Privacy Policy

01 Introduction

starph11 ("we," "us," "our," "the Platform") operates the online gaming platform accessible at starph11.vip. We understand that your personal data is important to you, and we take our responsibility as a data controller seriously. This Privacy Policy describes our practices with respect to the collection, use, storage, disclosure, and protection of personal information in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy applies to all personal data collected through the starph11 website, mobile platform, customer support channels, and any other interaction you have with starph11. By registering an account or using the starph11 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.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy.

02 Data Controller Information

For the purposes of the Data Privacy Act of 2012, starph11 is the Personal Information Controller (PIC) in respect of the personal data collected through this platform. As PIC, starph11 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data privacy laws.

starph11 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data privacy regulations. You may contact our DPO using the details provided in Section 15 of this policy.

03 Personal Data We Collect

starph11 collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected. The categories of personal data we collect include:

starph11 does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly required for KYC and regulatory compliance purposes. Where sensitive personal information is collected (e.g., government ID numbers), it is processed under the lawful bases described in Section 5.

04 How We Collect Your Data

starph11 collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the platform, including through cookies, web beacons, log files, and similar tracking technologies (see Section 9).
• Third-Party Sources: Identity verification data from KYC service providers; fraud and risk data from payment processors; publicly available information where permitted by law.
• Payment Processors: Transaction data shared by GCash, PayMaya (Maya), and banking partners in connection with deposits and withdrawals.

05 Purpose & Legal Basis for Processing

starph11 processes your personal data only where there is a lawful basis to do so under the Data Privacy Act of 2012. The following table sets out the primary purposes for which we process personal data and the corresponding legal basis:

• Contract Performance: Processing necessary to register your account, operate your gaming activity, process deposits and withdrawals, and provide customer support.
• Legal Obligation: Processing required to comply with PAGCOR regulations, Anti-Money Laundering Act (AMLA) obligations, Know Your Customer (KYC) requirements, and tax reporting obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improving the platform – where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Data Sharing & Disclosure

starph11 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Service Providers: GCash, PayMaya (Maya), and banking partners, for the purpose of processing deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services used to verify your age and identity in compliance with regulatory requirements.
• Game Software Providers: Game providers (e.g., Pragmatic Play, PG Soft, Jili) may receive limited technical data necessary to operate their games on the platform.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulatory obligation.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and fraud detection service providers who process data on our behalf under strict data processing agreements.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors where necessary for legal proceedings or compliance purposes.

All third-party service providers who process personal data on behalf of starph11 are required to enter into data processing agreements that impose obligations consistent with the Data Privacy Act of 2012 and this Privacy Policy.

07 Data Retention

starph11 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account Data & KYC Documents: Retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under the AMLA and applicable tax regulations.
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session, for dispute resolution and regulatory audit purposes.
• Customer Support Records: Retained for two (2) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing Consent Records: Retained for the duration of your account and for two (2) years following account closure, as evidence of consent.
• Technical & Log Data: Retained for up to twelve (12) months, unless required for longer periods for security investigations.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with our data disposal procedures. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

08 Data Security

starph11 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption in Transit: All data transmitted between your device and the starph11 platform is encrypted using TLS 1.2 or higher (256-bit SSL encryption).
• Encryption at Rest: Sensitive personal data stored on our servers is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-Factor Authentication: starph11 supports and encourages the use of two-factor authentication (2FA) for all player accounts to prevent unauthorized access.
• Regular Security Audits: Our platform undergoes regular penetration testing and security audits by independent cybersecurity professionals.
• Incident Response: starph11 maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay.

09 Cookies & Tracking Technologies

starph11 uses cookies and similar tracking technologies to operate the platform, enhance your experience, and gather analytics data. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that prevent fraudulent use. These cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred game categories, and display options to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how players use the platform, including pages visited, time spent, and features used. This data helps us improve the platform. Analytics cookies are only set with your consent.
• Security & Fraud Prevention Cookies: Help us detect and prevent fraudulent activity, bot access, and unauthorized account access.

You can manage your cookie preferences through the cookie consent banner displayed on your first visit to the platform, or by adjusting your browser settings. Please note that disabling certain cookies may affect the functionality of the starph11 platform. Strictly necessary cookies cannot be disabled as they are essential for platform operation.

starph11 does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

10 Your Data Privacy Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by starph11:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfils that obligation.
• Right of Access: You have the right to request a copy of the personal data starph11 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 most account information directly through your 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 under PAGCOR and AMLA regulations.
• 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 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 processing carried out prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please submit a written request to our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days. We may require you to verify your identity before processing your request.

11 Children's Privacy & Age Restriction

The starph11 platform is strictly intended for individuals who are at least twenty-one (21) years of age. starph11 does not knowingly collect personal data from individuals under the age of twenty-one (21).

As part of our registration and KYC process, all players are required to verify their age by submitting a valid government-issued photo ID. Any account found to belong to a person under twenty-one (21) years of age will be immediately suspended, all associated personal data will be deleted in accordance with our data disposal procedures, and any funds held in the account will be handled in accordance with our Terms & Conditions and applicable regulatory requirements.

If you believe that a minor has registered an account on the starph11 platform, please contact our support team immediately at [email protected] so that we can take prompt action.

12 Cross-Border Data Transfers

In the course of operating the starph11 platform, your personal data may be transferred to and processed in countries other than the Philippines, particularly where our technology infrastructure, game software providers, or KYC service providers are located outside the Philippines.

Where personal data is transferred outside the Philippines, starph11 ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012. These safeguards may include:

• Contractual clauses that impose data protection obligations on the recipient equivalent to those under Philippine law;
• Transfers to countries that have been assessed as providing an adequate level of data protection;
• Binding corporate rules where transfers are made within a corporate group.

By using the starph11 platform, you acknowledge and consent to the transfer of your personal data to other countries as described in this section, subject to the safeguards outlined above.

13 Third-Party Links & Services

The starph11 platform may contain references to third-party services, such as payment processors (GCash, PayMaya, banking partners) and game software providers. These third parties operate under their own privacy policies, which are independent of this Privacy Policy.

starph11 is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the starph11 platform. starph11 does not endorse or make any representations about the privacy practices of third-party services.

Where starph11 shares personal data with third-party service providers, such sharing is governed by data processing agreements that require those providers to process your data only in accordance with our instructions and applicable data privacy law.

14 Updates to This Privacy Policy

starph11 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made to this Privacy Policy, we will notify registered players by email or through a prominent notice on the platform at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent changes were made. Your continued use of the starph11 platform after the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy.

We recommend reviewing this Privacy Policy periodically to stay informed of how starph11 protects your personal data. The most current version will always be available at starph11.vip/privacy-policy.

15 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by starph11, please contact our Data Protection Officer:

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the chat widget on the starph11 platform
• Response Time: Data privacy requests are handled within fifteen (15) business days of receipt of a verified request.

If you are not satisfied with our response to your data privacy request or complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for administering and implementing the Data Privacy Act of 2012.