Privacy Policy – ubett Casino

1. Overview

ubett ("we," "us," or "our") operates the online gaming platform accessible at ubett.club. As a platform serving Filipino players, ubett is committed to protecting the privacy and personal data of all users in accordance with applicable data protection laws, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

This Privacy Policy describes the types of personal information we collect from you when you use the ubett platform, how we use and protect that information, the circumstances under which we may share it with third parties, and the rights you have in relation to your personal data. We encourage you to read this Policy in full alongside our Terms & Conditions.

ubett acts as the data controller for personal data collected through the ubett.club platform. If you have any questions or concerns about how your data is handled, please refer to Section 14 for our contact details.

2. Personal Data We Collect

ubett collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification — you must be 21 or older);
• Nationality and country of residence;
• Email address and mobile phone number;
• Residential address (barangay, city/municipality, province, ZIP code).

2.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine identification documents (e.g., PhilSys National ID, passport, driver's license, SSS/GSIS ID, Voter's ID);
• Proof of address documents (e.g., utility bill, bank statement);
• Selfie or facial image for liveness verification where required.

2.3 Financial Data

• GCash or PayMaya/Maya account reference (masked);
• Bank account details for withdrawal processing (bank name, account number — stored in masked form);
• Transaction history including deposits, withdrawals, wagers, and winnings in Philippine Peso (PHP).

2.4 Gaming & Behavioural Data

• Game history, bet amounts, session durations, and win/loss records;
• Responsible gaming settings you have applied (deposit limits, self-exclusion status);
• Bonus and promotion participation history.

2.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Login timestamps and session activity logs;
• Cookie identifiers and similar tracking technologies (see Section 9).

2.6 Communications Data

• Records of your communications with ubett customer support (live chat transcripts, email correspondence);
• Feedback, complaints, and dispute records.

3. How We Collect Your Data

ubett collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical and behavioural data collected automatically through cookies, log files, and similar technologies when you access and use the ubett platform;
• Third-party sources: Identity verification data from KYC service providers; fraud and risk screening data from compliance partners; payment confirmation data from payment processors such as GCash and PayMaya.

4. Purpose of Processing

ubett processes your personal data for the following purposes:

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC/AML obligations, age verification requirements, and regulatory reporting;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improving our services, where such interests are not overridden by your rights;
• Consent: Processing for direct marketing communications, where you have provided explicit consent. You may withdraw consent at any time by contacting ubett support.

6. Data Sharing & Disclosure

ubett does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• KYC and identity verification providers: To verify your identity and age in compliance with regulatory requirements;
• Payment processors: GCash, PayMaya/Maya, and Philippine banking partners, to process deposits and withdrawals in PHP;
• Game software providers: To deliver the games and gaming services available on the ubett platform;
• Fraud prevention and AML compliance partners: To screen transactions and player activity for suspicious patterns;
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory directive, including reporting obligations to relevant Philippine gaming authorities;
• IT and cloud service providers: Who provide infrastructure, hosting, and security services under strict data processing agreements.

All third-party service providers who process personal data on ubett's behalf are required to implement appropriate technical and organisational security measures and to process data only in accordance with ubett's instructions.

7. Data Retention

ubett retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and KYC data is retained for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements;
• Transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Communications and support records are retained for three (3) years from the date of the communication;
• Technical and device data (logs) are retained for up to twelve (12) months for security and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with ubett's data disposal procedures.

8. Security Measures

ubett implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ubett platform;
• Encryption of sensitive data at rest, including financial and KYC data;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of the ubett platform;
• Multi-factor authentication options for player accounts;
• Continuous monitoring for suspicious login activity and fraud indicators.

While ubett takes all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying ubett immediately if you suspect any unauthorised access to your account.

9. Cookies & Tracking Technologies

ubett uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and analyse platform usage. The types of cookies we use include:

• Essential cookies: Required for the platform to function correctly, including session management and security tokens. These cannot be disabled;
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits;
• Analytics cookies: Collect anonymised data about how players use the platform to help us improve performance and user experience;
• Marketing cookies: Used with your consent to deliver relevant promotional content based on your gaming preferences.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ubett platform. For essential cookies, no opt-out is available as they are strictly necessary for platform operation.

10. Your Data Rights

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

• Right to be informed: You have the right to be informed of how your personal data is collected, used, and processed, which this Privacy Policy fulfils;
• Right to access: You may request a copy of the personal data ubett holds about you at any time;
• Right to rectification: You may request correction of any inaccurate or incomplete personal data we hold about you;
• Right to erasure: You may request deletion 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;
• Right to data portability: You may request that ubett provide your personal data in a structured, commonly used, and machine-readable format;
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact ubett's Data Protection Officer using the contact details provided in Section 14. ubett will respond to all verified data rights requests within thirty (30) days of receipt.

11. Minors & Age Restriction

If ubett discovers or has reason to believe that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe that your child has registered on the ubett platform, please contact us immediately using the details in Section 14.

ubett employs age verification procedures during the registration process and may request documentary proof of age at any time. Accounts that cannot be verified as belonging to a person aged 21 or above will be suspended pending verification or permanently closed.

12. International Data Transfers

Some of ubett's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, ubett ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Philippine law, including:

• Contractual clauses requiring the recipient to process data in accordance with applicable data protection standards;
• Transfers only to jurisdictions that provide an adequate level of data protection as recognised by the National Privacy Commission;
• Technical and organisational security measures applied consistently regardless of where data is processed.

ubett will not transfer your personal data internationally in a manner that reduces the protections afforded to you under the Philippine Data Privacy Act of 2012.

13. Changes to This Privacy Policy

ubett reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email or a prominent notice on the ubett platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how ubett protects your personal data. Your continued use of the ubett platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by ubett, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe that ubett has not handled your personal data in accordance with applicable law. Information about the NPC and its complaint procedures is publicly available through official Philippine government channels.