PRIVACY POLICY
I. Introduction
This Privacy Policy explains how Trojans Well Entertainment Corporation (TWEC), the operator of Bet88 and a duly licensed Gaming System Administrator under the Philippine Amusement and Gaming Corporation (PAGCOR), collects, processes, uses, stores, and protects personal data.
TWEC acts as the Personal Information Controller for personal data processed through the Bet88 platform and related services. This Privacy Policy is adopted in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission, as well as relevant regulatory requirements including those of PAGCOR and other applicable Philippine laws.
By accessing or using the platform, users acknowledge that they have read and understood this Privacy Policy and consent to the processing of their personal data in accordance with its terms.
II. Process of Personal Data of Minors
The Bet88 platform is intended only for individuals who meet the minimum age requirement prescribed by applicable laws and regulations governing gaming activities. TWEC does not knowingly collect or process personal data from individuals below the legally permitted age.
If TWEC becomes aware that personal data belonging to a minor has been collected without the consent of a parent or legal guardian, such information will be promptly deleted or blocked from further processing in accordance with the Data Privacy Act of 2012 and its Implementing Rules and Regulations.
III. Sources and Collection of Personal Data
TWEC collects personal data through various means in connection with the operation of the platform and compliance with regulatory requirements.
Personal data may be collected through:
(1) Direct user submission, including account registration, identity verification procedures, transactions, and communications with customer support;
(2) Automated collection through the platform, including system logs, cookies, and monitoring tools used to maintain platform functionality and security;
(3) Service providers and partners, including payment processors, identity verification providers, and technical service providers assisting TWEC in operating the platform; and
(4) Third-party sources, including referral partners or publicly available information where permitted by law and necessary for regulatory compliance or fraud prevention.
IV. Personal Data We Collect
TWEC may collect and process the following categories of personal data.
Identity and Registration Information may include full name, date and place of birth, nationality, residential address, email address, mobile number, government-issued identification details, and selfie or liveness verification images used for identity verification. Government-issued identifiers and biometric verification images may constitute Sensitive Personal Information under the Data Privacy Act.
Financial and Transaction Information may include bank account details, e-wallet account details, deposit and withdrawal records, and transaction history. Certain financial data may also qualify as Sensitive Personal Information where applicable.
Gaming Activity Information may include wagers placed, wins and losses, gaming history, and platform usage records.
Technical and System Information may include IP address, device type, browser information, operating system, login records, and platform usage data automatically collected when users access the platform.
Communication Data may include customer support chat transcripts, email correspondence, complaint records, and call recordings.
V. Purposes of Processing
TWEC processes personal data only for legitimate and specified purposes necessary for operating the platform and complying with legal obligations. These purposes include:
(1) account registration and identity verification procedures;
(2) compliance with regulatory requirements, including PAGCOR regulations and anti-money laundering laws;
(3) processing deposits, withdrawals, and financial transactions;
(4) maintaining platform functionality and system security;
(5) providing customer support and resolving disputes;
(6) fraud detection, risk monitoring, and security reviews; and
(7) marketing communications where permitted by law and subject to user consent where required.
VI. Legal Basis for Processing
TWEC processes personal data based on lawful grounds recognized under the Data Privacy Act. These include consent of the data subject, processing necessary for the performance of a contract, compliance with legal obligations, protection of lawful rights and interests, and legitimate interests such as fraud prevention, platform security, and system integrity.
Sensitive Personal Information is processed only where permitted by law, including where consent is obtained, where processing is required by regulation, or where necessary to establish, exercise, or defend legal claims.
VII. Data Sharing and Disclosure
TWEC may disclose personal data where necessary for legitimate operational, regulatory, or legal purposes.
Recipients of personal data may include:
(1) regulatory authorities such as PAGCOR, the Anti-Money Laundering Council (AMLC), and the Bureau of Internal Revenue (BIR);
(2) financial institutions and payment service providers for the processing of deposits and withdrawals;
(3) technical service providers, including IT support and cloud infrastructure providers; and
(4) professional advisers, including auditors, legal advisers, and compliance consultants.
These entities may act as Personal Information Processors and may process personal data only in accordance with TWEC’s instructions and contractual safeguards consistent with the Data Privacy Act.
VIII. Security Reviews and Platform Monitoring
TWEC may conduct security reviews and verification procedures in order to maintain platform integrity and comply with regulatory obligations. These may include verification of identity information, validation of financial transactions, and monitoring of platform activity to detect fraud or unauthorized use.
Monitoring tools may also be used to detect automated gaming software or other activities that may compromise the fairness or security of the gaming environment.
IX. Data Retention
Personal data will be retained only for as long as necessary to fulfill the purposes for which it was collected.
Retention periods may depend on the duration of the user’s account, regulatory requirements applicable to gaming and financial transactions, and the need to establish or defend legal claims. Certain records may be retained for a minimum period of five (5) years or longer where required by law or regulation.
When personal data is no longer required, it will be securely deleted, anonymized, or disposed of in a manner that prevents unauthorized access or further processing.
X. Security Measures
TWEC implements appropriate organizational, physical, and technical safeguards to protect personal data.
Organizational safeguards include internal privacy policies, confidentiality obligations for employees, training programs on data protection, and the designation of a Data Protection Officer.
Physical safeguards include access restrictions to facilities and systems where personal data is processed.
Technical safeguards include encryption, secure servers, authentication systems, access controls, and monitoring systems designed to detect and respond to security incidents.
XI. Personal Data Breach Notification
In the event of a personal data breach that may pose a risk to individuals, TWEC will notify the National Privacy Commission and affected data subjects within seventy-two (72) hours of becoming aware of the breach, in accordance with applicable regulations.
XII. Data Subject Rights
Under the Data Privacy Act, data subjects have the right to be informed, to access their personal data, to correct inaccurate information, to object to processing, to withdraw consent, to request the erasure or blocking of personal data, to obtain a portable copy of their data where applicable, and to lodge a complaint with the National Privacy Commission.
Requests to exercise these rights may be submitted through the contact details provided below, and TWEC may require identity verification before processing such requests.
XIII. Corporate Transactions
In the event of a merger, acquisition, restructuring, sale of assets, or other corporate transaction involving TWEC, personal data may be transferred to the relevant successor entity, subject to appropriate safeguards and compliance with applicable data protection laws.
XIV. Contact Information
For inquiries regarding this Privacy Policy or the processing of personal data, users may contact the Data Protection Officer of Trojans Well Entertainment Corporation through the designated contact channels.
