efabet Privacy Policy

1. Introduction

efabet ("we," "us," "our," or the "Company") is committed to protecting the privacy and personal data of every Filipino player who uses our Platform. This Privacy Policy has been prepared in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the directives issued by the National Privacy Commission (NPC).

This Privacy Policy applies to all personal data collected through the efabet website at efabet.cam, any associated mobile applications, customer support communications, and all other interactions you have with efabet as a registered player or site visitor.

As a platform operating under Philippine Amusement and Gaming Corporation (PAGCOR) oversight, efabet is also subject to data handling requirements prescribed by PAGCOR's regulatory framework, which complements the protections afforded by the DPA.

efabet acts as the Data Controller responsible for your personal data. We determine the purposes and means of processing the personal information we collect from you, and we are accountable for all data processing activities conducted on our Platform or through our authorized third-party service providers.

2. Personal Data We Collect

efabet collects personal data in several ways: directly from you when you register or interact with the Platform, automatically through your use of the Service, and from third parties as necessary for verification and compliance.

2.1 Information You Provide Directly

• Registration Data: Full legal name, date of birth, nationality, email address, mobile number, and residential address;
• Identity Verification Documents: Copies of government-issued IDs (Philippine passport, driver's license, UMID, PhilSys national ID), proof of address documents, and selfie photographs where required by KYC procedures;
• Financial Information: Payment method details (GCash account number, PayMaya account, bank account details for BPI, BDO, Metrobank, UnionBank, and others), transaction history, and withdrawal preferences;
• Communications: Content of messages, support tickets, chat logs, and other correspondence submitted to efabet customer service;
• Responsible Gaming Data: Information you voluntarily provide when using self-exclusion tools, deposit limits, or seeking support for problem gambling.

2.2 Data Collected Automatically

• Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers;
• Usage Data: Pages visited, games played, betting history, session duration, clickstream data, and Platform navigation patterns;
• Location Data: General geographic location derived from your IP address to support geolocation compliance requirements;
• Cookies and Tracking Data: Information collected through cookies, web beacons, and similar tracking technologies as described in Section 6 of this Policy.

2.3 Data from Third Parties

efabet may receive personal data about you from third-party identity verification providers, payment processors, fraud prevention services, and regulatory authorities where required for legal compliance or security purposes.

3. How We Use Your Personal Data

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

• Account Registration and Management: To create, verify, and maintain your efabet player account in accordance with PAGCOR regulations;
• Identity and Age Verification: To confirm that you meet the minimum age requirement of 21 years and to comply with KYC obligations under Philippine AML laws;
• Service Delivery: To provide access to games, process bets, calculate winnings, and operate all features of the efabet Platform;
• Payment Processing: To process deposits and withdrawals through your chosen payment methods including GCash, PayMaya, and Philippine bank transfers;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other security threats;
• Legal and Regulatory Compliance: To meet obligations under Philippine law, PAGCOR regulations, the Data Privacy Act of 2012, and Anti-Money Laundering Act (AMLA) requirements;
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance through our 24/7 support team;
• Responsible Gaming: To monitor gaming behavior, identify patterns that may indicate problem gambling, enforce self-exclusion requests, and apply deposit or session limits;
• Marketing and Promotions: To send you promotional offers, bonus notifications, and gaming updates where you have provided consent to receive such communications;
• Platform Improvement: To analyze usage patterns, improve game offerings, and enhance the overall efabet player experience.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules, efabet relies on the following lawful bases for processing your personal data:

• Contractual Necessity: Processing required to enter into and perform the Terms & Conditions agreement between you and efabet — including account creation, bet settlement, payment processing, and account management;
• Legal Obligation: Processing necessary to comply with Philippine laws and regulations, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and NPC directives;
• Legitimate Interests: Processing necessary for efabet's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, provided such interests are not overridden by your data protection rights;
• Consent: Processing based on your freely given, specific, and informed consent, particularly for marketing communications and certain optional data processing activities. You may withdraw consent at any time without affecting processing conducted prior to withdrawal.

5. Data Sharing and Disclosure

efabet does not sell, rent, or trade your personal data to third parties for commercial gain. We may share your personal data only in the following circumstances:

5.1 Service Providers

We engage third-party service providers who process personal data on our behalf under strict data processing agreements. These include payment processors (GCash, PayMaya, Philippine banks), identity verification services, fraud detection providers, customer support software platforms, and cloud infrastructure providers. All such providers are contractually bound to process data only as instructed by efabet and to implement appropriate security measures.

5.2 Regulatory and Legal Disclosures

efabet may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts when required by Philippine law, valid legal process, or regulatory obligation. We will notify affected players of such disclosures where legally permissible to do so.

