smbet Privacy Policy

1. Introduction

smbet ("smbet", "we", "us", "our") is committed to protecting the privacy and personal data of all individuals who access or use the smbet Platform at smbet.xyz ("Platform"). This Privacy Policy ("Policy") describes how smbet collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform.

This Policy applies to all smbet members, registered users, and visitors to the Platform. It should be read together with smbet's Terms & Conditions and Responsible Gaming Policy, both of which are available on the Platform.

By registering an smbet account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

2. Data Controller

smbet is the data controller responsible for your personal data collected through the Platform. As data controller, smbet determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its implementing rules and regulations.

smbet has designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data privacy laws. You may contact the DPO at the address provided in Section 15 of this Policy.

3. Information We Collect

smbet collects the following categories of personal information:

• Identity Data: Full legal name, date of birth, gender, nationality, and copies of government-issued identification documents (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's licence, UMID).
• Contact Data: Email address, Philippine mobile number, and residential address (including city, province, and postal code).
• Financial Data: GCash account details, Maya / PayMaya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), debit card details, transaction history, deposit and withdrawal records.
• Account Data: Username, encrypted password, account preferences, bonus history, wagering history, and responsible gaming settings.
• Technical Data: IP address, device type, browser type and version, operating system, time zone, and session data collected automatically when you access the Platform.
• Usage Data: Information about how you use the Platform, including pages visited, games played, bet amounts, session duration, and click-stream data.
• Communications Data: Records of your communications with smbet support, including live chat transcripts, emails, and any feedback or complaints submitted.

smbet does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

4. How We Collect Your Data

smbet collects your personal data through the following means:

• Direct interactions: Information you provide when registering an smbet account, completing KYC verification, making deposits or withdrawals, contacting smbet support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access the Platform.
• Third-party sources: Identity verification and fraud prevention data from third-party KYC and anti-money laundering service providers; payment processing data from payment gateway providers; and publicly available information where relevant to regulatory compliance.

5. How We Use Your Data

smbet uses your personal data for the following purposes:

• To register and maintain your smbet account and verify your identity and eligibility.
• To process deposits, withdrawals, and other financial transactions on the Platform.
• To comply with applicable Philippine anti-money laundering (AML), counter-terrorism financing (CTF), and know-your-customer (KYC) obligations.
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited conduct on the Platform.
• To provide customer support and respond to your enquiries and complaints.
• To administer bonuses, promotions, and loyalty programmes for which you are eligible.
• To send you service-related communications, including account notifications, security alerts, and policy updates.
• To send you marketing communications about smbet products and promotions, where you have opted in to receive such communications.
• To improve the Platform, personalise your experience, and conduct analytics and research.
• To enforce smbet's Terms & Conditions and other policies.
• To comply with applicable laws, regulations, and orders from competent Philippine authorities.

6. Legal Basis for Processing

smbet processes your personal data on the following legal bases under the DPA:

• Contractual necessity: Processing required to perform the contract between you and smbet (i.e., the Terms & Conditions), including account registration, transaction processing, and customer support.
• Legal obligation: Processing required to comply with smbet's obligations under Philippine law, including AML/CTF regulations, KYC requirements, and orders from regulatory authorities such as PAGCOR and the Anti-Money Laundering Council (AMLC).
• Legitimate interests: Processing for smbet's legitimate business interests, including fraud prevention, Platform security, analytics, and improving the Platform, where such interests are not overridden by your data privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Sharing Your Data

smbet does not sell, rent, or trade your personal data to third parties for their own commercial purposes. smbet may share your personal data with the following categories of recipients:

• Service providers: Third-party vendors who provide services to smbet, including KYC and identity verification providers, payment processing partners, cloud hosting providers, customer support platforms, and analytics providers. All service providers are bound by contractual confidentiality and data protection obligations.
• Regulatory and law enforcement authorities: Philippine government agencies, regulatory bodies (including PAGCOR and the AMLC), and law enforcement authorities where smbet is required or permitted to disclose your data by applicable law, court order, or regulatory direction.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of smbet's assets, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by smbet, subject to professional confidentiality obligations.

