prior to the changes taking effect:

• A prominent notice displayed upon your next login to starph.com;
• An email notification to your registered email address;
• An in-Platform notification in your Account message center.

13.3 Continued Use as Acceptance. Your continued use of the starph.com Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you should cease using the Platform and may request Account closure.

If you wish to exercise your data subject rights, ask questions about this Privacy Policy, or raise a concern about how starph.com handles your Personal Data, please contact us through one of the following channels: