bet2bet Privacy Policy

This Privacy Policy applies to all personal data collected, processed, and stored by bet2bet in connection with the operation of the bet2bet online casino and sports betting platform accessible at bet2bet.app. It covers all players, registered account holders, and visitors to the bet2bet website located in the Philippines or accessing the platform from Philippine territory.

bet2bet is the personal information controller (PIC) responsible for the personal data you provide when you register an account, make a deposit or withdrawal, contact our support team, or otherwise interact with our platform. As a PIC, bet2bet is bound by the obligations set out in the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

This Policy should be read together with our Terms & Conditions. By registering an account with bet2bet, you acknowledge that you have read, understood, and consented to the data practices described in this Privacy Policy. If you do not agree with any part of this Policy, you must not create or continue to use a bet2bet account.

bet2bet collects the following categories of personal data in the course of operating our platform and fulfilling our regulatory obligations as a PAGCOR-regulated online gaming operator:

Identity & Contact Data

• Full legal name (as it appears on a government-issued ID)
• Date of birth
• Nationality and country of residence
• Registered email address
• Philippine mobile number
• Residential address (barangay, city/municipality, province)

Identity Verification (KYC) Data

• Government-issued ID type and number (e.g., PhilSys, Passport, SSS, UMID, Driver's License, Voter's ID)
• Copies of submitted KYC documents
• Selfie or liveness verification image where required
• Proof of address documentation

Financial & Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (GCash account reference, PayMaya reference, bank account last digits — we do not store full card numbers)
• Wallet balance history
• Bonus and promotional credit records

Gaming Activity Data

• Bet history, game session logs, and wagering records
• Sports and esports betting markets accessed and settled
• Bingo, slot, and arcade game participation records
• Responsible gaming tool usage (deposit limits set, self-exclusion periods, session reminders)

Technical & Device Data

• IP address at registration and login
• Device type, operating system, and browser
• Cookie identifiers and session tokens
• Geolocation data (city/region level, derived from IP)
• Platform access timestamps and session durations

Communications Data

• Customer support chat transcripts and email correspondence
• Feedback and survey responses
• Records of any dispute submissions

bet2bet collects your personal data through the following means:

Where bet2bet receives data about you from a third-party service provider (such as a KYC verification partner or payment processor), that data is subject to the same protections described in this Privacy Policy.

bet2bet processes your personal data only for specific, legitimate purposes. We do not use your data for any purpose that is incompatible with the reason it was originally collected. The primary purposes for which we process your personal data are:

• Account Creation & Management: To register your account, authenticate your identity at login, and maintain your profile settings and preferences.
• KYC & Age Verification: To verify that you meet the minimum age requirement of 21 years and to confirm your identity as required by PAGCOR regulations and Philippine AML law.
• Payment Processing: To facilitate deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, 7-Eleven, and Cebuana Lhuillier.
• Game Provision: To operate and deliver slot games, live casino, bingo, Dino Hunter, and esports betting services to your account.
• Fraud Prevention & Security: To detect and prevent unauthorized access, fraudulent transactions, multi-accounting, bonus abuse, and other prohibited activities.
• Anti-Money Laundering (AML) Compliance: To monitor transactions and report suspicious activity to the Anti-Money Laundering Council (AMLC) as required under Republic Act No. 9160, as amended.
• Responsible Gaming: To monitor gameplay patterns, administer self-exclusion and deposit limit tools, and intervene where problem gambling indicators are detected.
• Customer Support: To respond to your inquiries, resolve disputes, and process complaints.
• Regulatory Reporting: To fulfill our mandatory reporting obligations to PAGCOR, the NPC, the AMLC, and other competent Philippine authorities.
• Platform Improvement: To analyze aggregated, anonymized usage data to improve platform performance, user experience, and game selection.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may withdraw this consent at any time via your account settings.

Under the Data Privacy Act of 2012, bet2bet processes your personal data on the following lawful bases:

• Consent: Where you have given us clear, informed consent — for example, for marketing communications and the use of non-essential cookies.
• Contractual Necessity: Processing that is necessary to fulfill the contract between you and bet2bet — specifically, to operate your account, process your transactions, and deliver gaming services.
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR licensing conditions, AML reporting obligations under RA 9160, data breach notification requirements under RA 10173, and regulatory directives from competent authorities.
• Legitimate Interest: Processing carried out for bet2bet's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your data protection rights.

Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal, nor will it affect processing carried out on other legal bases.

bet2bet does not sell, rent, or trade your personal data to third parties for their own commercial marketing purposes. We share your data only in the following circumstances and with the following categories of recipients:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, 7-Eleven, and Cebuana Lhuillier — to process deposit and withdrawal transactions. These parties receive only the minimum data necessary to complete the transaction.
• KYC & Identity Verification Partners: Licensed third-party identity verification service providers used to perform document verification and liveness checks as part of our KYC process.
• Game Content Providers: Providers of slot games, live casino studios, and other game content may receive session data necessary to deliver game functionality to your account. These providers operate under strict data processing agreements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other Philippine government authorities, as required by applicable law or in response to valid legal process.
• Law Enforcement: Philippine National Police (PNP), National Bureau of Investigation (NBI), or other law enforcement agencies, in response to lawful orders, subpoenas, or court orders.
• Professional Advisors: Legal, audit, and compliance advisors engaged by bet2bet who are bound by confidentiality obligations.
• Successors in Business: In the event of a merger, acquisition, or sale of bet2bet's business operations, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

bet2bet uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit our website. We use the following types of cookies:

• Essential Cookies: Required for the platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. You cannot opt out of essential cookies while using the platform.
• Functional Cookies: Store your preferences such as language settings, preferred payment method, and display settings to improve your experience on return visits.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the platform — which games are most popular, how players navigate between sections, and where technical errors occur. This data helps us improve the platform.
• Session Security Cookies: Used to detect suspicious login behavior, prevent session hijacking, and protect your account from unauthorized access.

You may manage non-essential cookies through your browser settings. Disabling analytics or functional cookies will not prevent you from using the platform but may reduce the quality of your experience. Essential and security cookies cannot be disabled without logging out of your account.

bet2bet retains your personal data for no longer than is necessary for the purposes for which it was collected, subject to the retention periods required by applicable Philippine law:

Where a legal hold is placed on your data — for example, due to an ongoing investigation, dispute, or regulatory inquiry — the relevant data will be retained beyond the standard periods until the matter is fully resolved.

On expiry of the applicable retention period, your personal data will be securely deleted or anonymized in a manner that prevents re-identification.

bet2bet implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the bet2bet platform is encrypted in transit using industry-standard TLS protocols.
• Encryption at Rest: Sensitive personal data, including KYC documents and payment references, is encrypted in storage using AES-256 encryption.
• Access Controls: Access to personal data is restricted to bet2bet personnel and authorized service providers who have a demonstrated need to access that data. Role-based access controls and multi-factor authentication are enforced for all internal systems.
• Intrusion Detection: Our platform infrastructure is monitored 24/7 for suspicious access patterns, unauthorized login attempts, and anomalous transaction activity.
• Regular Security Audits: bet2bet conducts periodic internal and third-party security assessments, including penetration testing and vulnerability scanning.
• Data Breach Response: In the event of a personal data breach that poses a risk to your rights, bet2bet will notify the National Privacy Commission (NPC) within 72 hours of discovery, and will notify affected players as required under RA 10173 and NPC Circular No. 16-03.

Under the Data Privacy Act of 2012, as a data subject you have the following rights with respect to your personal data held by bet2bet:

To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Privacy Request — [Your Account ID]". We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days, as required under the NPC's implementing rules.

Note that certain rights are subject to limitations where legal obligations require continued data retention or processing — for example, we cannot delete AML-related transaction records during the mandatory 5-year retention period.

bet2bet is an adults-only platform. The minimum age requirement for all bet2bet players is 21 years old, in accordance with Philippine law on casino-style gambling and PAGCOR regulatory requirements. We do not knowingly collect, process, or retain personal data from individuals below 21 years of age.

During the registration process, all applicants are required to declare that they are 21 years of age or older. Age verification is further enforced through our mandatory KYC process, which requires submission of a government-issued ID confirming date of birth before full account access is granted.

If bet2bet discovers or is notified that an account has been registered by a person under 21 years of age:

• The account will be immediately suspended and permanently closed.
• All personal data associated with the account will be deleted from our systems, subject to any legal retention obligations relating to the incident.
• Any funds deposited will be returned to the original payment method used, less any amounts already wagered.
• The incident will be reported to PAGCOR as required under our operating conditions.

