twtbet Privacy Policy

01 Introduction

twtbet ("we," "us," "the Company," or "twtbet") operates the online gaming platform accessible at twtbet.cam (the "Platform"). We are committed to protecting the personal information of all users of the Platform, including registered account holders, visitors, and prospective registrants.

This Privacy Policy describes:

• What categories of personal data twtbet collects from you
• The purposes for which twtbet processes your personal data
• The legal bases on which twtbet relies to process your personal data
• How long twtbet retains your personal data
• With whom twtbet may share your personal data
• Your rights with respect to your personal data held by twtbet
• How to contact twtbet regarding privacy matters

twtbet processes personal data in compliance with applicable data protection legislation, including the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, and aligns its practices with internationally recognized data protection standards.

02 Data Controller

twtbet is the data controller responsible for the personal data collected and processed through the Platform. As data controller, twtbet determines the purposes and means of processing your personal data and is accountable for ensuring that processing activities comply with applicable data protection laws.

Where twtbet engages third-party service providers to process personal data on its behalf (for example, payment processors, identity verification services, or cloud infrastructure providers), those parties act as data processors under written data processing agreements that bind them to process your data only on twtbet's documented instructions and to maintain appropriate security standards.

03 Personal Data We Collect

twtbet collects the following categories of personal data from account holders and Platform users:

Identity & Registration Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (for age verification — 21+ requirement)
• Nationality and country of residence
• Username chosen during registration
• Email address
• Mobile phone number
• Residential address

KYC Verification Data

• Copy of government-issued photo ID (PhilSys ID, Philippine passport, LTO driver's license, UMID, PRC ID, or Voter's ID)
• Proof of address documentation (utility bill, bank statement, or equivalent)
• Selfie or liveness check image for biometric identity verification (where applicable)
• Source of funds documentation (where required by anti-money laundering obligations)

Financial & Transaction Data

• Deposit and withdrawal transaction records including amounts, timestamps, and payment method identifiers
• Payment method details (masked card numbers, GCash account reference, PayMaya account reference, bank account identifiers)
• Account balance history
• Bonus and promotional credit records

Gaming Activity Data

• Game session records including games played, wager amounts, outcomes, and session durations
• Sports betting slip records including market selections, stake amounts, and settlement results
• Responsible gaming tool activations and settings (deposit limits, session timers, self-exclusion records)

Technical & Usage Data

• IP address and geolocation data derived from IP
• Device type, operating system, browser type and version
• Login timestamps and session identifiers
• Platform navigation and feature usage patterns (aggregated and anonymized where possible)
• Cookie data and similar tracking technologies (see Section 10)

Communications Data

• Records of communications between you and twtbet customer support, including live chat transcripts and email correspondence
• Your stated preferences regarding marketing communications

04 How We Collect Your Data

twtbet collects your personal data through the following channels:

• Directly from you: Information you provide during account registration, KYC verification, payment transactions, support interactions, or when you update your account settings.
• Automatically through the Platform: Technical and usage data collected automatically when you access or use the twtbet platform, including through cookies and similar tracking technologies.
• From third-party verification services: Identity and age verification results from licensed KYC/AML service providers that twtbet engages to fulfill its regulatory obligations.
• From payment processors: Transaction confirmation data and payment reference identifiers from twtbet's payment processing partners (GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and USDT processors).
• From regulatory and law enforcement sources: Where required by applicable law, twtbet may receive or be required to process data in connection with regulatory reporting, anti-money laundering investigations, or law enforcement requests.

05 How We Use Your Personal Data

twtbet uses the personal data it collects for the following purposes:

twtbet will not use your personal data for any purpose that is incompatible with the purposes described in this Privacy Policy without first obtaining your consent or establishing a separate legal basis for such processing.

06 Legal Basis for Processing

twtbet processes your personal data on the following legal bases as applicable under the Philippines' Data Privacy Act of 2012 and related data protection frameworks:

• Contractual necessity: Processing required to perform our obligations under the twtbet Terms & Conditions, including account management, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable law, including anti-money laundering regulations, gaming regulatory requirements, age verification mandates, and tax reporting obligations.
• Legitimate interests: Processing necessary for twtbet's legitimate interests in platform security, fraud prevention, responsible gaming monitoring, and improving the Platform's performance and features, where such interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, and informed consent, including direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Data Sharing & Disclosure

twtbet does not sell your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and cryptocurrency payment processors require transaction data to execute deposits and withdrawals.
• KYC and identity verification providers: Licensed third-party identity verification services used to fulfill age verification and anti-money laundering obligations.
• Cloud infrastructure and hosting providers: twtbet uses licensed cloud service providers to host Platform data. These providers operate under data processing agreements and are bound to process data only on twtbet's instructions.
• Gaming software providers: Game providers may receive limited technical and session data necessary to deliver game content and verify game outcome integrity.
• Regulatory authorities: twtbet is required by applicable gaming regulations and anti-money laundering laws to report certain information to regulatory bodies and cooperate with authorized investigations.
• Law enforcement: twtbet will disclose personal data to law enforcement agencies where compelled to do so by valid legal process, court order, or statutory obligation.
• Professional advisors: Legal, audit, and compliance advisors engaged by twtbet may access personal data under confidentiality obligations as necessary for the provision of their services.

08 International Data Transfers

Some of twtbet's service providers and infrastructure partners operate in jurisdictions outside the Philippines. Where personal data is transferred internationally, twtbet ensures that appropriate safeguards are in place to protect the data in accordance with applicable data protection law. Such safeguards may include:

• Binding data processing agreements incorporating standard contractual clauses
• Transfers to jurisdictions that have been determined to provide an adequate level of data protection by relevant regulatory authorities
• Other legally recognized transfer mechanisms appropriate to the circumstances

You may request information about the specific safeguards applied to international transfers of your personal data by contacting twtbet's data protection team.

