twtbet Privacy Policy

1. Introduction

twtbet operates the online casino and sports betting platform accessible at twtbet.app, serving Filipino players across Metro Manila, Cebu, Davao, Quezon City, and the rest of the Philippines. As a platform that handles sensitive personal and financial information, twtbet takes its data protection obligations seriously.

This Privacy Policy applies to all personal data collected by twtbet in connection with your use of the twtbet platform, including data collected during account registration, identity verification, deposits and withdrawals, gameplay, customer support interactions, and any other use of our services. It applies to all registered players, visitors to the twtbet website, and any other individuals whose personal data twtbet processes in connection with the operation of the platform.

This policy should be read alongside twtbet's Terms and Conditions and Responsible Gaming Policy, both of which are available on the twtbet platform. By registering for a twtbet account or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2. Personal Data We Collect

2.1 Registration Data

When you create a twtbet account, we collect the personal information you provide during the registration process, which may include:

• Full legal name;
• Date of birth (to verify you are 21 years of age or older);
• Email address;
• Mobile phone number;
• Residential address (including city, province, and postal code);
• Username and password (password stored in hashed form only).

2.2 Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) process, required under Philippine anti-money laundering regulations, twtbet may collect:

• Government-issued photo identification (e.g., Philippine passport, driver's licence, SSS ID, PhilSys National ID, UMID);
• Proof of address documents (e.g., utility bills, bank statements);
• Selfie photographs for identity verification purposes;
• Tax Identification Number (TIN) where required by applicable law.

2.3 Financial Data

To process deposits and withdrawals, twtbet collects financial information including:

• GCash or PayMaya mobile number;
• Bank account details (account name, account number, bank name) for BPI, BDO, Metrobank, and other supported banks;
• Credit or debit card details (card number, expiry date, CVV – processed securely and not stored on twtbet servers in plain text);
• Transaction history associated with your twtbet account.

2.4 Usage and Technical Data

When you use the twtbet platform, we automatically collect certain technical and usage data, including:

• IP address and approximate geographic location;
• Device type, operating system, and browser information;
• Pages visited, features used, and time spent on the platform;
• Game history, betting activity, and session logs;
• Login timestamps and access logs.

2.5 Communications Data

When you contact twtbet's customer support team via live chat or email, we retain records of those communications, including the content of your messages and any attachments you provide, for quality assurance, training, and dispute resolution purposes.

3. How We Collect Your Data

twtbet collects your personal data through the following means:

• Directly from you: When you register for an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions;
• Automatically: Through cookies, web beacons, and similar tracking technologies when you access and use the twtbet platform;
• From third parties: From identity verification service providers, payment processors (such as GCash and PayMaya), fraud prevention services, and, where applicable, from publicly available sources for AML compliance purposes.

4. How We Use Your Personal Data

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

• Account management: To create, maintain, and manage your twtbet account, including processing your registration and verifying your identity;
• Age verification: To confirm that you are at least 21 years of age, as required by Philippine gaming regulations;
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, bank transfer, and card payments;
• Legal compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML), counter-terrorism financing (CTF), and data privacy regulations;
• Fraud prevention: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the platform;
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance;
• Platform improvement: To analyze usage patterns, identify technical issues, and improve the features and performance of the twtbet platform;
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out of marketing communications at any time.

5. Legal Basis for Processing

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

• Contractual necessity: Processing is necessary to perform our contract with you (i.e., to provide the twtbet gaming services you have registered for);
• Legal obligation: Processing is necessary to comply with our legal obligations under Philippine law, including AML, CTF, and gaming regulatory requirements;
• Legitimate interests: Processing is necessary for twtbet's legitimate interests, including fraud prevention, platform security, and improving our services, where those interests are not overridden by your data protection rights;
• Consent: Where we rely on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Data Sharing and Disclosure

6.1 Service Providers

twtbet shares your personal data with carefully selected third-party service providers who assist us in operating the platform. These include identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard), fraud detection services, cloud hosting providers, and customer support software vendors. All third-party service providers are contractually required to process your data only on twtbet's instructions and to maintain appropriate security measures.