5.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of all or part of efabet's business, personal data may be transferred to the acquiring entity, subject to the same data protection obligations set out in this Privacy Policy.

5.4 Cross-Border Transfers

Where personal data is transferred outside the Philippines, efabet ensures that such transfers comply with the requirements of the Data Privacy Act and NPC guidelines, including the implementation of appropriate safeguards such as data processing agreements incorporating standard contractual clauses.

6. Cookies and Tracking Technologies

efabet uses cookies and similar tracking technologies to deliver, maintain, and improve our Platform. Cookies are small text files stored on your device when you visit the efabet website.

6.1 Types of Cookies We Use

• Essential Cookies: Strictly necessary for Platform functionality, including maintaining your login session, remembering game preferences, and ensuring security features operate correctly. These cannot be disabled without affecting Platform usability;
• Analytics Cookies: Used to collect anonymized data about how visitors use the efabet Platform, helping us understand traffic patterns and improve the gaming experience;
• Functional Cookies: Allow efabet to remember your preferences, language settings, and personalization choices between sessions;
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of efabet marketing campaigns, subject to your consent.

6.2 Managing Cookies

You can control non-essential cookies through your browser settings or the efabet cookie preference center. Note that disabling certain cookies may limit your access to Platform features or affect the quality of your gaming experience. Continued use of efabet following cookie consent constitutes acceptance of our cookie practices.

7. Data Security

efabet implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security framework includes:

• SSL/TLS encryption for all data transmitted between your device and the efabet Platform;
• Encryption of sensitive data at rest, including financial and identity information;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication protocols for account access and financial transactions;
• 24/7 security monitoring and intrusion detection systems.

While efabet employs robust security measures, no online platform can guarantee absolute security. In the event of a personal data breach that poses a risk to your rights and freedoms, efabet will notify you and the National Privacy Commission in accordance with NPC Circular No. 16-03 and applicable data breach notification requirements.

8. Data Retention

efabet retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law and regulatory obligations.

Specifically, account and gaming records are retained for a minimum of five (5) years following account closure, in compliance with Philippine AMLA record-keeping requirements and PAGCOR operational standards. Financial transaction records may be retained for longer periods where required by tax law or ongoing legal proceedings.

Marketing communications data is retained until you withdraw consent or request removal from our mailing list. Technical logs and cookies data are retained for shorter periods consistent with their operational purpose, generally not exceeding thirteen (13) months.

Upon expiry of the applicable retention period, personal data is securely deleted, anonymized, or archived in a manner that prevents identification, in accordance with NPC guidelines on data disposal.

9. Your Data Subject 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: The right to be notified that your personal data is being processed and the purposes thereof, as set out in this Privacy Policy;
• Right of Access: The right to request a copy of the personal data efabet holds about you and information about how it is being processed;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data about you in efabet's records;
• Right to Erasure or Blocking: The right to request deletion or blocking of personal data that is unlawfully processed or no longer necessary for the purposes it was collected, subject to legal retention requirements;
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format for transfer to another service, where technically feasible;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or processing based on legitimate interests;
• Right to Withdraw Consent: The right to withdraw consent at any time for processing activities based on your consent, without affecting the lawfulness of processing conducted prior to withdrawal;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission if you believe your data protection rights have been violated.

To exercise any of these rights, please contact efabet's Data Protection Officer via email at [email protected] with the subject line "Data Privacy Request." We will respond to verified requests within thirty (30) calendar days in accordance with NPC guidelines.

10. Protection of Minors

If efabet discovers or has reason to believe that personal data has been collected from a person below the age of 21 without appropriate parental or guardian consent, we will promptly delete such data, close the associated account, and take appropriate remedial action in accordance with the Data Privacy Act and PAGCOR regulations.

Parents and guardians who believe their minor child may have created an efabet account are urged to contact our customer support team immediately at [email protected] so that the matter can be investigated and resolved without delay.

11. Changes to This Privacy Policy

efabet reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The "Last Updated" date at the top of this document indicates when the most recent revision was made.

Where changes are material to how we process your personal data, efabet will notify registered players via email or a prominent notice on the Platform prior to changes taking effect, where practicable. Your continued use of efabet Services following the posting of an updated Privacy Policy constitutes your acceptance of such changes.

We encourage you to review this Privacy Policy periodically to remain informed about how efabet protects your personal information.

12. Contact Our Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or efabet's data processing practices, please contact our designated Data Protection Officer:

• Email: [email protected]
• Subject Line: "Data Privacy Request" or "Privacy Policy Inquiry"
• Response Time: Within 30 calendar days of receiving your verified request
• Support Hours: 24 hours a day, 7 days a week

If you believe your data privacy rights under the Data Privacy Act of 2012 have been violated, you also have the right to file a complaint directly with the National Privacy Commission of the Philippines.