properbet Privacy Policy

1. Introduction

properbet ("we," "us," or "our") operates the online gaming and sports betting platform accessible at properbet.org (the "Platform"). We are committed to protecting the privacy and personal data of all players, visitors, and users ("you") who interact with the properbet Platform.

This Privacy Policy describes how properbet collects, uses, stores, shares, and protects your personal data. It also explains the rights available to you under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC) of the Philippines.

By registering for a properbet account or using the Platform in any way, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree, please discontinue use of the Platform immediately.

2. Data Controller

For the purposes of the Philippine Data Privacy Act, properbet is the Personal Information Controller (PIC) responsible for your personal data collected through the Platform. Our designated Data Protection Officer (DPO) can be contacted at the details provided in Section 15 of this Policy.

properbet operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Our data processing activities are conducted in accordance with PAGCOR's data governance requirements as well as the NPC's guidelines.

3. Personal Data We Collect

properbet collects the following categories of personal data:

• Identity Data: Full legal name, date of birth, nationality, and government-issued ID details (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's license, or UMID).
• Contact Data: Residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, or Makati), email address, and Philippine mobile number.
• Account Data: Username, encrypted password, account preferences, and communication settings.
• Financial Data: Payment method details (GCash number, PayMaya account, BPI/BDO/Metrobank account details), transaction history, deposit and withdrawal records, and balance information. Full payment credentials are never stored directly by properbet — they are handled by our PCI-DSS compliant payment processors.
• Gaming Data: Betting history, game preferences, session duration, wagering patterns, and bonus usage records.
• Technical Data: IP address, device type, browser type and version, operating system, time zone, and cookies or similar tracking data.
• KYC Verification Data: Copies of government-issued identification documents and proof of address submitted during the Know Your Customer (KYC) verification process.
• Communications Data: Records of your interactions with properbet's customer support team, including chat logs and email correspondence.

4. How We Collect Your Data

properbet collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical data collected automatically when you access the Platform, including through cookies, server logs, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank.
• Regulatory sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with licensing, compliance, or investigation requirements.

5. How We Use Your Personal Data

properbet uses your personal data for the following purposes:

• To create, verify, and manage your properbet account.
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (₱).
• To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine law.
• To comply with anti-money laundering (AML) obligations under the Philippine AMLA and AMLC regulations.
• To detect, investigate, and prevent fraud, cheating, collusion, and other prohibited activities on the Platform.
• To provide customer support and respond to your inquiries.
• To send you transactional communications (e.g., deposit confirmations, withdrawal notifications, account alerts).
• To send you promotional communications about properbet offers and new games, where you have consented to receive such communications.
• To personalize your gaming experience and recommend games or promotions relevant to your preferences.
• To analyze Platform usage and improve our services, user interface, and game offerings.
• To enforce our Terms & Conditions and other Platform policies.
• To comply with all applicable Philippine laws and regulatory requirements.

6. Legal Basis for Processing

properbet processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your properbet account and provide the Platform's services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for properbet's legitimate business interests, including fraud prevention, Platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — for example, for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

properbet does not sell your personal data. We may share your data only with the following categories of recipients, and only to the extent necessary:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay partners, solely to process your financial transactions.
• KYC and identity verification providers: Third-party services that assist properbet in verifying your identity and age in compliance with PAGCOR requirements.
• Fraud prevention and security partners: Service providers that help properbet detect and prevent fraudulent activity, money laundering, and other prohibited conduct.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law or regulatory directive.
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers operating under strict data processing agreements that prohibit independent use of your data.
• Professional advisers: Lawyers, auditors, and accountants where necessary for properbet's legal and compliance obligations, subject to professional confidentiality obligations.

All third parties with whom properbet shares personal data are required to handle that data in accordance with the Philippine Data Privacy Act and properbet's data protection standards.

8. Data Retention

properbet retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law and regulatory obligations. Specifically:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• KYC verification documents are retained for the same five-year minimum period.
• Customer support communications are retained for two (2) years following the resolution of the relevant inquiry.
• Marketing consent records are retained for the duration of your consent and for a reasonable period thereafter as evidence of that consent.

Upon expiry of the applicable retention period, properbet will securely delete or anonymize your personal data in accordance with NPC guidelines.

9. Data Security

properbet implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• TLS 1.3 encryption for all data in transit between your device and properbet's servers.
• AES-256 encryption for sensitive data stored at rest, including financial records and KYC documents.
• Multi-factor authentication (MFA) for access to internal systems containing personal data.
• Regular penetration testing and security audits conducted by independent third-party security firms.
• Strict role-based access controls limiting employee access to personal data on a need-to-know basis.
• Comprehensive staff training on data protection obligations under the Philippine Data Privacy Act.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, properbet will notify the National Privacy Commission and affected individuals in accordance with NPC Circular No. 16-03 and applicable breach notification requirements.

10. Cookies & Tracking Technologies

properbet uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the Platform. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Performance cookies: Used to collect anonymized data about how players use the Platform, helping us identify and fix issues and improve performance.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalize your experience.

properbet does not use third-party advertising or tracking cookies. You can manage or delete cookies through your browser settings at any time. Note that disabling strictly necessary cookies may affect the functionality of the Platform.

11. Your Rights as a Data Subject

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

• Right to be informed: The right to know that your personal data is being collected and processed, and the purposes for which it is used.
• Right of access: The right to request a copy of the personal data properbet holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: 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 properbet's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please contact properbet's Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days in accordance with NPC guidelines.

12. Children's Privacy

The properbet Platform is strictly intended for individuals aged 21 years and above, as required by PAGCOR regulations and Philippine law governing online gambling. properbet does not knowingly collect personal data from individuals under the age of 21.

If properbet becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended, all associated data will be deleted, and any funds will be returned in accordance with applicable regulations. If you believe a minor has registered on properbet, please contact us immediately at [email protected].

13. Cross-Border Data Transfers

properbet primarily processes and stores personal data within the Philippines. In limited circumstances, personal data may be transferred to service providers operating in other jurisdictions — for example, cloud infrastructure providers or international KYC verification services.

Any cross-border transfer of personal data is conducted only where the recipient country provides an adequate level of data protection, or where appropriate safeguards (such as contractual clauses approved by the NPC) are in place. properbet will not transfer your personal data to jurisdictions that do not meet the NPC's adequacy standards without your explicit consent or a lawful basis under the Data Privacy Act.

14. Changes to This Privacy Policy

properbet reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The date of the most recent revision is displayed at the top of this Policy. Your continued use of the properbet Platform following the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or properbet's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Role: Data Protection Officer, properbet
• Response time: Within 15 business days of receiving a verified request
• Support hours: 24 hours a day, 7 days a week
• Languages: English and Filipino

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data protection rights have not been adequately addressed by properbet.