6.2 Legal and Regulatory Disclosure

twtbet may disclose your personal data to Philippine government authorities, regulatory bodies, law enforcement agencies, or courts where required to do so by applicable law, court order, or regulatory direction. This includes disclosures to the Anti-Money Laundering Council (AMLC) of the Philippines in connection with suspicious transaction reporting obligations under the Anti-Money Laundering Act (AMLA).

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of twtbet's business, your personal data may be transferred to the acquiring entity as part of that transaction. twtbet will notify registered players of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

6.4 No Sale of Personal Data

twtbet does not sell, rent, or trade your personal data to third-party advertisers or data brokers. Your personal information is not a commercial product at twtbet.

7. Data Retention

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

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required under Philippine AML regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Customer support communications: Retained for three (3) years from the date of the communication;
• Marketing consent records: Retained for the duration of your account and for three (3) years following account closure or withdrawal of consent;
• Technical and usage logs: Retained for up to twelve (12) months, unless required for longer periods for fraud investigation or legal proceedings.

Upon expiry of the applicable retention period, twtbet will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless a longer retention period is required by law or is necessary for the establishment, exercise, or defence of legal claims.

8. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the twtbet platform;
• Encryption of sensitive data at rest, including payment details and government-issued ID scans;
• Role-based access controls ensuring that only authorized personnel can access personal data, and only to the extent necessary for their role;
• Regular security audits and penetration testing of the twtbet platform and infrastructure;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and responding to personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, twtbet will notify the National Privacy Commission (NPC) of the Philippines within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where required by applicable law.

9. Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit the twtbet platform. They allow the platform to recognize your device, remember your preferences, and collect information about how you use the site. twtbet also uses similar technologies such as web beacons and local storage for comparable purposes.

9.2 Types of Cookies We Use

• Essential cookies: Necessary for the platform to function correctly. These include session cookies that keep you logged in during your visit. These cannot be disabled without affecting platform functionality;
• Performance cookies: Collect anonymized information about how players use the platform (e.g., which pages are visited most frequently) to help us improve performance and user experience;
• Functional cookies: Remember your preferences such as language settings and display options to provide a more personalized experience;
• Analytics cookies: Used to analyze aggregate usage patterns and measure the effectiveness of platform features. Data collected is anonymized and not linked to individual players.

9.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is set. Please note that disabling essential cookies may affect the functionality of the twtbet platform, including your ability to log in and access your account. twtbet does not use cookies to track your activity on third-party websites unrelated to the twtbet platform.

10. Your Data Protection Rights

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

• Right to be informed: The right to be informed about how your personal data is collected and processed – which this Privacy Policy fulfils;
• Right of access: The right to request a copy of the personal data twtbet 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 twtbet's legal 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 data controller;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe twtbet has violated your data privacy rights.

To exercise any of these rights, please contact twtbet's Data Protection Officer via live chat or by emailing [email protected] with the subject line "Data Privacy Request." twtbet will respond to all valid data privacy requests within 30 days of receipt.

11. Children's Privacy

The twtbet platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gaming regulations. twtbet does not knowingly collect personal data from individuals under the age of 21. If twtbet becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted immediately and the associated account will be closed.

If you are a parent or guardian and believe that your child has provided personal data to twtbet, please contact our support team immediately via live chat or at [email protected] so that we can take appropriate action.

12. Third-Party Links

The twtbet platform may contain links to third-party websites or services, such as payment provider portals (e.g., GCash, PayMaya). twtbet is not responsible for the privacy practices of those third-party websites. When you leave the twtbet platform and visit a third-party site, that site's own privacy policy will govern the collection and use of your personal data. twtbet encourages you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

twtbet reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, twtbet will notify registered players via the email address associated with their account or via a prominent notice on the platform prior to the changes taking effect.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent changes were made. Your continued use of the twtbet platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised policy. If you do not agree to the updated policy, you must stop using the twtbet platform and may request account closure by contacting our support team.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or twtbet's data protection practices, please contact our Data Protection Officer through any of the following channels:

• Live Chat: Available 24/7 on the twtbet platform – average response time under 3 minutes
• Email: [email protected] – please use subject line "Privacy Policy Enquiry"
• Languages: English and Filipino

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe that twtbet has not handled your personal data in accordance with the Data Privacy Act of 2012. twtbet encourages players to contact us first so that we can address your concerns directly and promptly.