bet2 Privacy Policy

1. Introduction

bet2 ("we," "us," "our") operates the online gaming platform accessible at bet2.asia (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, including registered players, visitors, and prospective users.

This Privacy Policy describes the types of personal information we collect, the purposes for which we use it, the parties with whom we may share it, and the rights available to you as a data subject under Philippine law. It applies to all personal data processed in connection with your use of the bet2 Platform, whether accessed via desktop browser or mobile web.

This Privacy Policy should be read together with our Terms & Conditions. By registering an Account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, bet2 is the personal information controller responsible for the personal data collected through the Platform.

bet2 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. You may contact the DPO at any time using the contact details provided in Section 15 of this Policy.

bet2 operates under the regulatory oversight of PAGCOR — the Philippine Amusement and Gaming Corporation — and complies with all data handling requirements imposed by PAGCOR as a condition of its operating licence.

3. Personal Data We Collect

3.1 Registration & Account Data

When you create a bet2 Account, we collect the following information:

• Full legal name;
• Date of birth (to verify the 21+ age requirement);
• Philippine mobile number;
• Email address;
• Username and encrypted password;
• Preferred language and currency (PHP).

3.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and Philippine AML law, we collect the following KYC documents before processing withdrawals:

• Government-issued Philippine ID (e.g., PhilSys ID, passport, driver's licence, SSS/GSIS ID, Voter's ID);
• Proof of address (e.g., utility bill, bank statement dated within 90 days);
• Proof of payment method (e.g., screenshot of GCash or PayMaya account, bank account details);
• Selfie photograph for identity matching, where required.

3.3 Financial & Transaction Data

We collect records of all financial transactions conducted through your Account, including:

• Deposit and withdrawal amounts, dates, and payment methods;
• GCash or PayMaya account references (partial, masked);
• Bank account details (partial, masked) for bank transfer transactions;
• Bonus and promotional credit history;
• Betting and wagering history.

3.4 Technical & Usage Data

When you access the Platform, we automatically collect certain technical information, including:

• IP address and approximate geographic location (city/region level);
• Device type, operating system, and browser version;
• Session duration, pages visited, and features used;
• Referring URL and search terms used to find the Platform;
• Cookie identifiers and similar tracking technologies (see Section 8).

3.5 Communications Data

If you contact our customer support team, we collect records of your communications, including chat transcripts, email correspondence, and call recordings (where applicable), for quality assurance and dispute resolution purposes.

4. How We Collect Your Data

bet2 collects personal data through the following means:

• Directly from you: When you register an Account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion;
• Automatically: Through cookies, web beacons, and server logs when you access and use the Platform (see Section 8);
• From third parties: From payment processors (e.g., GCash, PayMaya, banks) to verify transaction details; from identity verification service providers during KYC; and from PAGCOR or Philippine law enforcement agencies where required by law;
• From publicly available sources: Where necessary for AML compliance or fraud prevention, we may cross-reference your information against publicly available databases or watchlists.

5. Purposes of Processing

bet2 processes your personal data for the following purposes:

• To create and manage your Account and verify your identity;
• To process deposits, withdrawals, and other financial transactions;
• To comply with PAGCOR licensing requirements, Philippine AML law, and other applicable regulations;
• To conduct KYC identity verification and ongoing due diligence;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited conduct;
• To provide customer support and resolve disputes;
• To send you transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts);
• To send you promotional communications and personalized offers, where you have consented to receive them;
• To improve the Platform's features, performance, and user experience through analytics;
• To enforce our Terms & Conditions and other policies;
• To support responsible gaming initiatives, including monitoring for signs of problem gambling and administering self-exclusion requests.

6. Legal Bases for Processing

Under the Philippine Data Privacy Act, bet2 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you (i.e., the Terms & Conditions), including Account management, transaction processing, and customer support;
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations, AML obligations under Republic Act No. 9160 (as amended), and the Data Privacy Act itself;
• Legitimate interests: Processing necessary for bet2'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, informed, and unambiguous consent, including the sending of promotional communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

bet2 does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

7.1 Regulatory & Law Enforcement Authorities

We are required by Philippine law to share certain personal data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies upon lawful request or as required by our operating licence.

7.2 Payment Processors

We share transaction data with payment processors (GCash, PayMaya/Maya, and partner banks including BPI, BDO, Metrobank, UnionBank, Landbank, PNB, and Security Bank) to facilitate deposits and withdrawals. These processors are bound by their own privacy policies and applicable Philippine financial regulations.

