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RA 10173 Compliant7 Min ReadVersion 2.4

Privacy Policy

Data privacy standards, processing purposes, dual-role responsibilities, and data subject rights for clubs and organizations using the Club Portal SaaS Platform.

Effective Date: September 2026

Platform: clubportal.org

Version: 2.4

Related Agreements:Terms of UsePrivacy PolicyData Processing Agreement (DPA)

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9 Sections
01Dual-Role Data Governance02Information Collected & Processed03Purpose of Data Processing04Clearance Verification Privacy Guard05Security, Encryption & Offline Caching06Cookie & Diagnostic Telemetry Policy07Data Retention Schedule08Data Subject Rights (RA 10173)09Privacy Inquiries & Data Requests
Data Protection Officer

Have a data subject access request, record correction, or account deletion inquiry under RA 10173?

[email protected]

Response window: 1 to 2 business days.

01

Overview & Dual-Role Data Governance

Club Portal is committed to upholding rigorous data privacy and confidentiality standards pursuant to Republic Act No. 10173 (Philippine Data Privacy Act of 2012). Our data operations operate strictly under a dual-role governance architecture:

Club Officers: Data Controller

Club officers act as Data Controllers for their member rosters, event attendance logs, and fee registries. Officers determine the lawful basis for member list ingestion, verify consent, and authorize dues transactions.

Club Portal: Data Processor

Club Portal operates as Data Processor, providing software infrastructure, database encryption, clearance status computations, and gate attendance check-in synchronization exclusively under officer direction.

02

Information Collected & Processed

To deliver organization management workflows, Club Portal processes personal data across three core categories:

Officer Account Records
• Legal Full Name
• Valid Email Address
• Assigned Role (Admin, Adviser, Manager, Operator)
• Cryptographic Password Hash (bcrypt)
Member Roster & Event Logs
• Member Identification Number
• Registered Full Name
• Program or Department & Standing
• Event Time-In & Time-Out Timestamps
Financial Dues & Transaction Logs
• Deployed Fee Registry Items (Dues, Merch, Fines)
• Payment Method Recorded (Cash, GCash, Bank)
• GCash or Remittance Reference Numbers
• Fee Exemption Grounds & Approving Officer

Sensitive Personal Information Prohibition

Financial records are processed strictly for organization clearance standing. Officers are expressly prohibited from uploading unrelated sensitive personal information such as evaluations, medical files, credit card numbers, or government-issued identity documents.

03

Purpose of Data Processing

Club Portal processes personal data exclusively for verified operational activities on behalf of registered organizations. We do not sell, rent, or monetize personal information.

Roster & Attendance ManagementAuthenticating member presence at scheduled organization meetings and activities.
Financial Dues TransparencyTracking collection balances, issuing digital receipts, and maintaining audited ledgers.
Clearance Sign-Off VerificationComputing eligibility standing so members can confirm completed obligations.
Role-Based Access EnforcementRestricting sensitive actions and financial reports to authorized officers only.
04

Clearance Verification Privacy Guard

To protect member records from unauthorized inspection or mass profiling, the Public Clearance Portal does not offer an open directory or search listing. Verification requires exact dual-field authentication:

Mandatory Dual Verification: Valid Member ID Number + Exact Registered Full Name

Public directory browsing is disabled. To mitigate brute-force attempts and name enumeration scripts, repeated failed lookups trigger an automated 60-second cooldown period. Subsequent probe failures are logged and subject to IP-level throttling.

05

Security, Encryption & Offline Caching

Club Portal implements administrative, physical, and technical safeguards in alignment with National Privacy Commission circulars:

Transport & Data EncryptionAll web communications are enforced over SSL/TLS (HTTPS). Officer passwords are salted and hashed using industry-standard bcrypt algorithms.
Tenant Isolation & Scoped QueriesDatabase queries are strictly segregated by organization workspace boundary, preventing cross-tenant information exposure.
Offline Storage CustodyDuring event check-ins when venue connectivity is degraded, scanner queue records are staged securely in browser IndexedDB storage and synchronized once internet connection is restored.
06

Cookie & Diagnostic Telemetry Policy

Club Portal uses minimal, purposeful web storage and telemetry to deliver secure platform performance:

  • Strictly Necessary Authentication Storage:Session tokens maintain encrypted officer sign-in states, while browser local storage caches UI theme preferences and offline scanner records.
  • Performance & Error Monitoring (Optional):Subject to consent preferences, we use Cloudflare Web Analytics and Google Analytics to monitor system load times and reliability. We also utilize Sentry solely for application error tracking and debugging.

None of the operational telemetry collected is sold to advertisers, traded, or utilized for cross-site behavioral marketing.

07

Data Retention Schedule

Personal data is retained only for the duration required to fulfill organization objectives or until purged by authorized officers:

Data CategoryRetention & Disposal Term
Officer Account DataRetained until deletion is explicitly initiated via Account Settings. Account deletion permanently drops personal credentials, sessions, and role bindings.
Organization Workspace DataMaintained throughout active organization use. Workspace administrators can invoke permanent data erasure at any time via the Purge Organization Data tool.
Attendance & Ledger RecordsGoverned by the organization Data Controller. End-of-cycle records may be locked via Archive Semester for read-only historical verification, or purged upon leadership turnover.
08

Data Subject Rights (RA 10173)

Under the Philippine Data Privacy Act of 2012, registered members and operating officers hold statutory rights regarding their personal data:

• Right to Information & AccessInspect individual clearance and attendance standing via the public portal.
• Right to RectificationRequest corrections for misspelled names, wrong ID numbers, or payment logs.
• Right to Erasure / BlockingRequest record deletion upon leaving the organization or membership graduation.
• Right to File ComplaintEscalate privacy grievances directly to the National Privacy Commission (NPC).
09

Privacy Inquiries & Data Requests

Have privacy questions or data subject requests?

Contact platform support and our data protection officer directly.

[email protected]

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