robet Privacy
Policy

1 Introduction

robet ("robet," "we," "us," or "our") is committed to protecting the personal data of every player who uses our online casino and sports betting platform. This Privacy Policy describes how robet collects, uses, stores, shares, and protects personal data in accordance with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA") and all related implementing rules and regulations issued by the National Privacy Commission ("NPC").

This Policy applies to all personal data provided by you when you create a robet account, access our platform, interact with our games, make deposits or withdrawals, contact customer support, or engage with robet through any other channel. It applies regardless of whether you access robet from a mobile browser, desktop browser, or any future application.

This Privacy Policy should be read together with robet's Terms & Conditions and Responsible Gaming Policy, which govern your use of the robet platform more broadly.

2 Who We Are — Data Controller

robet is the personal data controller responsible for your data processed under this Privacy Policy. As data controller, robet determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine privacy law.

robet operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Regulatory compliance obligations — including anti-money laundering (AML) requirements — require robet to collect and retain certain personal data independent of commercial purposes, as mandated by Philippine law.

For all privacy-related queries, concerns, or formal data subject requests, you may contact robet's designated Data Protection Officer (DPO) through the contact details set out in Section 15 of this Policy.

3 Personal Data We Collect

robet collects the following categories of personal data, depending on the nature of your interaction with the platform:

robet does not collect special categories of personal data (such as health data, racial or ethnic origin, political opinions, or religious beliefs) unless required for responsible gaming support purposes (for example, if you disclose health information in the context of a self-exclusion request), in which case such data is handled with the highest level of care and restricted to the specific purpose disclosed.

4 How We Collect Personal Data

robet collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, participate in promotions, or update your account settings.
• Automatically: Through cookies, web beacons, and similar tracking technologies when you browse or use the robet platform. See Section 8 for full details on cookies.
• Third-party service providers: Identity verification results from KYC providers, payment confirmation data from GCash, Maya, and banking partners, and fraud detection signals from security service providers.
• Regulatory sources: robet may receive or verify information about you from PAGCOR or other Philippine regulatory or law enforcement authorities in accordance with applicable legal obligations.

5 Purposes & Legal Basis for Processing

robet processes your personal data only where a valid legal basis exists under the Data Privacy Act of 2012. The following table sets out the primary purposes and their corresponding legal bases:

6 How We Use Your Personal Data

In line with the purposes and legal bases described in Section 5, robet uses your personal data for the following activities:

• Creating and managing your robet account, including verifying your identity and eligibility to play.
• Processing financial transactions — deposits via GCash, Maya, BPI, BDO, Metrobank, and other supported Philippine payment channels — and withdrawing your winnings to your verified payment account.
• Complying with PAGCOR's licensing conditions and the Anti-Money Laundering Act (AMLA) of the Philippines, including transaction monitoring, suspicious transaction reporting, and record-keeping requirements.
• Enforcing robet's responsible gaming policies, including monitoring gaming patterns that may indicate problem gambling behaviour and applying self-exclusion or limit restrictions you have requested.
• Detecting and preventing fraud, money laundering, collusion, and other prohibited conduct as defined in robet's Terms & Conditions.
• Providing customer support and responding to your queries, complaints, and disputes through live chat, email, and other support channels.
• Improving the robet platform, including analysing usage patterns, testing new features, and optimising game performance for Philippine mobile users.
• Sending you promotional communications — including bonus offers, tournament announcements, and platform updates — where you have provided consent to receive such communications.
• Personalising your robet experience, such as displaying game recommendations based on your playing history, where you have not opted out of such personalisation.

7 Sharing Your Personal Data

robet shares your personal data only where necessary and only with parties who are bound by appropriate data protection obligations. The categories of recipients are as follows:

• Payment service providers: GCash (GXI), Maya (PayMongo), BPI, BDO, Metrobank, and other Philippine payment partners — to process deposits and withdrawals. These providers process your data as independent data controllers subject to their own privacy policies and Philippine BSP regulations.
• Identity verification providers: Third-party KYC service providers used to verify your identity documents and conduct liveness checks. These providers act as data processors under robet's instruction.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where robet is legally required to disclose information.
• Game content providers: Software providers whose games appear on robet's platform may receive limited technical data (such as session tokens and bet records) to operate the games. These providers are contractually bound to handle data only for the purposes of game operation.
• IT and cloud infrastructure providers: Hosting, database, and security service providers who process data on robet's behalf under data processing agreements that comply with Philippine data protection law.
• Professional advisers: Lawyers, auditors, and regulators, to the extent necessary for robet to comply with legal obligations or exercise legal rights.

robet does not transfer your personal data to recipients outside the Philippines except where necessary to provide the services described above and where appropriate contractual safeguards are in place. Any cross-border data transfer will comply with NPC regulations on personal data protection in cross-border transfers.

8 Cookies & Tracking Technologies

robet uses cookies and similar tracking technologies on its platform to operate core site functions, analyse usage patterns, and (where you have consented) personalise your experience. A "cookie" is a small text file placed on your device by a website when you visit it.

robet uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged in to your robet account during a session. You cannot opt out of these without disabling robet's core functionality.
• Functional Cookies: Remember your preferences, such as language settings and game lobby filters, to improve your experience on subsequent visits.
• Analytics Cookies: Collect aggregated data about how players use the robet platform — pages visited, time spent, game category preferences, error rates — to help robet improve. This data does not identify you individually.
• Marketing Cookies: Used only where you have given explicit consent, to track the effectiveness of promotional campaigns and avoid showing you repetitive promotional content.

