sbet Privacy Policy

1 Introduction

sbet ("sbet," "we," "us," or "our") is committed to protecting the privacy and personal data of every individual who uses the sbet platform at sbet.cam. This Privacy Policy describes how sbet collects, processes, stores, shares, and protects personal data relating to registered Members and visitors of the sbet Platform, and it sets out the rights available to data subjects under applicable Philippine privacy legislation.

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations ("IRR"), as administered by the National Privacy Commission ("NPC") of the Philippines. sbet also processes data in accordance with relevant PAGCOR regulatory requirements applicable to licensed online gaming operators.

By registering for an sbet account, accessing the sbet Platform, or using any sbet service, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, please do not use the sbet Platform.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, sbet is the personal information controller ("PIC") responsible for personal data collected through the sbet Platform. sbet determines the purposes and means of processing Member personal data and is accountable for ensuring that such processing is carried out in accordance with this Privacy Policy and applicable Philippine law.

sbet has designated a Data Protection Officer ("DPO") who oversees compliance with data privacy obligations, handles Member data rights requests, and serves as the primary point of contact with the National Privacy Commission. Contact details for the sbet DPO are provided in Section 15 of this Privacy Policy.

3 Personal Data We Collect

3.1 Registration Data

When you create an sbet account, we collect the information you provide during registration, including: full legal name, date of birth, Philippine mobile number, email address, and preferred username. This information is required to create and administer your sbet account.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR licensing requirements and the Anti-Money Laundering Act (RA 9160, as amended), sbet is required to verify the identity of all Members before processing withdrawals. KYC data collected may include: copies of a valid Philippine government-issued ID (passport, driver's license, SSS ID, UMID, or PhilSys National ID), proof of address documents, and in certain cases, source of funds documentation. This data is processed under legal obligation.

3.3 Financial Transaction Data

sbet collects records of all financial transactions conducted through your account, including deposit amounts, payment methods used (GCash, PayMaya, BPI, BDO, or Metrobank), withdrawal requests, wagering activity, and PHP Wallet balances. This data is necessary for account management, fraud prevention, and regulatory reporting.

3.4 Device and Technical Data

When you access the sbet Platform, we automatically collect certain technical information including: IP address, device type and operating system, browser type and version, session duration, and general geographic location derived from IP address. This data is used for security monitoring, fraud detection, and platform performance optimisation.

3.5 Gameplay and Behavioural Data

sbet records your activity on the Platform including games played, bet amounts, session times, and promotional participation. This data is used to personalise your gaming experience, operate responsible gaming tools, administer loyalty programs, and detect patterns indicative of problem gambling or fraudulent activity.

3.6 Communications Data

If you contact sbet through live chat, email, or any other support channel, we retain records of those communications — including your messages and our responses — for quality assurance, dispute resolution, and audit purposes.

4 How We Use Your Personal Data

sbet uses the personal data we collect for the following purposes:

5 Legal Basis for Processing

sbet processes your personal data on the following legal bases as recognised under RA 10173 and its IRR:

• Consent: Where you have given explicit, informed consent to a specific processing activity, such as receiving sbet promotional communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contractual Necessity: Processing necessary to perform the contract between sbet and you as a registered Member — including account management, game access, and payment processing.
• Legal Obligation: Processing required to comply with Philippine law, including KYC obligations under RA 9160 (Anti-Money Laundering Act), reporting obligations to PAGCOR, and compliance with court orders or law enforcement requests.
• Legitimate Interest: Processing necessary for sbet's legitimate business interests, such as fraud prevention, platform security, and responsible gaming monitoring, provided that such interests are not overridden by your fundamental privacy rights.

6 Data Sharing & Disclosure

6.1 sbet Does Not Sell Personal Data

sbet does not sell, rent, or trade your personal data to any third party for commercial purposes. Any sharing of personal data is limited to what is necessary and proportionate for the purposes described in this Privacy Policy.

6.2 Service Providers and Partners

sbet engages trusted third-party service providers who process personal data on sbet's behalf as personal information processors ("PIPs") under RA 10173. These include payment processors (GCash, PayMaya, and banking partners), KYC identity verification service providers, certified game software providers who may have access to anonymised gameplay data for technical integration purposes, and cloud hosting and infrastructure providers. All such providers are bound by data processing agreements that require compliance with RA 10173 and this Privacy Policy.

6.3 Regulatory and Law Enforcement Disclosure

sbet is required by Philippine law to share certain Member data with PAGCOR as its licensing authority, the Anti-Money Laundering Council (AMLC) where a reportable transaction is identified, and with other competent Philippine government authorities when required by a valid court order, subpoena, or lawful government request. Such disclosures will be limited to what is legally required.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of sbet's assets, Member personal data may be transferred to the succeeding entity, subject to the same privacy protections as set out in this Privacy Policy. sbet will notify affected Members of any such transfer in advance where practicable.

