i8club Privacy Policy — How We Handle Your Personal Data

The data controller responsible for the personal data processed in connection with the i8club platform is the operator of i8club.cam, a PAGCOR-licensed online gaming operator. References to "i8club", "we", "us", or "our" throughout this Privacy Policy refer to this entity in its capacity as data controller.

i8club has appointed a Data Protection Officer (DPO) in accordance with Section 21 of RA 10173. The DPO is responsible for overseeing all data protection activities, monitoring compliance with this Policy, and serving as the primary point of contact for data subjects and the National Privacy Commission (NPC). Contact details for the DPO are provided in Section 15 of this Policy.

This Privacy Policy applies to all personal data collected and processed by i8club in connection with your use of the i8club platform, including:

• The i8club website accessible at i8club.cam and all subdomains;
• The i8club mobile-optimized web interface;
• All account registration, login, deposit, withdrawal, and gameplay activities conducted through the Platform;
• Communications between you and i8club through live chat, email, or any other channel.

This Policy is intended to complement, not replace, the i8club Terms and Conditions. By registering an Account with i8club, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

i8club collects personal data across several categories depending on the nature of your interaction with the Platform:

i8club does not collect sensitive personal information as defined under Section 3(l) of RA 10173 (such as racial or ethnic origin, religious beliefs, or health data) unless specifically required for responsible gaming or legal compliance purposes and you have provided explicit written consent.

i8club processes your personal data on one or more of the following lawful bases as recognized under RA 10173:

• Contractual Necessity: Processing required to fulfil our obligations under the i8club Terms and Conditions — including account management, game provision, and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR licensing requirements, Anti-Money Laundering Act obligations, tax reporting requirements, and other applicable Philippine law;
• Legitimate Interests: Processing conducted for i8club's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent — in particular for direct marketing communications where you have opted in to receive them.

Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing already carried out prior to withdrawal.

i8club uses personal data collected from players for the following specific purposes:

1. Account Administration: Creating, maintaining, and managing your i8club Account, including processing your registration, verifying your identity, and enabling login access;
2. Service Delivery: Providing access to all games and services on the Platform, processing deposits and withdrawals, and administering bonuses and promotions;
3. KYC & AML Compliance: Verifying your identity and age in accordance with PAGCOR requirements, screening against sanctions lists, and monitoring transactions for potential money laundering in compliance with Republic Act No. 9160 and its amendments;
4. Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, collusion, and other prohibited behaviors set out in the i8club Terms and Conditions;
5. Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviors, administering self-exclusion and limit tools, and fulfilling PAGCOR's responsible gaming regulatory obligations;
6. Customer Support: Responding to your inquiries, complaints, and dispute resolution requests submitted through live chat, email, or other contact channels;
7. Platform Improvement: Analysing aggregated and anonymized usage data to improve platform performance, game selection, and user experience;
8. Legal & Regulatory Compliance: Meeting all reporting and record-keeping obligations imposed by PAGCOR, the AMLC, the Bureau of Internal Revenue, the NPC, and other applicable Philippine regulatory bodies;
9. Direct Marketing (Consent-Based): Where you have opted in, sending you information about new games, promotional offers, and platform updates relevant to your interests. You may opt out of marketing communications at any time through your Account settings.

i8club does not sell, rent, or otherwise commercialize your personal data. We share your data only in the following specific circumstances:

• Payment Service Providers: GCash (G-Xchange, Inc.), Maya (Voyager Innovations), BancNet, and other Philippine payment processors require transaction reference data to process deposits and withdrawals;
• KYC & Identity Verification Partners: Licensed third-party providers that assist i8club in verifying the identity, age, and address of registering Players in compliance with PAGCOR requirements;
• Game Content Providers: Game providers such as Pragmatic Play, JILI, and PG Soft may receive session identifiers and game logs for the purpose of operating certified game environments and resolving technical disputes;
• IT & Infrastructure Providers: Hosting, cloud infrastructure, and cybersecurity service providers operating under contractual data processing agreements that impose obligations equivalent to those in this Policy;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), the National Privacy Commission (NPC), and Philippine law enforcement agencies, where disclosure is required by law or regulatory directive;
• Professional Advisers: Legal counsel, auditors, and compliance consultants bound by professional confidentiality obligations, where engagement is necessary for i8club's legal and regulatory compliance.

