Clash of Odds Privacy Policy for Players in the Philippines

📄1. Introduction

Welcome to the Clash of Odds Privacy Policy. Clash of Odds ("we", "us", "our") operates the online gaming platform at clashofodds.org and is committed to protecting the privacy and personal data of all registered players in the Philippines.

This Privacy Policy describes in detail what personal data we collect when you register for and use the Clash of Odds platform, the purposes for which that data is processed, how it is stored and protected, how long it is retained, who it may be shared with, and what rights you have as a Filipino data subject under the Republic Act 10173 (Data Privacy Act of 2012).

This Policy applies to all personal data collected through the Clash of Odds website, mobile application, customer support channels, and any other interaction you have with the platform. By registering a Clash of Odds account, you confirm that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

📂2. Personal Data We Collect

Clash of Odds collects personal data in three main ways: information you provide directly during registration and use of the platform, information generated automatically by your use of the platform, and information provided by third-party payment processors when you make a deposit or withdrawal.

Information you provide directly:

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (used to verify that you are at least 21 years old)
• Valid email address
• Philippine mobile number
• Residential address in the Philippines
• Government-issued ID type and reference number (PhilSys, passport, LTO licence, or COMELEC voter's ID)
• Username and encrypted password
• Profile preferences and communication settings

Information generated automatically:

• IP address and approximate geographic location at the time of login
• Device type, operating system, and browser version
• Session timestamps — date and time of each login and logout
• Pages and game categories visited within the platform
• Bet history, game selections, wagered amounts in PHP, and game outcomes
• Deposit and withdrawal transaction references and timestamps
• Customer support chat transcripts and email correspondence

Information from third-party payment processors:

• Transaction reference numbers from GCash, Maya, or Philippine bank transfers
• Payment status confirmations (success, pending, failed)
• The name registered to the payment account (used to enforce the name-matched payment policy)

⚙️3. How We Use Your Personal Data

Clash of Odds uses personal data collected from Filipino players for the following specific purposes. We do not use your data for any purpose beyond what is listed here without first obtaining your separate consent.

• Account registration and identity verification: Your name, date of birth, and government ID are used to verify that you are eligible to hold an account on the platform — specifically that you are at least 21 years old and are located in the Philippines.
• Platform operation: Your login credentials, session data, and device information are used to authenticate your access to the platform and to keep your account secure.
• Payment processing: Your financial data and payment method details are used to process deposits in PHP and to fulfil withdrawal requests to your GCash wallet, Maya account, or Philippine bank account.
• Customer support: Your account data and support correspondence are used to identify you and resolve any issues or enquiries you raise with the Clash of Odds support team.
• Responsible gaming compliance: Your gaming history, session data, and deposit activity are monitored to identify patterns that may indicate problem gaming behaviour, enabling us to apply the appropriate responsible gaming safeguards.
• Fraud prevention and platform security: Technical data including IP address and device information is used to detect and prevent unauthorised account access, bonus abuse, collusion, and other fraudulent activity.
• Legal and regulatory compliance: Your identity data and transaction history may be used to fulfil obligations under Philippine law, including anti-money laundering requirements.
• Platform improvements: Aggregated and anonymised usage data — data that cannot be traced back to any individual player — is used to analyse platform performance and improve the player experience.

⚖️4. Legal Basis for Processing

Under the Data Privacy Act of 2012 (Republic Act 10173) and its implementing rules, Clash of Odds relies on the following legal bases to process your personal data:

• Contractual necessity: Processing your identity data, contact data, and financial data is necessary to perform the contract between you and Clash of Odds — that is, to operate your account, accept deposits, and process withdrawals.
• Consent: Where we send you optional promotional communications or use non-essential cookies, we rely on your explicit consent. You may withdraw this consent at any time through your account settings or by contacting our support team.
• Legitimate interests: Processing technical data for fraud prevention and platform security is based on our legitimate interest in protecting the platform and its players from harm, provided that interest does not override your fundamental privacy rights.
• Legal obligation: Retaining identity and transaction records to comply with Philippine anti-money laundering legislation and other applicable laws is based on legal obligation.

🤝5. Sharing Your Personal Data

Clash of Odds does not sell your personal data to any third party. We share personal data only in the limited circumstances described below, and only to the extent necessary for each specific purpose.

• Payment processors: When you make a deposit or request a withdrawal, your name and transaction details are shared with the relevant payment processor — such as GCash, Maya, or a Philippine banking partner — solely to execute that transaction.
• Game software providers: Third-party game studios that supply live casino, slot, or bingo content to the Clash of Odds platform may receive anonymised session data necessary to operate their games. These providers do not receive your full identity data.
• IT infrastructure and security providers: Cloud hosting and cybersecurity service providers that support the operation of the Clash of Odds platform may process certain technical data as part of providing their services. All such providers are bound by data processing agreements that prohibit them from using your data for any purpose other than providing the contracted service.
• Legal and regulatory authorities: Clash of Odds will disclose personal data to Philippine government agencies, law enforcement bodies, or courts when required to do so by law, by a valid legal process, or to protect the rights and safety of the platform and its players.

💳6. Payment Data and Philippine Financial Channels

All financial transactions on Clash of Odds are denominated in Philippine pesos (PHP). When you initiate a deposit via GCash, Maya, or a Philippine bank transfer, the following data handling applies:

• The transaction reference number generated by your payment provider is recorded in your Clash of Odds account to enable deposit confirmation and dispute resolution.
• The name registered to your payment method is checked against the name on your Clash of Odds account to enforce the name-matched payment policy required under these Terms.
• The PHP amount of each deposit and withdrawal is recorded as part of your transaction history, which is retained for compliance purposes.