7 Data Retention

sbet retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable Philippine law. The following indicative retention periods apply:

• Account and registration data: Retained for the duration of your membership and for a minimum of five (5) years following account closure, as required under PAGCOR licensing conditions and the Anti-Money Laundering Act.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the end of the business relationship, in compliance with RA 9160.
• Financial transaction records: Retained for a minimum of five (5) years, as required by AML regulations and PAGCOR.
• Customer support communications: Retained for two (2) years following the closure of the relevant support interaction.
• Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter for compliance demonstration purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised using industry-standard methods. Anonymised, aggregated data may be retained indefinitely for statistical analysis and platform improvement purposes.

8 Security Measures

sbet implements a range of technical and organisational security measures to protect Member personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the sbet Platform;
• Encryption of stored personal data at rest using industry-standard encryption algorithms;
• Role-based access controls restricting employee access to personal data on a strict need-to-know basis;
• Regular independent security audits and vulnerability assessments;
• Multi-factor authentication requirements for sbet staff accessing internal systems containing Member data;
• Intrusion detection systems and real-time security monitoring;
• Staff data privacy training and binding data confidentiality obligations.

In the event of a personal data breach that is likely to result in serious harm to affected Members, sbet will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected Members without undue delay, in accordance with the requirements of RA 10173 and NPC Circular 16-03.

9 Cookies & Similar Technologies

9.1 What Cookies sbet Uses

The sbet Platform uses the following categories of cookies and similar tracking technologies:

• Strictly Necessary Cookies: Essential for the operation of the sbet Platform — these maintain your login session, remember your language preferences, and enable core platform functionality. These cookies cannot be disabled without significantly impairing your ability to use sbet.
• Performance and Analytics Cookies: Used to collect aggregated, anonymised information about how Members use the sbet Platform, helping us identify pages that perform well or poorly and improve overall user experience. Individual Members are not identified through this data.
• Functional Cookies: Allow the Platform to remember choices you make — such as your preferred game view or table stake settings — to provide a more personalised experience.

9.2 Managing Cookies

You can manage or disable cookies through your browser's settings at any time. Instructions for managing cookies are available in your browser's help documentation. Please note that disabling strictly necessary cookies may prevent you from using certain features of the sbet Platform, including the ability to maintain a login session.

10 Your Data Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by sbet:

To exercise any of the above rights, please submit a written request to the sbet Data Protection Officer at the contact details provided in Section 15. sbet will respond to all verified data rights requests within fifteen (15) working days of receipt, as required by the NPC. In complex cases, this period may be extended by a further fifteen (15) working days with prior notification to you.

If you believe sbet has not adequately addressed your privacy concerns, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

11 Children and Minors

The sbet Platform is strictly intended for individuals aged twenty-one (21) years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. sbet does not knowingly collect personal data from individuals under the age of 21. If sbet becomes aware that personal data has been submitted by or on behalf of a person under 21, that account will be immediately closed, any deposited funds returned, and all associated personal data deleted, except where retention is required by applicable law.

12 Third-Party Links

The sbet Platform may contain links to third-party websites or services operated by sbet's licensed game providers or business partners. This Privacy Policy applies solely to personal data processed by sbet through the sbet Platform. sbet has no control over the privacy practices of third-party websites and is not responsible for their content or data handling procedures. We encourage you to review the privacy policies of any third-party websites you visit independently of sbet.

13 Cross-Border Data Transfers

In the course of providing its services, sbet may transfer certain Member personal data to servers or service providers located outside the Philippines — for example, to certified cloud infrastructure providers or licensed game software providers whose data processing facilities are located in other jurisdictions. Where such transfers occur, sbet ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required by RA 10173, including contractual data processing agreements with overseas recipients. sbet will not transfer personal data to a foreign country unless that country has been deemed to have adequate data protection standards or where appropriate contractual safeguards have been established.

14 Changes to This Privacy Policy

sbet reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, our data processing practices, or the services we offer. The most current version of this Privacy Policy will always be available at sbet.cam/privacy-policy. The "Last Updated" date at the top of this page indicates when the most recent revision was made.

For material changes that significantly affect how we process your personal data, sbet will provide advance notice through a prominent notice on the sbet Platform and, where practicable, by direct notification to your registered email address. Continued use of the sbet Platform following such notification constitutes acceptance of the revised Privacy Policy.

15 Contact & Data Protection Officer

For all privacy-related inquiries, data rights requests, or concerns regarding sbet's processing of your personal data, please contact the sbet Data Protection Officer through the following channels:

• Email: [email protected] (please include "Data Privacy" in the subject line)
• Live Chat: Available 24/7 through the sbet Platform — select "Privacy / Data Request" as the issue category

sbet will acknowledge all data privacy inquiries within three (3) working days and will endeavour to fully resolve data rights requests within fifteen (15) working days, as mandated by RA 10173. For complaints that cannot be resolved through sbet's internal process, you may submit a formal complaint to the National Privacy Commission of the Philippines through its official channels.