holobet Privacy Policy

This Privacy Policy ("Policy") describes how holobet ("holobet," "we," "us," or "our"), the operator of the online gaming platform at holobet.club, collects, uses, discloses, and safeguards the personal information of users ("Player," "User," or "you") who access or use the holobet platform.

holobet is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC) of the Philippines.

By registering a holobet account or using any part of the holobet 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. This Policy should be read together with holobet's Terms & Conditions and Responsible Gaming Policy.

If you have any questions about this Policy or holobet's data practices, please contact our Data Protection Officer at the details provided in Section 13 of this Policy.

holobet collects personal information that is necessary to provide our gaming services, comply with legal obligations, and maintain the security and integrity of our platform. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name, date of birth, and gender
• Residential address (including city, province, and postal code)
• Email address and mobile phone number
• Username and encrypted password
• Government-issued identification documents (for KYC verification purposes, e.g., Philippine passport, driver's licence, SSS/GSIS ID, PhilSys National ID)

2.2 Financial & Transaction Data

• GCash or PayMaya account details (mobile number associated with the e-wallet)
• Philippine bank account details (bank name, account number) for bank transfer transactions
• Debit card details (card number masked, expiry date)
• Transaction history including deposits, withdrawals, and gaming activity

2.3 Technical & Usage Data

• IP address, device type, operating system, and browser type
• Pages visited, features used, and time spent on the holobet platform
• Login timestamps and session duration data
• Cookies and similar tracking technology data (see Section 7)

2.4 Communications Data

• Records of communications between you and holobet's customer support team
• Feedback, survey responses, and promotional opt-in preferences

holobet uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your holobet account, including verifying your identity and age in compliance with PAGCOR requirements.
• Service Delivery: To provide access to holobet's gaming platform, process deposits and withdrawals, and deliver the services you have requested.
• Legal Compliance: To comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, money laundering, and other illegal activities on the holobet platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features and performance of the holobet platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications.
• Responsible Gaming: To monitor gaming behavior and implement responsible gaming tools, including deposit limits, session timers, and self-exclusion, in accordance with holobet's Responsible Gaming Policy.

holobet processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing is necessary to perform the contract between you and holobet (i.e., the Terms & Conditions), including providing gaming services and processing financial transactions.
• Legal Obligation: Processing is required to comply with holobet's legal obligations under Philippine law, including PAGCOR regulations, AMLA requirements, and NPC directives.
• Legitimate Interests: Processing is necessary for holobet's legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided such interests are not overridden by your privacy rights.
• Consent: For marketing communications and non-essential cookies, holobet relies on your freely given, specific, and informed consent, which you may withdraw at any time.

holobet does not sell, rent, or trade your personal data to third parties for their own commercial purposes. holobet may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, and Philippine banking partners, to process deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to assist with regulatory compliance.
• Technology Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on holobet's behalf under strict data processing agreements.
• Game Content Providers: Licensed game studios and live dealer operators whose games are available on the holobet platform, to the extent necessary to deliver gaming services.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities, where disclosure is required by law or regulatory mandate.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a valid legal order, warrant, or subpoena.

All third-party service providers engaged by holobet are contractually required to process personal data only for the specified purpose, maintain appropriate security measures, and comply with the Philippine Data Privacy Act.

holobet retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. Specifically:

• Account and identity data is retained for the duration of your holobet account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AMLA obligations.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by Philippine anti-money laundering regulations.
• Customer support communications are retained for three (3) years from the date of the last interaction.
• Marketing preference data is retained until you withdraw consent or request deletion.

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

holobet uses cookies and similar tracking technologies (including web beacons and local storage) to enhance your experience on the platform. The categories of cookies used by holobet are:

• Essential Cookies: Strictly necessary for the operation of the holobet platform, including session management, authentication, and security functions. These cannot be disabled.
• Functional Cookies: Used to remember your preferences and settings, such as language preferences and display options.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the holobet platform, enabling us to improve performance and user experience.
• Marketing Cookies: Used to deliver relevant promotional content to players who have opted in to marketing communications. These are only set 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 holobet platform. For more information on managing cookies in your browser, refer to your browser's help documentation.

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

• Right to Be Informed: The right to be informed of how your personal data is collected, used, and processed by holobet.
• Right of Access: The right to request a copy of the personal data holobet 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, subject to holobet's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe holobet has violated your data privacy rights.

To exercise any of the above rights, please contact holobet's Data Protection Officer using the contact details provided in Section 13. holobet will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. holobet may request proof of identity before processing any data subject request to protect against unauthorized access to personal data.

holobet implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the holobet platform.
• Encryption of sensitive data at rest, including financial information and government-issued identification documents.
• Role-based access controls ensuring that holobet personnel can only access personal data necessary for their specific job functions.
• Regular security audits, vulnerability assessments, and penetration testing conducted by independent cybersecurity specialists.
• Multi-factor authentication requirements for access to holobet's internal systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, holobet will notify the National Privacy Commission and affected players within seventy-two (72) hours of becoming aware of the breach, as required by the Data Privacy Act and NPC Circular No. 16-03.

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

The holobet platform is strictly intended for adults aged 21 years and above, in compliance with Philippine gambling regulations administered by PAGCOR. holobet does not knowingly collect personal data from individuals under the age of 21.

If holobet becomes aware that personal data has been collected from a person under 21 years of age, it will immediately close the associated account, delete the personal data concerned, and report the incident to PAGCOR as required. If you believe that holobet may have inadvertently collected personal data from an underage individual, please contact our Data Protection Officer immediately using the details in Section 13.

Parents and guardians are encouraged to use parental control tools to prevent minors from accessing online gambling platforms. holobet supports the responsible use of such tools and cooperates with PAGCOR's underage gambling prevention initiatives.

holobet primarily stores and processes personal data within the Republic of the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or game content suppliers operating internationally.

Where such international transfers occur, holobet ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that impose data protection obligations equivalent to those required under the Philippine Data Privacy Act. holobet will not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining NPC approval.

holobet reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. Where changes are material, holobet will provide reasonable advance notice to registered players via email or a prominent notice on the holobet platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the holobet platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. If you do not agree with any changes, you should cease using the holobet platform and may request account closure in accordance with the Terms & Conditions.

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

If you have any questions, concerns, or requests regarding this Privacy Policy or holobet's data practices, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated: