unlibet Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by unlibet ("unlibet," "we," "us," or "our") and applies to all personal data collected, processed, stored, and used in connection with your access to and use of the unlibet online gaming platform available at https://unlibet.org, including all associated services, features, mobile interfaces, and communications (collectively, the "Platform").

unlibet is committed to protecting the privacy and personal data of all players, visitors, and users of the Platform. This Policy explains in clear terms what personal data we collect, the purposes for which we process it, the legal bases on which we rely, how long we retain it, and the rights available to you as a data subject under Philippine law.

By registering an account on unlibet or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform and contact us to close your account.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which form part of the agreement between you and unlibet.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, unlibet acts as the personal information controller in respect of the personal data collected through the Platform.

If you have any questions about how unlibet handles your personal data, or if you wish to exercise any of your data subject rights, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

unlibet collects the following categories of personal data from players and users of the Platform:

3.1 Identity and Registration Data

When you register an account on unlibet, we collect information necessary to create and verify your account, including:

• Full legal name as it appears on your government-issued identification;
• Date of birth (to verify that you are at least 21 years of age);
• Gender;
• Nationality and country of residence;
• Username and password (stored in encrypted form);
• Contact details including email address and mobile phone number.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and anti-money laundering (AML) requirements, unlibet may request the following documents:

• Copy of a valid Philippine government-issued ID (e.g., PhilSys ID, passport, driver's license, UMID, SSS ID, or voter's ID);
• Proof of residential address (e.g., utility bill, bank statement, or barangay certificate issued within the last three months);
• Proof of payment method ownership (e.g., screenshot of GCash account, bank account statement);
• Selfie photograph for liveness verification where required.

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records, including amounts, dates, and payment method references;
• GCash account reference numbers, PayMaya account details, or bank account details used for transactions;
• Bonus and promotional credit history;
• Account balance history.

3.4 Gaming Activity Data

• Game session records, including games played, wagers placed, outcomes, and session duration;
• Responsible gaming tool settings, including deposit limits, loss limits, and self-exclusion records;
• Bonus wagering progress and promotional participation history.

3.5 Technical and Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser information;
• Cookie identifiers and session tokens;
• Platform access logs and timestamps.

3.6 Communications Data

• Records of communications between you and unlibet's customer support team, including live chat transcripts and email correspondence;
• Survey responses and feedback submitted through the Platform.

4. How We Collect Your Data

unlibet 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 data collected automatically when you access the Platform, including through cookies, session tracking, and server logs;
• Third-party sources: Identity verification data from KYC service providers; payment confirmation data from payment processors such as GCash and PayMaya; fraud prevention data from third-party risk management services.

5. Legal Basis for Processing

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

Processing Purpose	Legal Basis
Account registration and management	Performance of a contract with you
Identity verification (KYC)	Legal obligation (PAGCOR / AML regulations)
Payment processing	Performance of a contract with you
Fraud prevention and security	Legitimate interests of unlibet
Responsible gaming monitoring	Legal obligation and legitimate interests
Marketing communications	Your consent (opt-in)
Platform analytics and improvement	Legitimate interests of unlibet
Regulatory reporting	Legal obligation

6. How We Use Your Personal Data

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

• To create, verify, and manage your unlibet account;
• To process deposits, withdrawals, and other financial transactions in Philippine Peso;
• To verify your identity and age in compliance with PAGCOR requirements and AML regulations;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities;
• To enforce our Terms & Conditions and other platform policies;
• To provide customer support and respond to your inquiries;
• To administer bonuses, promotions, and loyalty programs;
• To monitor gaming activity for responsible gaming purposes and to apply player protection tools where appropriate;
• To send you marketing communications and promotional offers where you have provided your consent;
• To analyze Platform usage and improve our services, games, and user experience;
• To comply with applicable Philippine laws, PAGCOR regulations, and any lawful requests from competent authorities.