You may manage or withdraw your cookie consent at any time through your browser settings. Note that disabling strictly necessary cookies will prevent you from using robet's gaming services. Disabling other cookie categories will not affect your ability to play but may reduce functionality or personalisation features.

9 Data Retention

robet retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, tax, and accounting obligations. The specific retention periods that apply to different categories of data are as follows:

• Account and identity data: Retained for the duration of your active account plus five (5) years after account closure, in accordance with PAGCOR licensing conditions and Philippine AML record-keeping requirements.
• Financial transaction records: Retained for five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• KYC identity documents: Retained for five (5) years after account closure or from the date of the last transaction, whichever is later.
• Gaming history and session data: Retained for five (5) years for regulatory compliance and responsible gaming monitoring purposes.
• Customer support communications: Retained for two (2) years from the date of each interaction, unless a formal dispute is open, in which case records are retained until the dispute is fully resolved.
• Marketing preference data: Retained until you withdraw your consent or request deletion, plus six (6) months thereafter as a record of your preference history.
• Technical and usage logs: Retained for twelve (12) months from collection for security and fraud detection purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents re-identification. robet conducts regular data retention reviews to ensure that no personal data is held longer than necessary.

10 Security Measures

robet implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your browser and robet's servers is encrypted using TLS (Transport Layer Security) protocol. Sensitive data stored at rest — including KYC documents and financial records — is encrypted using AES-256 or equivalent standards.
• Access controls: Access to personal data within robet is restricted to employees and service providers who have a legitimate need to access that data for their job function. Access is governed by role-based permissions and is subject to audit logging.
• Two-factor authentication (2FA): robet offers and encourages 2FA for all player accounts via SMS OTP to your registered Philippine mobile number.
• Regular security assessments: robet conducts periodic security testing, including vulnerability assessments and penetration testing, to identify and remediate security weaknesses in the platform.
• Employee training: All robet personnel with access to personal data receive data privacy and security training in line with NPC guidelines.
• Incident response: robet maintains a data breach response plan. In the event of a personal data breach, robet will notify the NPC within seventy-two (72) hours of becoming aware of the breach and will notify affected players without undue delay where the breach poses a risk to their rights.

While robet takes all reasonable steps to protect your data, no data transmission over the internet or electronic storage system is 100% secure. robet cannot guarantee absolute security, but it does commit to responding swiftly and transparently to any security incident affecting your personal data.

11 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by robet. You may exercise these rights by contacting robet's Data Protection Officer using the details in Section 15.

To exercise any of the above rights, submit a written request to robet's Data Protection Officer via live chat or email (details in Section 15). robet will respond within thirty (30) calendar days of receiving your request. Where a request is complex or requires verification, robet may extend this period by a further thirty (30) days, notifying you of the extension within the initial thirty-day window.

12 Children's Privacy

robet's platform and services are intended exclusively for persons who are 21 years of age or older, in accordance with PAGCOR's minimum age requirements for online casino gaming in the Philippines. robet does not knowingly collect personal data from individuals under the age of 21.

If robet discovers that it has collected personal data from a person under 21, it will immediately suspend the associated account, delete the personal data in question, and retain only the records necessary to document the age violation for regulatory compliance purposes.

Parents or guardians who believe that a minor under their care has registered a robet account should contact support immediately via live chat so that appropriate action can be taken without delay.

13 Third-Party Links

The robet platform may contain links to third-party websites or services — for example, links to payment provider portals or game provider information pages. This Privacy Policy does not apply to those third-party sites or services.

robet is not responsible for the privacy practices or content of any third-party website that you may access through a link on the robet platform. We encourage you to read the privacy policies of any third-party services you visit. The presence of a link on robet's platform does not constitute robet's endorsement of that third party's privacy practices.

14 Changes to This Privacy Policy

robet may update this Privacy Policy from time to time to reflect changes in our data processing practices, the services we offer, or applicable Philippine law. The "Last Updated" date at the top of this Policy will be revised whenever material changes are made.

Where changes are material — meaning they affect the nature of the personal data we collect, the purposes for which we use it, or the rights available to you — robet will notify registered players via email or in-platform notification at least seven (7) days before the changes take effect.

Your continued use of robet's platform following the effective date of any revision constitutes your acknowledgement of the updated Privacy Policy. If you do not agree with the revised Policy, please discontinue use of robet's services and contact support to close your account.

15 Contact Us & Data Privacy Complaints

For all data privacy queries, Data Subject Access Requests (DSARs), or formal complaints related to robet's handling of your personal data, you may contact robet's Data Protection Officer through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the robet platform. Select "Data Privacy Request" from the support category menu.
• Email (Data Privacy): [email protected] — include "DATA PRIVACY REQUEST" in the subject line
• Support Hours: 8:00 AM – 12:00 Midnight PHT (live chat available around the clock)

robet will acknowledge receipt of your request within two (2) business days and will provide a substantive response within thirty (30) calendar days.

If you are not satisfied with robet's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory authority responsible for administering and implementing the Data Privacy Act of 2012 in the Philippines.