Privacy Policy

1 Who We Are — Data Controller

phbeti ("phbeti," "we," "us," or "our") is the operator of the online casino and sports betting platform accessible at phbeti.cam and its associated subdomains, mobile applications, and digital services (collectively, the "Platform"). phbeti acts as the Personal Information Controller (PIC) in respect of all personal data collected through the Platform, as that term is defined under Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations.

phbeti operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). In its capacity as a PAGCOR-regulated operator, phbeti is subject to data processing obligations arising from both the Data Privacy Act and applicable PAGCOR licensing conditions, which together govern the lawful basis on which phbeti processes personal data relating to its registered players.

2 Scope of This Privacy Policy

This Privacy Policy applies to all personal data collected, processed, stored, or transmitted by phbeti in connection with your access to and use of the Platform, including data collected during:

• Account registration and profile management.
• Know Your Customer (KYC) identity and age verification procedures.
• Deposit and withdrawal transactions via GCash, Maya, BPI, BDO, UnionBank, and other accepted payment methods.
• Gameplay activity across all casino, sports betting, bingo, and instant game products on the Platform.
• Customer support interactions via live chat, email, and other contact channels.
• Participation in promotional offers, bonuses, and loyalty programmes.
• Browsing activity on the Platform, including through cookies and similar tracking technologies.

This Policy does not apply to personal data processed by third-party websites, services, or applications that may be linked from the Platform. phbeti is not responsible for the privacy practices of third parties, and players are encouraged to review the privacy policies of any third-party service they access independently.

3 Categories of Personal Data We Collect

phbeti collects the following categories of personal data from registered players and platform visitors, as necessary for the purposes described in Section 5:

phbeti does not intentionally collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act (e.g., health data, racial or ethnic origin, religious beliefs) unless specifically required by applicable law or regulatory obligation. Where the collection of such data is unavoidable — for example, where a player's government ID incidentally contains such information — it is handled with the heightened protection prescribed by the Data Privacy Act.

4 How We Collect Personal Data

phbeti collects personal data through the following mechanisms:

4.1 Direct Collection from You

The majority of personal data phbeti holds is provided directly by you during account registration, KYC verification, payment transactions, customer support interactions, and promotional participation. This includes data you voluntarily submit via account forms, ID upload portals, and communication channels.

4.2 Automated Collection

When you access and use the Platform, phbeti automatically collects technical and gameplay data through server logs, session tracking systems, and cookies or similar technologies (see Section 8). This data is collected regardless of whether you are a registered player or an anonymous visitor to the Platform.

4.3 Third-Party Sources

In limited circumstances, phbeti may receive personal data about you from third parties, including: KYC verification service providers who confirm identity document authenticity; payment processors who confirm transaction status; fraud detection services who flag suspicious activity patterns; and regulatory bodies such as PAGCOR who may provide player protection notifications. Data received from third-party sources is processed in accordance with this Policy and the applicable legal basis.

5 Purposes of Processing

phbeti processes your personal data for the following specific and declared purposes:

• Account Registration and Management: Creating and maintaining your phbeti account, authenticating your identity on login, managing account settings and preferences, and communicating account-related information.
• Age and Identity Verification (KYC): Verifying that you meet the minimum age requirement of 21 years as required by PAGCOR, confirming your identity for anti-money laundering compliance, and fulfilling KYC obligations under applicable Philippine law.
• Payment Processing: Processing deposit and withdrawal transactions, reconciling account balances, and complying with financial reporting and anti-money laundering (AML) obligations under Republic Act No. 9160 (Anti-Money Laundering Act) and related AMLC issuances.
• Service Delivery: Providing access to casino games, sports betting markets, live dealer tables, bingo, and all other Platform services, and ensuring the technical stability and security of those services.
• Responsible Gaming: Monitoring gameplay patterns to identify potential signs of problem gambling, administering responsible gaming tools (deposit limits, self-exclusion), and fulfilling PAGCOR responsible gaming obligations.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, money laundering, bonus abuse, account takeover, and other prohibited conduct as described in the phbeti Terms & Conditions.
• Regulatory Compliance: Fulfilling reporting and record-keeping obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities.
• Customer Support: Responding to player inquiries, resolving complaints, and maintaining records of support interactions for quality assurance and dispute resolution purposes.
• Marketing and Promotions: Sending promotional communications, personalised offers, and bonus notifications to players who have consented to receiving marketing communications from phbeti. You may withdraw this consent at any time via your account settings.
• Platform Improvement: Analysing aggregated usage data to improve Platform features, game selection, payment options, and user experience — in a manner that does not identify individual players where technically feasible.

