Sulobet Privacy Policy

1 Introduction

Sulobet ("Sulobet," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the Sulobet platform at sulobet.org. This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information when you access or use the Sulobet website, mobile application, games, and related services (collectively, the "Platform").

This Policy applies to all players registered on Sulobet, visitors to our website, and any individual whose personal data we process in connection with the operation of the Platform. By registering an account or continuing to use the Sulobet Platform, you acknowledge that you have read and understood this Privacy Policy.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference and govern your overall use of the Sulobet Platform.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, Sulobet is the Personal Information Controller in respect of the personal data collected through the Platform. This means Sulobet determines the purposes and means by which your personal data is processed.

Where Sulobet engages third-party service providers to process personal data on its behalf — such as payment processors, KYC verification providers, and IT infrastructure partners — those parties act as Personal Information Processors and are contractually bound to process your data only on Sulobet's documented instructions and in accordance with applicable Philippine data protection law.

If you have any questions about how Sulobet handles your personal data, or if you wish to exercise any of your data subject rights, please contact our Data Protection Officer using the details provided in Section 14 of this Policy.

3 Personal Data We Collect

Sulobet collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include the following:

Sulobet does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by law or where you voluntarily provide such information in the context of a responsible gaming self-assessment.

4 How We Collect Your Data

Sulobet collects personal data through the following channels:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions;
• Automated technologies: Data collected automatically when you access the Platform, including cookies, web beacons, server logs, and similar tracking technologies (see Section 8 for details);
• Third-party sources: Data received from identity verification providers, payment processors, fraud prevention services, and, where applicable, PAGCOR-affiliated responsible gaming databases;
• Public sources: Publicly available information used to verify your identity or to comply with anti-money laundering obligations.

5 How We Use Your Personal Data

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

• Account management: To create, maintain, and administer your Sulobet player account;
• Service delivery: To provide access to games, process bets, and deliver the features of the Platform;
• Payment processing: To process deposits and withdrawals through GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels;
• Identity verification: To verify your age (21+), identity, and eligibility to use the Platform in compliance with PAGCOR requirements;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct;
• Responsible gaming: To monitor gaming behaviour, enforce deposit limits and self-exclusion requests, and identify players who may need support;
• Customer support: To respond to your enquiries, complaints, and feedback;
• Legal compliance: To comply with applicable Philippine laws, PAGCOR regulations, and court orders;
• Platform improvement: To analyse usage patterns and improve the functionality, performance, and content of the Sulobet Platform;
• Marketing communications: To send you promotional offers and updates about Sulobet, where you have provided your consent to receive such communications.

Sulobet will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, Sulobet relies on the following legal bases to process your personal data:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your account, process bets, and handle payments;
• Legal obligation: Processing required to comply with Philippine law, PAGCOR licensing conditions, anti-money laundering regulations, and tax obligations;
• Legitimate interests: Processing necessary for Sulobet's legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent — primarily for direct marketing communications. You may withdraw your consent at any time by updating your account notification preferences.

7 Sharing Your Personal Data

Sulobet does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We 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, BPI, BDO, Metrobank, and other payment service providers, to process your financial transactions;
• KYC and identity verification providers: Third-party services engaged to verify your identity and age in compliance with regulatory requirements;
• IT and cloud infrastructure providers: Service providers who host and maintain the Sulobet Platform and its underlying systems;
• Fraud prevention and security services: Providers who assist Sulobet in detecting and preventing fraudulent activity and money laundering;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where required by law or regulatory obligation;
• Legal and professional advisers: Lawyers, auditors, and other professional advisers engaged by Sulobet in connection with legal proceedings or compliance matters.

8 Cookies & Tracking Technologies

Sulobet uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse how players use our services. A cookie is a small text file placed on your device when you visit the Sulobet website.

We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function — these cannot be disabled. They include session authentication cookies and security tokens;
• Functional cookies: Used to remember your preferences, such as language settings and login details, to improve your experience;
• Analytics cookies: Used to collect anonymised data about how players navigate the Platform, helping us identify areas for improvement;
• Marketing cookies: Used to deliver relevant promotional content within the Sulobet Platform, based on your activity and preferences.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Sulobet Platform. Sulobet does not use cookies to serve third-party advertising on external websites.

9 Data Security

Sulobet implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and Sulobet's servers;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing of the Platform's infrastructure;
• Multi-factor authentication options for player accounts;
• Incident response procedures to detect, report, and address personal data breaches promptly.

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

10 Data Retention

Sulobet retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements;
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations;
• Gaming and betting records: Retained for a minimum of three (3) years from the date of the relevant game session;
• Customer support communications: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained until you withdraw your consent, plus one (1) year thereafter for compliance documentation purposes.

When personal data is no longer required, Sulobet will securely delete or anonymise it in accordance with our internal data disposal procedures. Anonymised data that can no longer be linked to an identifiable individual may be retained indefinitely for statistical and analytical purposes.

11 Your Data Subject Rights

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

• Right to be informed: The right to be told how your personal data is being collected and used — which is the primary purpose of this Privacy Policy;
• Right of access: The right to request a copy of the personal data Sulobet 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 Sulobet'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 legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller where technically feasible;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact Sulobet's Data Protection Officer using the contact details in Section 14. Sulobet will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

12 Children's Privacy

The Sulobet Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. Sulobet does not knowingly collect personal data from individuals under the age of 21.

If Sulobet becomes aware 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. Any funds deposited by an underage player will be handled in accordance with applicable Philippine law.

13 Changes to This Privacy Policy

Sulobet 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 by posting a prominent notice on the Platform and, where practicable, by sending a notification to the email address registered on your account.

The date of the most recent revision is displayed at the top of this page. Your continued use of the Sulobet Platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the changes. We encourage you to review this Policy periodically to stay informed about how Sulobet protects your personal data.

If you do not agree with any changes to this Privacy Policy, you should cease using the Platform and may request closure of your account by contacting our support team.

14 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way Sulobet handles your personal data, please contact our Data Protection Officer using the details below:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe that Sulobet has not handled your personal data in accordance with the Data Privacy Act of 2012. For more information about your rights and how to file a complaint, visit the NPC's official website.

For responsible gaming concerns, including self-exclusion requests and deposit limit adjustments, please visit our dedicated Responsible Gaming page.