If you have reason to believe that a minor has accessed or registered on the bet2bet platform, please notify us immediately at [email protected].

The bet2bet platform integrates with a number of third-party service providers who may process personal data on bet2bet's behalf as personal information processors (PIPs) under RA 10173. These include:

• Payment Gateway Providers: Process financial transactions and may collect payment method verification data directly from you during deposit and withdrawal flows.
• KYC & AML Verification Services: Process submitted identity documents and perform automated verification checks. These providers are contractually prohibited from using your KYC data for any purpose other than identity verification for bet2bet.
• Game Content Providers: Provide the slot, live casino, bingo, arcade, and esports betting game engines. Game providers receive session identifiers and gameplay data necessary to run the games but are not provided with your full identity data.
• Cloud Infrastructure Providers: Host the bet2bet platform infrastructure. All cloud hosting providers are subject to strict data processing agreements and are required to implement equivalent security standards.
• Customer Support Platform: Provides the live chat and ticketing infrastructure used by our support team. Chat transcript data is stored within this platform and subject to its own security controls, governed by our data processing agreement.

All third-party service providers engaged by bet2bet as personal information processors are bound by written data processing agreements that require them to process your data only on bet2bet's documented instructions, to implement appropriate security measures, and to comply with RA 10173 and applicable data protection standards.

bet2bet is not responsible for the privacy practices of third-party websites or services that are not operated by bet2bet and that are not integrated into the bet2bet platform.

In some circumstances, personal data processed by bet2bet may be transferred to or accessed from locations outside the Philippines — for example, where a cloud infrastructure provider or game content provider operates servers located in other jurisdictions such as Singapore, Japan, or the European Union.

Where such cross-border transfers occur, bet2bet ensures that an adequate level of data protection is maintained through one or more of the following mechanisms:

• Transfer to a country recognized by the NPC as providing an adequate level of data protection.
• Standard contractual clauses or equivalent contractual safeguards approved by the NPC, binding the recipient to comply with data protection standards equivalent to those in RA 10173.
• Binding corporate rules where data is transferred within a group of companies.
• Your explicit consent to the transfer, provided after being informed of the risks associated with the absence of an adequacy finding.

bet2bet will not transfer your personal data cross-border to any jurisdiction or entity that cannot demonstrate an adequate and equivalent level of data protection as required under Philippine law.

bet2bet may update this Privacy Policy from time to time to reflect changes in our data practices, the services we offer, or applicable legal requirements. When we make material changes — that is, changes that significantly affect your privacy rights or the way we process your personal data — we will:

• Post a notice on the bet2bet platform at least 14 days before the updated Policy takes effect.
• Send an email notification to your registered email address summarizing the key changes.
• Update the "Last Updated" date displayed at the top of this Policy.

For minor or non-material changes (such as typographical corrections or clarifications that do not alter the substance of our data practices), the updated Policy will take effect immediately upon posting, and we may not provide advance notice.

Your continued use of the bet2bet platform after the effective date of any updated Privacy Policy constitutes your acknowledgment and acceptance of the revised terms. If you do not agree with the updated Privacy Policy, you should close your account and cease using the platform before the effective date.

We encourage you to review this Privacy Policy periodically to stay informed about how bet2bet protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or bet2bet's data processing practices, please contact our Data Protection Officer (DPO) through the following channels:

• Email: [email protected] (Subject line: "Privacy / DPO Request — [Your Account ID]")
• Response Time: We aim to acknowledge all data privacy requests within 5 business days and resolve them within 30 calendar days.
• Operating Hours: Our support team is available 24/7 via live chat inside your account dashboard for general inquiries. DPO-specific requests are handled during Philippine business hours (Monday to Friday, 9:00 AM – 6:00 PM PHT).

Filing a Complaint with the NPC

If you believe that bet2bet has violated your data privacy rights under RA 10173 and you are not satisfied with our response to your complaint, you have the right to file a formal complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the government body responsible for administering and enforcing the Data Privacy Act of 2012.

Information on how to file a complaint with the NPC is available through their official government channels. bet2bet fully cooperates with NPC investigations and will respond promptly to any inquiry or order from the Commission.