pelbet Privacy Policy – How We Collect, Use, and Protect Your Personal Data

1. Data Controller

1.1. For the purposes of the Data Privacy Act of 2012, pelbet ("pelbet," "we," "us," or "our") is the Personal Information Controller (PIC) responsible for your personal data collected through the pelbet Platform at pelbet.one.

1.2. pelbet has appointed a Data Privacy Officer (DPO) who is responsible for overseeing compliance with applicable data protection laws. Contact details for the pelbet DPO are set out in Section 15 of this Policy.

1.3. This Policy applies to the personal data of all Members, registered users, and visitors to the pelbet Platform, regardless of their location within the Philippines.

2. Scope of This Policy

2.1. This Privacy Policy applies to all personal data collected, processed, stored, or transmitted by pelbet in connection with:

• Account registration and maintenance;
• Identity verification and Know Your Customer (KYC) procedures;
• Deposits, withdrawals, and payment processing;
• Participation in games, betting markets, and promotions on the Platform;
• Customer support communications;
• Marketing and promotional communications (where consent has been provided);
• Compliance with PAGCOR regulations and anti-money laundering (AML) obligations;
• Use of cookies and similar tracking technologies on the pelbet website.

2.2. This Policy does not apply to third-party websites or services that may be linked from the pelbet Platform. pelbet is not responsible for the privacy practices of third-party operators.

3. Personal Data We Collect

3.1. The categories of personal data that pelbet may collect include:

3.2. pelbet does not collect sensitive personal information (as defined under the Data Privacy Act of 2012) unless strictly required for identity verification purposes, in which case such data is handled with heightened security controls and processed only to the extent necessary.

4. How We Collect Your Data

4.1. pelbet collects personal data through the following means:

• Direct collection: Information you provide when registering an Account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in a promotion;
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, log files, and session monitoring tools;
• Third-party sources: Identity and fraud-screening data from licensed identity verification and AML screening service providers engaged by pelbet to fulfil its regulatory obligations;
• Payment processors: Transaction confirmation data from GCash, Maya, BPI, BDO, and other payment service providers used for deposit and withdrawal processing.

5. Legal Basis for Processing

5.1. pelbet processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to provide the services you have contracted for as a registered pelbet Member (account management, game access, payment processing);
• Legal obligation: Processing required to comply with PAGCOR regulatory requirements, AML obligations under the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications, where you have provided explicit consent. You may withdraw marketing consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Personal Data

6.1. pelbet uses the personal data it collects for the following purposes:

• To create, verify, and manage your pelbet Account;
• To process deposits and withdrawals via GCash, Maya, BPI, BDO, and other supported payment methods;
• To verify your age and identity in compliance with the 21+ age restriction and PAGCOR KYC requirements;
• To conduct AML and counter-terrorism financing (CTF) screening as required under Philippine law;
• To deliver customer support services, including responding to queries via live chat and email;
• To operate, maintain, and improve the pelbet Platform, including personalising your game lobby experience;
• To detect and prevent fraud, collusion, account sharing, and other prohibited conduct;
• To monitor for responsible gaming indicators and implement account restrictions or interventions where appropriate;
• To send transactional communications (account notifications, payment confirmations, security alerts);
• To send marketing communications regarding pelbet promotions, new games, and offers, where you have consented to receive such communications;
• To generate aggregate, anonymised analytics data for internal reporting and platform optimisation.

7. Sharing Your Personal Data

7.1. pelbet does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes.

7.2. pelbet may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment service providers: GCash, Maya, BPI, BDO, UnionBank, and other payment processors, for the purpose of processing your deposits and withdrawals. These providers operate as independent data controllers for transactions conducted through their platforms;
• Identity verification providers: Licensed KYC and AML screening service providers engaged to assist pelbet in fulfilling its regulatory verification obligations;
• Game technology providers: Game software providers who supply live dealer studio services or RNG game software to the pelbet Platform, to the extent necessary for game delivery and dispute resolution;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or court order;
• IT and infrastructure providers: Cloud hosting, database management, and cybersecurity service providers who process data on behalf of pelbet as Personal Information Processors under data processing agreements.

7.3. In all cases where personal data is shared with third-party processors, pelbet ensures that appropriate contractual safeguards are in place requiring those processors to protect your data with standards at least equivalent to those applied by pelbet.

8. Cookies & Tracking Technologies

8.1. The pelbet Platform uses cookies and similar tracking technologies to operate core Platform functions, maintain session state, prevent fraud, and gather analytics data for service improvement.

8.2. The following categories of cookies are used on the Platform:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled without impairing Platform functionality;
• Functional cookies: Remember your preferences (e.g., language, game lobby view settings) to improve your experience;
• Analytics cookies: Collect aggregate data on how Members use the Platform (pages visited, session duration, feature engagement) to support ongoing improvement. This data is processed in anonymised form;
• Security and fraud-prevention cookies: Used to detect and prevent suspicious login activity and fraudulent account behaviour.

