holobet Privacy Policy

1 Introduction

This Privacy Policy ("Policy") applies to all personal data collected by holobet ("holobet," "we," "us," or "our") through the holobet website, mobile applications, and all associated services (collectively, the "Platform"). By accessing or using the holobet Platform, you ("User," "you," or "your") acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Policy.

This Policy should be read in conjunction with our Terms & Conditions, which govern your use of the holobet Platform. If you do not agree with any provision of this Policy, you must immediately cease using the Platform and may request the deletion of your account and personal data, subject to our legal retention obligations.

holobet respects your privacy and is committed to transparency in our data handling practices. We collect only the personal information necessary to provide you with a secure, compliant, and enjoyable gaming experience, and we implement robust technical and organizational measures to protect your data from unauthorized access, loss, or misuse.

2 Data Controller

holobet is the data controller responsible for the processing of your personal data collected through the Platform. As the data controller, holobet determines the purposes and means of processing your personal information and is responsible for ensuring compliance with applicable data protection laws, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

If you have any questions, concerns, or requests regarding the processing of your personal data, you may contact our Data Protection Officer using the contact details provided in Section 14 of this Policy.

3 Information We Collect

holobet collects various categories of personal information to provide, maintain, and improve the Platform and to comply with applicable legal and regulatory obligations. The types of personal data we collect include:

3.1 Information You Provide Directly

• Account Registration Data: Full legal name, date of birth, gender, residential address, email address, mobile phone number, username, and password.
• Identity Verification Data (KYC): Government-issued identification documents (e.g., Philippine passport, SSS ID, UMID, driver's license, PhilSys National ID), proof of address (e.g., utility bills, bank statements, barangay certificates), and selfie photographs for identity verification purposes.
• Payment Information: Payment method details (e.g., GCash account, PayMaya account, bank account information), transaction history, deposit and withdrawal records, and source of funds declarations where required by anti-money laundering regulations.
• Communications: Any information you provide when you contact our customer support team via live chat, email, or phone, including the content of your messages, support tickets, and feedback.
• Marketing Preferences: Your consent to receive promotional communications, newsletters, and marketing materials from holobet.

3.2 Information Collected Automatically

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (e.g., IMEI, MAC address), and mobile network information.
• Usage Data: Pages visited, games played, bet history, win/loss records, session duration, clickstream data, referral sources, and interaction with Platform features.
• Location Data: IP address, geolocation data (where permitted by your device settings), and time zone information to verify your location and ensure compliance with geographic restrictions on online gambling.
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, pixels, and similar tracking technologies to enhance your user experience, analyze Platform performance, and deliver personalized content. For more information, see Section 10 of this Policy.

3.3 Information from Third Parties

• Payment Processors: Transaction confirmation data, payment status, and fraud detection information from GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers.
• Identity Verification Services: Verification results and risk assessment data from third-party KYC and AML service providers.
• Affiliate Partners: Referral information and marketing attribution data from affiliate partners who refer users to the holobet Platform.

4 How We Use Your Data

holobet uses the personal information we collect for the following purposes:

4.1 Account Management & Service Delivery

• Creating, maintaining, and managing your holobet account.
• Processing deposits, withdrawals, and other financial transactions.
• Providing access to games, promotions, and Platform features.
• Communicating with you about your account, transactions, and support requests.
• Sending service-related notifications, including security alerts and policy updates.

4.2 Legal & Regulatory Compliance

• Verifying your identity and age (21+) in compliance with applicable gaming regulations.
• Conducting anti-money laundering (AML) and counter-terrorism financing (CTF) checks.
• Complying with PAGCOR regulations and other applicable Philippine laws.
• Maintaining records as required by law and responding to lawful requests from regulatory authorities and law enforcement agencies.
• Detecting, investigating, and preventing fraud, cheating, and other prohibited activities.

4.3 Platform Improvement & Analytics

• Analyzing usage patterns to improve Platform performance, features, and user experience.
• Conducting internal research and development to enhance our gaming products and services.
• Monitoring and resolving technical issues, bugs, and security vulnerabilities.

4.4 Marketing & Personalization

• Sending promotional offers, bonuses, and marketing communications where you have provided consent.
• Personalizing your gaming experience based on your preferences and activity history.
• Delivering targeted advertisements on the Platform and through third-party channels, subject to your consent and applicable law.

4.5 Responsible Gaming

• Monitoring gaming activity to identify signs of problem gambling and to enforce responsible gaming tools such as deposit limits, session limits, and self-exclusion.
• Complying with self-exclusion requests and maintaining exclusion records to prevent re-registration.