i8club uses cookies and similar tracking technologies on the Platform to ensure proper functionality, enhance your experience, and support our security and analytics operations. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the operation of the Platform — enabling login sessions, maintaining your wallet state, and ensuring platform security. These cookies cannot be disabled as they are required for the Platform to function;
• Functional Cookies: Used to remember your preferences such as language settings, game filters, and responsible gaming tool configurations. Disabling these cookies may affect your Platform experience;
• Analytics Cookies: Used to understand how players interact with the Platform — which pages are visited most, how long sessions last, and which features are used. Data collected via analytics cookies is aggregated and anonymized;
• Security Cookies: Used to detect and prevent fraudulent access, bot activity, and other security threats. These cookies are essential for maintaining Account security.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may impair the functionality of the Platform. i8club's cookie implementation does not involve cross-site tracking for third-party advertising purposes.

i8club retains personal data in accordance with the following retention schedule, subject to any longer period required by applicable Philippine law or regulatory obligation:

• Account and Identity Data: Retained for the duration of your Account and for a period of 5 years following account closure, in accordance with PAGCOR AML record-keeping requirements;
• Financial Transaction Data: Retained for 5 years from the date of each transaction in compliance with the Anti-Money Laundering Act and BIR requirements;
• Gaming Activity Logs: Retained for 3 years from the date of each gaming session for dispute resolution and regulatory audit purposes;
• Customer Support Communications: Retained for 2 years from the date of the final communication in a support interaction;
• Marketing Preferences: Retained until you withdraw consent for marketing, after which preference records are retained for 1 year to document the opt-out;
• Technical / Log Data: Typically retained for 90 days unless required for an active security investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or rendered permanently anonymous using methods that prevent re-identification.

i8club implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• AES-256 SSL/TLS encryption for all data in transit between your device and i8club's servers;
• Encryption of sensitive data at rest within i8club's database infrastructure;
• Role-based access controls ensuring that only authorized i8club personnel with a legitimate need can access personal data;
• Multi-factor authentication requirements for all i8club staff accessing production data systems;
• Regular third-party penetration testing and security audits of the Platform's infrastructure;
• Documented incident response procedures aligned with NPC Circular No. 16-03 breach notification requirements.

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by i8club. To exercise any of these rights, contact the i8club DPO using the details in Section 15:

The i8club Platform is strictly restricted to individuals who are at least 21 years of age in accordance with PAGCOR's minimum age requirements for online casino-style gaming in the Philippines. i8club does not knowingly collect or process personal data from persons under the age of 21.

Age is verified at the point of registration through a date-of-birth declaration and subsequently confirmed through KYC identity document verification. Where i8club discovers that personal data has been collected from a person under 21, it will immediately close the associated Account, delete the collected data to the extent permitted by legal obligations, and — where required — notify the relevant authorities.

Some of i8club's third-party service providers — including game content providers and cloud infrastructure partners — may be located outside the Philippines. Where personal data is transferred to entities in other jurisdictions, i8club ensures that appropriate safeguards are in place as required by Section 21 of RA 10173, including:

• Execution of cross-border data transfer agreements that impose data protection standards equivalent to those required under Philippine law;
• Verification that the recipient jurisdiction provides an adequate level of protection comparable to RA 10173, where applicable;
• Standard contractual clauses approved by the National Privacy Commission where the above conditions are not otherwise met.

i8club does not transfer personal data internationally for marketing or data commercialization purposes.

The i8club Platform does not include links to external third-party websites for advertising or referral purposes. Any incidental references to external services in Platform content do not constitute endorsement, and i8club accepts no responsibility for the privacy practices or data processing activities of third-party websites or applications that are not under i8club's control.

i8club reserves the right to update or amend this Privacy Policy at any time. Material changes — those that affect your rights or the way i8club processes your personal data — will be communicated to registered players via email or in-platform notification at least 7 days prior to taking effect. Non-material changes (such as typographic corrections or formatting updates) may be made without advance notice.

The effective date and last updated date at the top of this Policy will always reflect the most recent version. Your continued use of the i8club Platform following any amendment constitutes acceptance of the revised Policy. If you do not agree to an amendment, you should close your Account and request deletion of your personal data in accordance with Section 10 of this Policy.

For any questions, concerns, or requests relating to this Privacy Policy or your personal data held by i8club, please contact us through the following channels:

• Data Protection Officer (DPO): Reachable via the i8club support team — request DPO escalation in your communication;
• Live Chat: Available 24/7 through the i8club Platform after logging in to your Account — fastest response for urgent matters;
• Email: [email protected] — for written data subject requests, please include "Data Privacy Request" in the subject line and provide your registered mobile number for identity verification purposes.

i8club will acknowledge all written data privacy requests within 3 business days and endeavour to respond substantively within 15 business days, in accordance with NPC guidelines. Complex requests may require additional time, in which case i8club will notify you of the expected timeline.