8.3. You may manage cookie preferences through your browser settings. However, disabling strictly necessary cookies will impair your ability to log in to and use the pelbet Platform. pelbet does not use third-party advertising or behavioural tracking cookies.

9. Data Security

9.1. pelbet implements a comprehensive information security programme to protect personal data against unauthorised access, disclosure, alteration, and destruction. Security measures include:

• SSL/TLS encryption for all data in transit between user devices and pelbet servers;
• Encryption of personal data and financial data at rest;
• Role-based access controls limiting data access to authorised pelbet personnel;
• Multi-factor authentication for internal system access;
• Regular vulnerability assessments and penetration testing;
• Continuous security monitoring and intrusion detection systems;
• Formal incident response procedures aligned with NPC breach notification requirements.

9.2. While pelbet takes all reasonable measures to protect your personal data, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. Members are advised to take personal security precautions, including enabling two-factor authentication (2FA) on their pelbet Account and using a strong, unique password.

10. Data Retention

10.1. pelbet retains personal data for as long as is necessary to fulfil the purposes outlined in this Policy, or as required by applicable Philippine law.

10.2. Specific retention periods applicable to key data categories:

• Account and identity data: For the duration of the Account plus five (5) years following account closure, as required by PAGCOR and AMLA record-keeping obligations;
• Transaction and financial records: Five (5) years from the date of each transaction, in accordance with AMLA requirements;
• KYC documentation: Five (5) years from account closure or the date the relevant KYC document was last relied upon, whichever is later;
• Customer support communications: Two (2) years from the date of the communication, unless longer retention is required for ongoing dispute resolution;
• Technical and log data: Twelve (12) months from collection, after which it is deleted or anonymised.

10.3. Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised.

11. Your Data Subject Rights

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed. This Policy fulfils that obligation;
• Right of access: You may request a copy of the personal data pelbet holds about you, along with information about how it is processed;
• Right to rectification: You may request correction of inaccurate or incomplete personal data in pelbet's records;
• Right to erasure or blocking: You may request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to pelbet's legal retention obligations;
• Right to object: You may object to processing of your personal data based on legitimate interests, and you may withdraw consent for marketing communications at any time;
• Right to data portability: Where technically feasible and legally applicable, you may request your personal data in a structured, commonly used format;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

11.1. pelbet will respond to data subject rights requests within thirty (30) calendar days of receipt. Complex requests may require an extension, in which case you will be notified.

12. Children's Privacy

12.1. The pelbet Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine law and PAGCOR regulations governing casino-style gaming.

12.2. pelbet does not knowingly collect personal data from individuals under the age of 21. If pelbet discovers that it has inadvertently collected personal data from a person under 21, such data will be immediately deleted and the associated Account closed.

12.3. If you believe that pelbet has collected personal data from a person under the age of 21, please contact the pelbet Data Privacy Officer immediately using the details in Section 15.

13. Cross-Border Data Transfers

13.1. Some of pelbet's service providers and game technology partners may be located outside the Philippines. Where personal data is transferred to a country outside the Philippines, pelbet ensures that:

• The recipient country provides an adequate level of data protection as recognised by the National Privacy Commission; or
• Appropriate contractual safeguards (such as data processing agreements containing standard contractual clauses) are in place with the recipient; or
• The transfer is necessary for the performance of a contract between you and pelbet (e.g., processing a payment through an international payment network).

13.2. pelbet's primary data storage and processing infrastructure is located within the Asia-Pacific region. Where cross-border transfers occur, they are limited to the minimum data necessary for the specific processing purpose.

14. Updates to This Privacy Policy

14.1. pelbet may update this Privacy Policy from time to time to reflect changes in our data practices, updates to applicable Philippine law, or PAGCOR regulatory requirements. The date of the most recent revision is always displayed at the top of this page.

14.2. Where material changes are made to this Policy, pelbet will notify registered Members via their registered mobile number or email address, or via a prominent notice on the Platform, before the revised Policy takes effect.

14.3. Continued use of the pelbet Platform following the effective date of a revised Privacy Policy constitutes your acknowledgement of the changes. If you do not accept a revised Policy, you must cease use of the Platform and may request Account closure.

15. Contact & Data Privacy Officer

15.1. If you have any questions, concerns, or requests relating to this Privacy Policy or pelbet's personal data practices, please contact the pelbet Data Privacy Officer:

15.2. You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with pelbet's response to your data privacy concern. The NPC accepts complaints through its official channels.

15.3. pelbet is committed to working cooperatively with the NPC and with affected data subjects to resolve any data privacy concerns promptly and in accordance with applicable law.