09 Data Retention

twtbet retains personal data for the periods necessary to fulfill the purposes described in this Privacy Policy and to comply with our legal obligations. Key retention periods include:

• Account and identity data: Retained for the duration of your active twtbet account plus a minimum of five (5) years following account closure, as required by applicable anti-money laundering and gaming regulatory frameworks.
• Financial and transaction records: Retained for a minimum of seven (7) years following the date of each transaction, consistent with statutory record-keeping requirements.
• KYC documents: Retained for the minimum period mandated by applicable gaming and anti-money laundering regulations, typically five (5) years from the date of verification or account closure.
• Customer support records: Retained for three (3) years from the date of each interaction, or longer where the interaction relates to an unresolved dispute or legal matter.
• Marketing preferences: Retained until you withdraw consent or request deletion, subject to any overriding legal retention obligations.

Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized in accordance with twtbet's data destruction procedures.

10 Cookies & Tracking Technologies

twtbet uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain session security, and collect analytical data. The categories of cookies used by twtbet are as follows:

• Strictly necessary cookies: Essential for Platform functionality, including maintaining your login session, processing transactions, and enforcing security controls. These cookies cannot be disabled without breaking core Platform functions.
• Functional cookies: Remember your preferences (such as language settings and responsible gaming configurations) to personalize your experience across sessions.
• Analytical cookies: Collect aggregated, anonymized data about how users interact with the Platform, used to improve performance, identify errors, and optimize user flows. twtbet uses privacy-respecting analytics tools for this purpose.
• Security cookies: Support fraud detection, session integrity monitoring, and protection against cross-site request forgery and other security threats.

You may control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of some Platform features. twtbet does not use third-party advertising or behavioral targeting cookies.

11 Your Data Protection Rights

Subject to applicable law and any overriding legal obligations of twtbet, you have the following rights in relation to your personal data:

• Right of access: You have the right to request a copy of the personal data twtbet holds about you and information about how it is processed.
• Right to rectification: You have the right to request correction of inaccurate or incomplete personal data twtbet holds about you.
• Right to erasure: You may request deletion of your personal data where there is no longer a lawful basis for twtbet to retain it. Note that certain data must be retained by law regardless of an erasure request.
• Right to restriction of processing: You may request that twtbet restrict the processing of your personal data in certain circumstances, for example while the accuracy of data is disputed.
• Right to data portability: Where processing is based on consent or contractual necessity and carried out by automated means, you may request your personal data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing of your personal data where twtbet relies on legitimate interests as the legal basis, or at any time to the processing of your personal data for direct marketing purposes.
• 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 prior to withdrawal.

To exercise any of these rights, please contact twtbet's data protection team through the support channels described in Section 16. twtbet will respond to verified data subject requests within thirty (30) days of receipt.

12 Children & Minors

twtbet's platform is strictly for persons aged 21 years and above. twtbet does not knowingly collect, process, or retain personal data from any person under the age of 21. The 21+ minimum age is enforced through age declaration at registration and mandatory KYC verification.

If twtbet discovers or has reasonable grounds to believe that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, the data will be deleted in accordance with our data deletion procedures, and the matter will be escalated in accordance with applicable regulatory requirements.

13 Security Measures

twtbet implements a multi-layered data security framework to protect personal data against unauthorized access, disclosure, alteration, and destruction. Key security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and twtbet servers
• Encryption at rest for sensitive data stored in twtbet's database systems
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Multi-factor authentication requirements for twtbet staff accessing production systems containing personal data
• Continuous monitoring and intrusion detection systems on all production infrastructure
• Regular security assessments and penetration testing conducted by independent security specialists
• Documented incident response procedures for data security events

While twtbet takes all commercially reasonable steps to protect your data, no online platform can guarantee absolute security. You are also responsible for maintaining the security of your own twtbet account credentials and for enabling available security features such as two-factor authentication.

14 Third-Party Links & Services

The twtbet platform may reference or link to third-party services such as payment method providers and game software providers. This Privacy Policy applies only to data processed by twtbet. Third-party services operate under their own privacy policies, and twtbet is not responsible for the privacy practices of those third parties.

When you interact with third-party payment services (such as authorizing a GCash deposit), that transaction is governed by the relevant third party's terms and privacy policy in addition to this Privacy Policy. twtbet recommends that you review the privacy notices of any third-party services you interact with.

15 Updates to This Privacy Policy

twtbet may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or Platform features. Material updates to this Privacy Policy will be communicated to registered account holders via email to their registered address and will be posted on this page with an updated effective date.

Your continued use of the twtbet platform following notification of any material update to this Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to an updated Privacy Policy, you must cease use of the Platform and may request account closure at any time by contacting twtbet support.

We recommend periodically reviewing this Privacy Policy to stay informed about how twtbet protects and uses your personal data.

16 Contact & Data Protection Queries

For any questions, requests, or concerns relating to this Privacy Policy or twtbet's data processing activities, please contact twtbet through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the support widget on the twtbet platform
• Email: [email protected] — please include "Privacy Request" in the subject line for data subject rights requests

twtbet aims to acknowledge all privacy-related requests within 48 hours and to provide a substantive response to data subject rights requests within thirty (30) days. Where a request is complex or twtbet receives a high volume of requests, the response period may be extended by up to a further sixty (60) days, of which twtbet will inform you.