6 Legal Bases for Processing

Under the Data Privacy Act and its Implementing Rules and Regulations, phbeti processes personal data on the following legal bases, depending on the specific purpose involved:

• Contractual Necessity: Processing necessary for the performance of phbeti's contractual obligations to you as a registered player, including account management, game access, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine law, including PAGCOR licensing conditions, AML/KYC requirements under the Anti-Money Laundering Act, and tax reporting obligations.
• Legitimate Interest: Processing necessary for phbeti's legitimate interests in fraud prevention, platform security, and responsible gaming compliance, provided that such interests are not overridden by your rights and freedoms as a data subject.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — in particular, for the sending of direct marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing with Third Parties

phbeti does not sell, rent, or commercially trade your personal data to any third party. We share personal data with third parties only to the extent necessary for the purposes described in this Policy, and subject to contractual data processing agreements that impose equivalent data protection obligations on the recipient. Categories of third-party recipients include:

• Payment Service Providers: GCash (GXI Inc.), Maya (Voyager Innovations), BPI, BDO, UnionBank, and cryptocurrency gateway operators, for the purpose of processing deposit and withdrawal transactions.
• KYC and Identity Verification Providers: Third-party services engaged by phbeti to verify the authenticity of identity documents and confirm player age and identity in compliance with PAGCOR requirements.
• Game Content Providers: Licensed game suppliers (including JILI, Pragmatic Play, PG Soft, and others) who may receive limited technical session data necessary to deliver their games through the Platform.
• Fraud Prevention and Security Services: Third-party services that assist phbeti in detecting and preventing fraudulent activity, account takeover, and other security threats.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Professional Advisers: Legal, accounting, and auditing professionals engaged by phbeti, subject to professional confidentiality obligations.

8 Cookies & Tracking Technologies

phbeti uses cookies and similar tracking technologies (including web beacons, pixel tags, and session storage) on the Platform. These technologies serve the following purposes:

8.1 Strictly Necessary Cookies

Essential for the Platform to function correctly. These include session authentication cookies that keep you logged in during your visit, security cookies that protect against CSRF attacks, and load balancing cookies. These cannot be disabled without impairing Platform functionality.

8.2 Functional Cookies

Remember your preferences and settings — such as your preferred language, responsible gaming settings, and last-used payment method — to personalise your Platform experience across sessions.

8.3 Analytics Cookies

Collect aggregated, anonymised data about how players interact with the Platform — which pages are visited most frequently, where sessions end, and which features are most used — to enable phbeti to improve the Platform. Analytics data is processed in aggregate form and does not identify individual players where technically avoidable.

You may manage your cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from accessing the Platform, but may affect certain personalisation features.

9 Data Retention

phbeti retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR licensing conditions. The following general retention periods apply:

• Account and KYC Data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, as required by PAGCOR and AMLC record-keeping obligations.
• Transaction and Financial Records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act and applicable tax legislation.
• Gameplay Logs: Retained for a minimum of two (2) years for dispute resolution, regulatory audit, and responsible gaming monitoring purposes.
• Customer Support Records: Retained for two (2) years from the date of the last interaction for quality assurance and dispute resolution purposes.
• Marketing Preferences and Consents: Retained for the duration of the account relationship and for one (1) year following withdrawal of consent, to evidence the consent history.
• Technical and Log Data: Retained for twelve (12) months for security monitoring and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data subject's identity.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights as a data subject with respect to your personal data held by phbeti. To exercise any of these rights, please contact phbeti's Data Protection Officer using the details in Section 16.

phbeti will respond to data subject rights requests within fifteen (15) business days of receipt of a verified request. In complex cases, this period may be extended by up to an additional fifteen (15) business days, with written notification of the extension provided to you within the initial period.