Clash of Odds does not store your GCash account PIN, your Maya login credentials, or your online banking username or password. All authentication for these payment methods takes place on the respective provider's own secure platform, not on Clash of Odds systems. Clash of Odds never has visibility of or access to your payment provider login credentials.

If a deposit is flagged for review — for example, because the sender name does not match your Clash of Odds account name — the funds will be held pending investigation. You will be contacted via the email address registered to your account with instructions on how to resolve the discrepancy.

🔐7. Data Security

Clash of Odds implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Clash of Odds platform
• Encrypted storage of all passwords — your password is never stored in readable form on our systems
• Optional two-factor authentication (2FA) for player accounts, which we strongly recommend all Filipino players enable
• Role-based access controls that limit staff access to personal data to only those who require it to perform their job
• Regular independent security audits and penetration testing of platform infrastructure
• Automated monitoring systems that detect and alert on suspicious login activity, including logins from unusual IP addresses or devices

Despite these measures, no online platform can guarantee absolute security. In the unlikely event of a data breach that is likely to result in a risk to your rights and freedoms, Clash of Odds will notify affected players and, where required by law, the National Privacy Commission of the Philippines, within the timeframes specified by applicable regulation.

🍪8. Cookies and Tracking Technologies

Clash of Odds uses cookies and similar tracking technologies on the platform website and mobile app. Cookies are small text files stored on your device that help the platform function correctly and allow us to understand how players use the site.

Types of cookies we use:

• Strictly necessary cookies: These are required for the platform to function and cannot be disabled. They include session cookies that keep you logged in during a browsing session and security cookies that help protect against cross-site request forgery attacks.
• Functional cookies: These remember your preferences — such as your chosen language settings or lobby display options — so you do not have to re-enter them each time you visit. Disabling these cookies may affect your experience on the platform.
• Analytics cookies: These collect aggregated and anonymised data about how players navigate the platform, which pages are most visited, and where technical errors occur. This data is used to improve the platform. These cookies require your consent and can be disabled in your cookie preferences.
• Marketing cookies: If you have consented to receive personalised offers from Clash of Odds, marketing cookies may be used to record which promotions you have seen so we do not show you the same offer repeatedly. These are strictly optional and require your consent.

You can manage your cookie preferences at any time through the cookie settings option available in the footer of the platform website. Note that disabling strictly necessary cookies will prevent the platform from functioning correctly.

🗂️9. Data Retention

Clash of Odds retains your personal data for as long as your account is active and for a period after account closure as required by law or legitimate business need. The following retention periods apply:

• Identity and contact data: Retained for the duration of your account and for at least five years after account closure, in accordance with Philippine anti-money laundering record-keeping requirements.
• Transaction and financial data: Retained for at least five years from the date of each transaction.
• Gaming history: Retained for the duration of your account and for two years after account closure, used to support responsible gaming monitoring and dispute resolution.
• Technical and session data: Retained for up to 90 days from the date of collection, after which it is deleted or anonymised.
• Customer support correspondence: Retained for two years from the date of the last interaction in a support thread.

When the applicable retention period expires, your personal data is securely deleted or anonymised so that it can no longer be associated with you as an individual. Anonymised data — data that cannot identify any specific player — may be retained indefinitely for statistical and platform improvement purposes.

✅10. Your Data Rights as a Filipino Player

Under the Data Privacy Act of 2012, you as a Filipino data subject have the following rights in relation to the personal data Clash of Odds holds about you. To exercise any of these rights, contact the Clash of Odds Data Privacy Officer at the email address in Section 13.

Clash of Odds will respond to all data rights requests within thirty (30) days of receipt. If a request is particularly complex, we may extend this period by a further thirty days, in which case we will notify you of the extension and the reason for it. Exercising your data rights is free of charge.

If you believe Clash of Odds has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

🔞11. Minors and Age Policy

Clash of Odds is strictly for players aged 21 years and above. The platform does not knowingly collect or process personal data from any person under the age of 21. Age verification using a valid Philippine government-issued ID is mandatory for all new accounts.

If Clash of Odds discovers or is notified that personal data has been collected from a person who is under 21 years of age, the following actions will be taken immediately:

• The account will be permanently closed.
• All personal data associated with the account will be securely deleted, except where retention is required by law to document the violation.
• Any deposited funds will be returned to the payment method used, after deducting any amounts already wagered.

Parents and guardians who believe a minor may have registered on the Clash of Odds platform should contact our support team immediately at the email address listed in Section 13.

📝12. Updates to This Privacy Policy

Clash of Odds may update this Privacy Policy from time to time to reflect changes in how we operate the platform, changes in applicable Philippine privacy law, or feedback from our players. When material changes are made, registered players will be notified via email or an in-platform notification at least seven days before the updated Policy takes effect, unless immediate changes are required for legal or security reasons.

The "Last updated" date at the top of this page reflects when the current version of the Policy was last revised. We encourage you to review this page periodically. Your continued use of the Clash of Odds platform after the effective date of any updated Policy constitutes your acceptance of the changes.

If the updated Policy requires your fresh consent for a new type of data processing, Clash of Odds will obtain that consent explicitly before proceeding with the new processing activity.

✉️13. Contact Our Data Privacy Officer

If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to raise a privacy concern, please contact the Clash of Odds Data Privacy Officer using the details below. All privacy-related communications are handled confidentially.

• Email: [email protected]
• General Support Email: [email protected]
• Platform Support: Visit the Platform page for all available live support channels

For questions about responsible gaming tools or self-exclusion, visit the Responsible Gaming page. For questions about your account terms, refer to the Terms and Conditions. For general platform questions, our FAQ page covers a wide range of common topics.