7. Disclosure of Your Personal Data

unlibet 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 only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, 7-Eleven, Cebuana, and M Lhuillier, for the purpose of processing deposits and withdrawals;
• KYC and identity verification providers: Third-party services engaged to verify your identity and age in compliance with regulatory requirements;
• Fraud prevention and risk management services: Third-party providers that assist unlibet in detecting and preventing fraudulent activity;
• Game content providers: Licensed game studios and software providers whose games are available on the Platform, to the extent necessary for game operation and dispute resolution;
• Regulatory authorities: PAGCOR and other competent Philippine government authorities, where disclosure is required by law or regulation;
• Law enforcement: Philippine law enforcement agencies or courts, where disclosure is required by a lawful order or where unlibet reasonably believes disclosure is necessary to prevent or report illegal activity;
• Professional advisors: Legal counsel, auditors, and other professional advisors engaged by unlibet, subject to confidentiality obligations.

All third parties with whom unlibet shares personal data are required to handle such data in accordance with applicable Philippine data protection law and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

8. Cookies and Tracking Technologies

unlibet uses cookies and similar tracking technologies to operate the Platform, remember your preferences, maintain your session, and analyze Platform usage. The following types of cookies are used:

• Strictly necessary cookies: Required for the Platform to function correctly, including session management and security tokens. These cannot be disabled.
• Functional cookies: Used to remember your preferences such as language settings and display options.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping us improve performance and user experience.
• Marketing cookies: Used to deliver relevant promotional content to you based on your activity on the Platform, where you have consented to receive marketing communications.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Continued use of the Platform following the display of our cookie notice constitutes acceptance of our use of cookies as described in this Policy.

9. Data Retention

unlibet retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce our agreements. The following general retention periods apply:

• Account registration and KYC data: Retained for a minimum of five (5) years following account closure, in accordance with PAGCOR and AML regulatory requirements;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction;
• Gaming activity logs: Retained for a minimum of three (3) years;
• Customer support communications: Retained for two (2) years from the date of the last communication;
• Marketing consent records: Retained until you withdraw your consent, plus one (1) year thereafter as evidence of consent.

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

10. Data Security

unlibet implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including passwords and financial information;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Two-factor authentication (2FA) available for all player accounts;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, unlibet will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC regulations.

11. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by unlibet:

• Right to be informed: You have the right to be informed about how your personal data is collected and processed, as set out in this Policy;
• Right of access: You have the right to request a copy of the personal data unlibet holds about you;
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data;
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to unlibet's legal retention obligations;
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time;
• Right to data portability: You have the right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact unlibet's Data Protection Officer using the contact details in Section 15. unlibet will respond to all data subject requests within thirty (30) days of receipt, in accordance with NPC guidelines.

12. Children's Privacy

The unlibet Platform is strictly intended for adults aged twenty-one (21) years and above. unlibet does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete such data and close the associated account.

If you believe that a minor has registered an account on unlibet or that we have inadvertently collected personal data from a minor, please contact us immediately at the details provided in Section 15.

13. Third-Party Services

The unlibet Platform may integrate with third-party services including payment gateways, game content providers, and analytics tools. These third parties operate under their own privacy policies and data protection practices. unlibet is not responsible for the privacy practices of third-party services and encourages players to review the privacy policies of any third-party services they interact with.

unlibet does not include third-party advertising networks or social media tracking pixels on the Platform that would allow third parties to collect your personal data for their own purposes without your knowledge.

14. Changes to This Privacy Policy

unlibet reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material, unlibet will notify registered players by email or through an in-platform notification prior to the changes taking effect. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with the amended Policy, you should cease using the Platform and contact us to close your account.

15. Contact and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way unlibet handles your personal data, please contact our Data Protection Officer:

• Support Email: [email protected]
• Live Chat: Available 24/7 via the unlibet Platform
• Response Time: Under 2 minutes for live chat; within 30 days for formal data subject requests

If you are not satisfied with unlibet's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC and how to file a complaint is available through official Philippine government channels.