11 Children's Privacy and Underage Player Protection

The phbeti platform is intended solely for use by adults aged 21 years and above, in compliance with PAGCOR regulations governing online gaming in the Republic of the Philippines. phbeti does not knowingly collect personal data from persons under the age of 21.

Age verification is a mandatory component of the phbeti KYC process. Any account found to have been registered by a person under 21 years of age will be immediately closed, all related personal data will be deleted to the extent permissible under law, and any balance held in the account will be forfeited in accordance with phbeti's Terms & Conditions and applicable regulatory requirements.

12 Security Measures

phbeti implements and maintains a comprehensive set of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, without limitation:

• SSL/TLS encryption for all data transmitted between your device and phbeti's servers.
• AES-256 encryption for personal data stored in phbeti's databases.
• Role-based access controls limiting internal access to personal data to authorised personnel on a need-to-know basis.
• Regular independent penetration testing and vulnerability assessments of phbeti's infrastructure.
• Intrusion detection and prevention systems monitoring for anomalous access patterns.
• Two-factor authentication available to all players and mandatory for phbeti's internal administrative systems.
• A documented Data Breach Response Plan compliant with NPC Circular No. 16-03 (Personal Data Breach Management), including notification procedures within the 72-hour window required by NPC regulations.
• Regular employee training on data protection obligations and security best practices.

Notwithstanding these measures, no security system is impenetrable. phbeti cannot guarantee absolute security of personal data transmitted over the internet. You are encouraged to maintain the security of your own account credentials and to notify phbeti immediately of any suspected unauthorised access to your account.

13 Cross-Border Data Transfers

In the course of providing Services, personal data held by phbeti may be transferred to, accessed from, or processed in countries outside the Republic of the Philippines — for example, by game content providers or technology infrastructure providers whose servers are located in other jurisdictions.

Where such cross-border transfers occur, phbeti ensures that appropriate safeguards are in place in accordance with Section 21 of the Data Privacy Act and NPC Circular No. 16-01. Safeguards employed include: contractual clauses imposing data protection obligations equivalent to those applicable under Philippine law; verification that the recipient country's data protection framework has been assessed as providing an adequate level of protection; and where applicable, your explicit consent to the transfer.

14 Third-Party Links and Integrated Services

The phbeti Platform may contain links to or integrations with third-party websites, services, or platforms — for example, payment gateway interfaces or game provider portals. These third-party services operate under their own privacy policies, which phbeti does not control and is not responsible for.

phbeti recommends that you review the privacy policy of any third-party service you access from the Platform. The inclusion of a link to a third-party service on the Platform does not constitute phbeti's endorsement of that service's privacy practices or any other aspect of its operations.

15 Updates to This Privacy Policy

phbeti reviews this Privacy Policy at minimum annually, and updates it whenever a material change occurs to our data processing practices, applicable legislation, or PAGCOR regulatory requirements. Material changes will be communicated to registered players via the email address on record or via a notice on the Platform prior to the effective date of the change.

The version of the Privacy Policy in effect at the time of your use of the Platform governs phbeti's processing of your personal data at that time. The "Last Updated" date at the top of this page indicates when the most recent revision was made. Your continued use of the Platform following notification of a material change constitutes your acknowledgment of the updated Policy.

16 Contact Us & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or phbeti's data processing practices — including the exercise of your data subject rights under the Data Privacy Act — please contact phbeti's Data Protection Officer through the following channels:

• Email (DPO & Privacy Inquiries): [email protected]
• Live Chat Support: Available 24/7 through the phbeti Platform.
• About Us Page: Additional regulatory and company information is available at phbeti.cam/about-us.

phbeti aims to respond to all privacy-related inquiries and data subject rights requests within fifteen (15) business days. For urgent account security concerns, live chat is the recommended channel.

If you are not satisfied with phbeti's response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available through official Philippine government channels.