Privacy Policy

1. Introduction

phbwt ("we," "us," or "our") operates the online casino and sports betting platform accessible at phbwt.com, serving Filipino players across Luzon, Visayas, and Mindanao. We understand that your personal data is important to you, and we take our responsibility as a data controller seriously.

This Privacy Policy describes the types of personal information phbwt collects from players and visitors, the purposes for which that information is used, the circumstances under which it may be shared with third parties, and the rights available to you under Philippine law — in particular, the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

phbwt is committed to processing your personal data lawfully, fairly, and transparently. If you have any questions about how phbwt handles your data, please contact our Data Protection Officer at the details provided in Section 15 of this Policy.

2. Data Controller

phbwt is the data controller responsible for the personal data collected through the phbwt platform. As data controller, phbwt determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data protection law.

phbwt has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection legislation. You may contact the DPO at [email protected] with the subject line "Data Protection Inquiry."

3. Data We Collect

phbwt collects the following categories of personal data from players and platform visitors:

3.1 Identity Data

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (used to verify the 21+ age requirement)
• Gender (optional, for personalisation purposes)
• Copies of government-issued identification documents submitted during KYC verification (e.g., passport, driver's licence, SSS card, PhilHealth ID, UMID)

3.2 Contact Data

• Email address
• Mobile phone number
• Residential address (province, city/municipality)

3.3 Financial Data

• GCash or PayMaya mobile wallet number
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where provided for withdrawal purposes
• Transaction history, including deposit amounts, withdrawal amounts, and dates

3.4 Gaming Activity Data

• Game session history, including games played, wagers placed, and outcomes
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status)

3.5 Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Session duration and platform navigation data
• Cookie identifiers and similar tracking technologies

3.6 Communications Data

• Records of your communications with phbwt customer support, including live chat transcripts and email correspondence
• Survey responses and feedback submitted through the platform

4. How We Collect Your Data

phbwt collects personal data through the following means:

• Direct collection: Information you provide when registering for a phbwt account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the phbwt platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from payment processors; and, where applicable, information from PAGCOR or other regulatory bodies in connection with compliance obligations.

5. How We Use Your Data

phbwt uses your personal data for the following purposes:

phbwt will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our obligations under the phbwt Terms & Conditions, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, and tax reporting requirements.
• Legitimate interests: Processing necessary for phbwt's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent — for example, sending you promotional communications about phbwt offers and new games. You may withdraw consent at any time by contacting [email protected].

7. Data Sharing and Disclosure

phbwt does not sell your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

7.1 Service Providers

phbwt engages trusted third-party service providers to assist in operating the platform, including KYC and identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), customer support software providers, and cloud hosting providers. These service providers are contractually bound to process your data only on phbwt's instructions and in accordance with applicable data protection law.

7.2 Regulatory and Law Enforcement Authorities

phbwt may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine authorities where required by law, court order, or regulatory directive.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of phbwt's assets, your personal data may be transferred to the acquiring entity. phbwt will notify you of any such transfer and the privacy choices available to you.

7.4 With Your Consent

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

8. Cookies and Tracking Technologies

phbwt uses cookies and similar tracking technologies to operate and improve the platform. The following types of cookies are used:

• Strictly necessary cookies: Required for the platform to function, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and display options, to personalise your phbwt experience.
• Analytics cookies: Collect aggregated, anonymised data about how players use the phbwt platform, helping us identify areas for improvement.
• Performance cookies: Monitor platform load times and technical performance to ensure a smooth gaming experience across devices.

You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the phbwt platform. phbwt does not use cookies to serve third-party advertising.

9. Data Retention

phbwt retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulation. Specifically:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AMLA obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• Customer support communications: Retained for two (2) years from the date of the last communication.
• Technical and analytics data: Retained in anonymised or aggregated form for up to two (2) years for platform improvement purposes.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, phbwt will securely delete or anonymise that data.

10. Data Security

phbwt implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the phbwt platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing of the phbwt platform.
• Secure, access-controlled data centres with physical security measures.
• Staff training on data protection obligations and information security best practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phbwt will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular 16-03.

11. Your Rights

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

• Right to be informed: The right to be told how your personal data is being collected and processed — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data phbwt 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 phbwt's legal retention obligations.
• Right to object: The right to object to the processing of your personal data on grounds of legitimate interest or for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another data controller.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phbwt has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact phbwt's Data Protection Officer at [email protected] with the subject line "Data Rights Request." phbwt will respond to your request within thirty (30) days of receipt.

12. Children and Minors

The phbwt platform is strictly intended for individuals who are twenty-one (21) years of age or older. phbwt does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the KYC process before any withdrawal is processed.

If phbwt becomes aware that personal data has been collected from an individual under the age of 21, that account will be immediately suspended, all balances will be reviewed in accordance with phbwt's Terms & Conditions, and the personal data will be deleted as soon as practicable. If you believe a minor has registered on the phbwt platform, please notify us immediately at [email protected].

13. Third-Party Links

The phbwt platform may contain links to third-party websites or services, including payment provider portals. phbwt is not responsible for the privacy practices of those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to data collected by phbwt through the phbwt.com platform.

14. Changes to This Privacy Policy

phbwt reserves the right to update or amend 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 phbwt platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy will be revised whenever changes are made. Your continued use of the phbwt platform following the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy. If you do not agree to the revised Policy, you must cease using the platform and may request deletion of your account and personal data.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or phbwt's handling of your personal data, please contact our Data Protection Officer:

Email: [email protected]

Please include "Privacy Policy" or "Data Rights Request" in the subject line of your email so we can direct your inquiry to the appropriate team. phbwt aims to respond to all data protection inquiries within thirty (30) days.

If you are not satisfied with phbwt's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.