7.3 Identity Verification Providers

We engage third-party KYC and identity verification service providers to assist with document verification and fraud screening. These providers process your data solely on our instructions and are contractually bound to maintain confidentiality and comply with the Data Privacy Act.

7.4 Technology & Infrastructure Providers

We use third-party cloud hosting, analytics, and security service providers to operate the Platform. These providers act as personal information processors under our instructions and are subject to data processing agreements that require them to protect your data in accordance with applicable law.

7.5 Professional Advisers

We may share personal data with our legal, financial, and compliance advisers where necessary for the conduct of our business, subject to professional confidentiality obligations.

8. Cookies & Tracking Technologies

bet2 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences such as language settings, preferred payment method, and game display options to provide a more personalized experience.
• Analytics cookies: Help us understand how players use the Platform, which pages are most visited, and where technical issues occur. This data is aggregated and anonymized where possible.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our campaigns. These are only set with your consent.

You may manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate securely.

9. Data Security

bet2 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• AES-256 encryption for all personal data stored at rest;
• TLS 1.3 encryption for all data transmitted between your device and our servers;
• Multi-factor authentication (MFA) for all internal systems and administrative access;
• Role-based access controls ensuring that only authorized personnel can access personal data, strictly on a need-to-know basis;
• Regular third-party security audits, vulnerability assessments, and penetration testing;
• 24/7 intrusion detection and monitoring systems;
• Secure data backup and disaster recovery procedures;
• Staff training on data privacy and security obligations under Philippine law.

In the event of a personal data breach that is likely to result in harm to affected individuals, bet2 will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with the Data Privacy Act and NPC Circular No. 16-03.

While bet2 takes all reasonable steps to protect your personal data, no system is completely immune to security risks. You are responsible for maintaining the security of your Account credentials and for notifying bet2 immediately if you suspect unauthorized access to your Account.

10. Data Retention

bet2 retains your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Philippine law and PAGCOR regulations. The following retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from the date of Account closure, as required by Philippine AML law (Republic Act No. 9160, as amended by Republic Act No. 10365);
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with PAGCOR and AMLC requirements;
• Customer support communications: Retained for two (2) years from the date of the last communication, for dispute resolution and quality assurance purposes;
• Technical and usage data: Retained for up to twelve (12) months in identifiable form, after which it is anonymized or deleted;
• Marketing consent records: Retained for the duration of your Account and for three (3) years after Account closure, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized using industry-standard data destruction methods. Where data cannot be immediately deleted due to technical constraints, it will be isolated and protected from further processing until deletion is possible.

11. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by bet2:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy;
• Right of access: You have the right to request a copy of the personal data we hold 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;
• 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 legal retention obligations;
• 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 it 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 contact our Data Protection Officer using the details in Section 15. bet2 will respond to all data subject requests within fifteen (15) Philippine business days. We may require you to verify your identity before processing your request.

12. Children & Minors

The bet2 Platform is strictly intended for individuals who are twenty-one (21) years of age or older, in accordance with Philippine law and PAGCOR regulations. bet2 does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated Account, delete the personal data in question (subject to any legal obligations to retain evidence of the underage access), and report the matter to PAGCOR as required.

If you are a parent or guardian and believe that your child under 21 has registered on the Platform or provided personal data to bet2, please contact us immediately using the details in Section 15 so that we can take appropriate action.

13. Cross-Border Data Transfers

bet2 primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed from servers or service providers located outside the Philippines — for example, where we use international cloud infrastructure or technology providers.

Where such transfers occur, bet2 ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the NPC;
• Entering into data processing agreements with international service providers that incorporate standard contractual clauses approved by the NPC;
• Conducting transfer impact assessments where required to ensure that your rights are not undermined by the transfer.

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

14. Amendments to This Privacy Policy

bet2 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR requirements. Material changes will be communicated to registered players via SMS and email to the contact details on file, and will be posted on the Platform with an updated "Last Updated" date at the top of this page.

Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy. If you do not agree to the amended Privacy Policy, you must cease using the Platform and may request Account closure as described in our Terms & Conditions.

We recommend reviewing this Privacy Policy periodically to stay informed about how bet2 protects your personal data.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by bet2, please contact our Data Protection Officer:

Data Protection Officer — bet2

Email: privacy at bet2.asia
General Support: support at bet2.asia

All data subject requests and privacy-related inquiries will be acknowledged within three (3) Philippine business days and resolved within fifteen (15) Philippine business days, subject to the complexity of the request and any identity verification requirements.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph (please type this address directly into your browser).