efabet Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how efabet ("we," "us," or "our") collects, uses, stores, shares, and protects the personal data of individuals ("you" or "your") who access or use the efabet online gaming platform available at efabet.net and any associated mobile applications (collectively, the "Platform").

efabet is committed to handling your personal data with the highest standards of privacy and security. We comply with the requirements of Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines.

By registering an account on the efabet Platform or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

This Policy should be read together with efabet's Terms & Conditions, which govern your use of the Platform and are incorporated herein by reference.

2. Personal Data We Collect

efabet collects personal data from you in the following categories, depending on how you interact with the Platform:

2.1 Registration and Account Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Email address
• Mobile phone number
• Username and encrypted password
• Residential address
• Nationality

2.2 Identity Verification (KYC) Data

• Government-issued identification documents (e.g., Philippine passport, driver's license, SSS ID, PhilSys ID, UMID, Voter's ID)
• Proof of address documents
• Selfie or facial image for identity matching purposes
• Source of funds documentation where required by anti-money laundering regulations

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash account reference, bank account details for BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, or debit card details)
• Transaction amounts and timestamps
• Bonus and promotion redemption history

2.4 Gaming Activity Data

• Game session records, including games played, wagers placed, and outcomes
• Betting history and account balance history
• Responsible gaming tool usage (deposit limits, session limits, self-exclusion records)

2.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session logs and access timestamps
• Cookie identifiers and similar tracking data (see Section 5)

2.6 Communications Data

• Records of your communications with efabet customer support, including live chat transcripts and email correspondence
• Feedback and survey responses you voluntarily provide

3. How We Use Your Personal Data

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

4. Legal Basis for Processing

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

• Contractual necessity: Processing is necessary to perform our contract with you — that is, to provide you with access to the efabet Platform and its gaming services, including account management, deposits, withdrawals, and game play.
• Legal obligation: Processing is necessary for efabet to comply with its legal obligations under Philippine law, including anti-money laundering regulations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate interests: Processing is necessary for efabet's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and improving our services, provided that these interests are not overridden by your rights and interests.
• Consent: For certain processing activities, such as sending you marketing communications or using non-essential cookies, we rely on your consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Cookies and Tracking Technologies

efabet uses cookies and similar tracking technologies on the Platform to enhance your experience and to collect technical data as described in Section 2.5. The types of cookies we use include:

• Strictly necessary cookies: These cookies are essential for the Platform to function and cannot be disabled. They include session cookies that keep you logged in and security cookies that protect against cross-site request forgery.
• Performance and analytics cookies: These cookies help us understand how players use the Platform, which pages are most visited, and where errors occur. This information is used in aggregate form to improve Platform performance.
• Functional cookies: These cookies remember your preferences, such as your preferred language and display settings, to provide a more personalized experience.
• Marketing cookies: With your consent, these cookies are used to deliver relevant promotional content and to measure the effectiveness of our marketing campaigns.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate.

6. Sharing Your Personal Data

efabet does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only where necessary and in accordance with applicable law:

• Identity verification and KYC service providers: Third-party providers who assist us in verifying your identity and age as required by our regulatory obligations.
• Payment processors: Financial institutions and payment service providers (including GCash, Maya, and partner banks) that process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• Gaming platform and software providers: Technology partners who provide the gaming software and infrastructure that powers the efabet Platform. These partners process data only as necessary to deliver gaming services.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other government authorities where disclosure is required by law or in response to a lawful request.
• Professional advisers: Lawyers, auditors, and other professional advisers who are bound by confidentiality obligations.
• Fraud prevention and security services: Third-party providers who assist in detecting and preventing fraud, cheating, and other prohibited conduct on the Platform.

All third parties with whom efabet shares personal data are required to handle that data in accordance with applicable privacy laws and are permitted to use it only for the specific purposes for which it was shared.

7. International Data Transfers

Some of efabet's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that afforded by Philippine law, efabet will implement appropriate safeguards to protect your data, such as contractual clauses that require the recipient to protect your data to the same standard required under the Data Privacy Act of 2012.

By using the efabet Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines in accordance with this Policy.

8. Data Retention

efabet retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering regulations.
• Transaction and financial data: Retained for a minimum of five (5) years following the date of the transaction, in accordance with applicable financial regulations.
• Gaming activity data: Retained for the duration of your account and for a minimum of three (3) years following account closure.
• Communications data: Retained for a minimum of two (2) years following the date of the communication.
• Technical and device data: Retained for up to twelve (12) months from the date of collection, unless required for longer periods for security or fraud investigation purposes.
• Marketing consent records: Retained for the duration of your consent and for a reasonable period thereafter as evidence of consent.

When personal data is no longer required, it will be securely deleted, destroyed, or anonymized in accordance with efabet's data disposal procedures.

9. Your Privacy Rights

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

• Right to be informed: You have the right to be informed about how your personal data is being collected and processed, which is the purpose of this Privacy Policy.
• Right to access: You may request a copy of the personal data efabet holds about you. We will respond to verified access requests within a reasonable timeframe.
• Right to rectification: You may request the correction of inaccurate or incomplete personal data. Basic account details can be updated directly through your account settings.
• Right to erasure or blocking: You may request the deletion or blocking 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 object: You may object to the processing of your personal data for direct marketing purposes at any time. You can opt out of marketing communications through your account preferences or by contacting customer support.
• Right to data portability: You may request a copy of your personal data in a structured, machine-readable format where technically feasible.
• Right to lodge a complaint: If you believe your privacy rights have been violated, you may lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, please contact efabet's Data Protection Officer using the contact details provided in Section 13. We may need to verify your identity before processing your request.

10. Children's Privacy and Age Restriction

The efabet Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. efabet does not knowingly collect personal data from persons under the age of 21.

If efabet becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended and the personal data will be deleted in accordance with our data disposal procedures. Any funds held in such an account will be handled in accordance with applicable regulations.

If you are a parent or guardian and believe that a minor has registered an account on the efabet Platform, please contact us immediately using the details in Section 13.

11. Third-Party Links and Services

The efabet Platform may contain references to third-party payment services (such as GCash and Maya) that are necessary for processing your transactions. These third-party services operate under their own privacy policies, and efabet is not responsible for the privacy practices of those services.

We encourage you to review the privacy policies of any third-party services you use in connection with your efabet account, particularly your chosen payment provider, to understand how they handle your personal data.

12. Updates to This Privacy Policy

efabet reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. When material changes are made, we will notify registered players via the email address associated with their account and/or by posting a prominent notice on the Platform.

The date of the most recent revision is displayed at the top of this page. Your continued use of the efabet Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy. If you do not agree with the changes, you must cease using the Platform and may request account closure.

We recommend that you review this Privacy Policy periodically to stay informed of how efabet is protecting your personal data.

13. Contact and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, you may contact efabet's Data Protection Officer (DPO) through the following channel:

• Email: [email protected] (plain text — not a clickable link)
• General Support Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 through the efabet Platform

efabet's Data Protection Officer is responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. All privacy-related inquiries will be handled with strict confidentiality and responded to within a reasonable timeframe.

If you are not satisfied with efabet's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.