5 Legal Basis for Processing

holobet processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012 and applicable data protection principles:

• Contractual Necessity: Processing is necessary to perform our contract with you, including providing access to the Platform, processing transactions, and managing your account.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including KYC/AML obligations, gaming licensing requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security, Platform improvement, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent: Where required by law, we will obtain your explicit consent before processing your personal data for specific purposes, such as sending marketing communications or processing sensitive personal information. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

holobet does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

6.1 Service Providers

We engage trusted third-party service providers to assist in operating the Platform and delivering our services. These include payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC and identity verification providers, cloud hosting and infrastructure providers, customer support platforms, analytics providers, and fraud detection services. All service providers are contractually bound to process your data only on our instructions and to maintain appropriate security standards.

6.2 Regulatory & Law Enforcement Authorities

holobet may disclose your personal data to PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), law enforcement agencies, courts, and other government authorities where required by applicable law, regulation, legal process, or lawful governmental request.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of holobet's business or assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and any material changes to this Policy that may result.

6.4 With Your Consent

We may share your personal data with other third parties where you have provided your explicit consent to such sharing.

7 Data Retention

holobet retains your personal data for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our agreements. Specific retention periods include:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR regulations and AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 (Republic Act No. 9160, as amended).
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by applicable law.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing Data: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.
• Self-Exclusion Records: Retained indefinitely to prevent re-registration by self-excluded users, even after account closure.

Upon expiry of the applicable retention period, holobet will securely delete or anonymize your personal data in accordance with our data disposal procedures.

8 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012 and applicable data protection regulations, you have the following rights with respect to your personal data held by holobet:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, stored, and shared, as described in this 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 the correction of inaccurate, incomplete, or outdated personal data. You may update most of your account information directly through your holobet account settings.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that we transmit this data to another data controller where technically feasible.
• 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 our legitimate interests.
• 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 prior processing.
• 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.

To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 14. We will respond to your request within thirty (30) days, subject to identity verification and any applicable legal limitations.

9 Security Measures

holobet implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the holobet Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols. Sensitive data at rest, including payment information and identity documents, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized holobet personnel and service providers on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular security training.
• Two-Factor Authentication (2FA): holobet offers 2FA for user accounts to provide an additional layer of security against unauthorized access.
• Regular Security Audits: We conduct regular penetration testing, vulnerability assessments, and security audits to identify and remediate potential security risks.
• Incident Response: holobet maintains a data breach response plan and will notify affected users and the National Privacy Commission (NPC) of any personal data breach in accordance with applicable notification requirements.

While holobet takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorized access to your account.

10 Cookies & Tracking Technologies

holobet uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. The types of cookies we use include:

10.1 Essential Cookies

These cookies are strictly necessary for the Platform to function and cannot be disabled. They include session cookies that maintain your login state, security cookies that protect against cross-site request forgery, and cookies that remember your language and regional preferences.

10.2 Analytics Cookies

These cookies help us understand how users interact with the Platform by collecting aggregated, anonymized data about page visits, session duration, and user journeys. This information is used to improve Platform performance and user experience.

10.3 Functional Cookies

These cookies enable enhanced functionality and personalization, such as remembering your game preferences, display settings, and recently played games.

10.4 Marketing Cookies

With your consent, we may use marketing cookies to deliver personalized promotional content and to measure the effectiveness of our marketing campaigns. You may opt out of marketing cookies at any time through your browser settings or our cookie preference center.

11 International Data Transfers

holobet primarily processes and stores your personal data within the Philippines. However, some of our service providers and technology partners may process your data in other countries. Where personal data is transferred outside the Philippines, holobet ensures that appropriate safeguards are in place to protect your data in accordance with the Philippine Data Privacy Act of 2012 and applicable international data transfer requirements.

Such safeguards may include contractual clauses that require the recipient to protect your personal data to the same standard as required under Philippine law, or transfers to countries that have been recognized as providing an adequate level of data protection. By using the holobet Platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the purposes described in this Policy.

12 Children's Privacy

The holobet Platform is strictly intended for adults aged 21 years and above. holobet does not knowingly collect, process, or store personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account.

13 Changes to This Privacy Policy

holobet reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or Platform features. We will notify you of material changes by posting the updated Policy on the Platform and, where practicable, by sending an email notification to your registered email address. The date of the most recent revision will be indicated at the top of this page.

Your continued use of the holobet Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request the closure of your account and deletion of your personal data, subject to our legal retention obligations.

We encourage you to review this Privacy Policy periodically to stay informed about how holobet protects your personal information.

14 Contact Us

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

You also 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. For more information about your rights and how to file a complaint, please refer to the NPC's official resources.

For responsible gaming concerns, self-exclusion requests, or problem gambling support, please visit our Responsible Gaming page.