8. International Transfers

smbet primarily stores and processes your personal data within the Philippines. Where smbet engages service providers located outside the Philippines, smbet ensures that appropriate safeguards are in place to protect your personal data in accordance with the DPA, including contractual data protection clauses and, where applicable, adequacy determinations by the National Privacy Commission.

By using the smbet Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

9. Data Retention

smbet retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically, smbet applies the following retention periods:

• Account and transaction records: Retained for a minimum of five (5) years from the date of the last transaction or account closure, in accordance with Philippine AML/CTF regulations and PAGCOR requirements.
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, as required by the Anti-Money Laundering Act and its implementing rules.
• Customer support communications: Retained for a period of three (3) years from the date of the communication, unless a longer period is required for the resolution of a dispute or legal claim.
• Marketing consent records: Retained for the duration of your smbet membership and for a period of two (2) years following account closure or withdrawal of consent, whichever is later.
• Technical and usage data: Retained for a period of twelve (12) months from the date of collection, unless a longer period is required for fraud investigation or legal proceedings.

Upon expiry of the applicable retention period, smbet will securely delete or anonymise your personal data in accordance with its data disposal procedures.

10. Cookies & Tracking Technologies

smbet uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain your session, remember your preferences, and collect analytics data. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management and security features. These cookies cannot be disabled without affecting Platform functionality.
• Functional cookies: Used to remember your preferences and settings, such as language selection and display preferences, to provide a more personalised experience.
• Analytics cookies: Used to collect aggregated, anonymised information about how visitors use the Platform, including pages visited, time spent, and navigation paths. This data helps smbet improve the Platform's performance and content.
• Marketing cookies: Used to deliver relevant promotional content to you on the Platform, based on your activity and preferences. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the smbet Platform. For detailed information on the specific cookies used by smbet, please contact smbet support.

11. Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by smbet:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of access: The right to request a copy of the personal data smbet holds about you, together with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data smbet holds about you.
• 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 smbet's legal and regulatory retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on smbet's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe smbet has processed your personal data in violation of the DPA.

To exercise any of the above rights, please contact smbet's Data Protection Officer using the contact details provided in Section 15. smbet will respond to your request within the timeframe prescribed by the DPA. smbet may require you to verify your identity before processing your request.

12. Security

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

• SSL/TLS encryption for all data transmitted between your device and the smbet Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Strict access controls limiting access to personal data to authorised smbet personnel on a need-to-know basis.
• Regular security assessments, vulnerability testing, and penetration testing of the Platform.
• Staff training on data privacy and security obligations.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While smbet takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. smbet cannot guarantee the absolute security of your data and encourages you to use strong, unique passwords for your smbet account and to enable any available two-factor authentication features.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, smbet will notify you and the National Privacy Commission in accordance with the requirements of the DPA.

13. Children's Privacy

The smbet Platform is strictly intended for individuals who are 21 years of age or older, in accordance with the minimum legal age for casino-style gambling in the Philippines. smbet does not knowingly collect personal data from individuals under the age of 21.

If smbet becomes aware that personal data has been collected from a person under 21 years of age, smbet will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered an smbet account or provided personal data to smbet, please contact smbet support immediately.

14. Changes to This Policy

smbet reserves the right to update or amend this Privacy Policy at any time to reflect changes in smbet's data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, smbet will post the updated Policy on the Platform with a revised "Last Updated" date and, where appropriate, notify registered members via email or in-platform notification.

Your continued use of the smbet Platform after any changes to this Policy have been posted constitutes your acknowledgment of the updated Policy. smbet recommends that you review this Policy periodically to stay informed about how smbet protects your personal data.

15. Contact & Complaints

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

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the smbet Platform
• Response Time: smbet aims to respond to all data privacy requests within fifteen (15) business days, as required by the DPA.

If you are not satisfied with smbet's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.