sm bet Privacy Policy

This Privacy Policy ("Policy") describes how sm bet ("sm bet," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the sm bet website at sm-bet.app and all associated services, games, and features (collectively, the "Platform").

sm bet is committed to protecting the privacy and personal data of all players, particularly those based in the Republic of the Philippines. Our data practices are designed to comply with Republic Act No. 10173, also known as the Data Privacy Act of 2012, and the implementing rules and regulations issued by the National Privacy Commission (NPC) of the Philippines.

By registering an account on the sm bet Platform, making a deposit, or otherwise using our services, 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, please discontinue use of the Platform immediately.

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

Where sm bet engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and analytics platforms — those parties act as Personal Information Processors and are contractually bound to process your data only in accordance with sm bet's instructions and applicable Philippine data privacy law.

If you have any questions or concerns about how sm bet handles your personal data, you may contact our designated Data Protection Officer (DPO) at [email protected].

sm bet collects the following categories of personal data from players and Platform visitors. We collect only the data that is necessary for the purposes described in this Policy.

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (used to verify the 21+ age requirement)
• Residential address in the Philippines (e.g., Quezon City, Makati, Cebu, Davao, Manila)
• Email address and mobile phone number
• Government-issued ID details (e.g., Philippine passport number, driver's license number, SSS/UMID number)

3.2 Financial Data

• GCash mobile number or PayMaya account details
• BPI, BDO, or Metrobank account details (where used for deposits or withdrawals)
• Transaction history, including deposit amounts, withdrawal requests, and bet records
• Source of funds declarations where required for AML compliance

3.3 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, pages visited, and features used on the Platform
• Login timestamps and access logs
• Cookie identifiers and similar tracking technologies (see Section 10)

3.4 Communications Data

• Records of your communications with sm bet customer support
• Feedback, complaints, and dispute records
• Marketing preferences and communication opt-in/opt-out records

sm bet collects personal data through the following channels:

4.1 Directly From You

The majority of the personal data sm bet holds about you is provided directly by you during the account registration process, KYC verification, deposit and withdrawal transactions, customer support interactions, and when you participate in promotions or surveys on the Platform.

4.2 Automatically Through the Platform

When you access the sm bet Platform, certain technical data is collected automatically through cookies, web beacons, server logs, and similar technologies. This includes your IP address, device identifiers, browser type, and session activity. This data helps us maintain Platform security, detect fraud, and improve the user experience.

4.3 From Third Parties

sm bet may receive personal data about you from the following third-party sources:

• Identity verification providers — to confirm the accuracy of the information you provide during KYC verification.
• Payment processors — including GCash, PayMaya, BPI, BDO, and Metrobank, to confirm transaction details and prevent fraud.
• Anti-fraud and AML screening services — to comply with Philippine anti-money laundering obligations.
• Analytics providers — aggregated and anonymized data to help us understand how players use the Platform.

sm bet uses the personal data we collect for the following purposes:

sm bet will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable Philippine law.

Under the Data Privacy Act of 2012, sm bet processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between you and sm bet — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, tax obligations, and gaming regulatory requirements.
• Legitimate interests: Processing is necessary for sm bet's legitimate interests, including fraud prevention, Platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — sm bet relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

sm bet 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:

7.1 Service Providers

sm bet engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification services, cloud hosting providers, customer support platforms, and analytics tools. These providers are contractually prohibited from using your data for any purpose other than providing services to sm bet.

7.2 Regulatory and Law Enforcement Authorities

sm bet may disclose your personal data to Philippine government agencies, regulatory bodies, law enforcement authorities, or courts where required to do so by applicable law, court order, or regulatory directive. This includes disclosures required under the Anti-Money Laundering Act (AMLA) and its implementing rules.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of sm bet's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

7.4 With Your Consent

sm bet may share your personal data with other third parties where you have given your explicit consent to such sharing.

sm bet retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulations. 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 accordance with AML record-keeping requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Technical and usage logs: Retained for up to twelve (12) months, after which they are anonymized or deleted.
• Marketing consent records: Retained until you withdraw consent or for three (3) years from the date of last interaction, whichever is earlier.

When personal data is no longer required, sm bet will securely delete or anonymize it in accordance with our internal data disposal procedures.

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the sm bet Platform.
• Encryption at rest for sensitive personal data stored on sm bet's servers.
• Access controls limiting access to personal data to authorized sm bet personnel on a strict need-to-know basis.
• Multi-factor authentication for internal systems that process personal data.
• Regular security audits and penetration testing of the Platform infrastructure.
• Staff training on data privacy obligations and secure data handling practices.

While sm bet takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, sm bet will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

The sm bet Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and gather analytics data. A cookie is a small text file placed on your device when you visit a website.

10.1 Types of Cookies We Use

10.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies may affect the functionality of the sm bet Platform, including your ability to log in and access your account. Disabling analytics or marketing cookies will not affect your ability to use the Platform's core features.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by sm bet. To exercise any of these rights, please contact our Data Protection Officer at [email protected]. sm bet will respond to all valid requests within thirty (30) days.

The sm bet Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. sm bet does not knowingly collect personal data from individuals under the age of 21.

If sm bet 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. If you are a parent or guardian and believe that your child has provided personal data to sm bet, please contact us immediately at [email protected].

sm bet employs age verification procedures during the registration process and reserves the right to request documentary proof of age at any time. Any account found to belong to a person under 21 will be suspended immediately and all associated data handled in accordance with this Policy and applicable law.

Some of sm bet's third-party service providers — including cloud hosting infrastructure and analytics platforms — may process personal data outside of the Republic of the Philippines. Where such cross-border transfers occur, sm bet ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Data Privacy Act of 2012.

These safeguards may include contractual clauses approved by the National Privacy Commission, binding corporate rules, or transfers to countries that have been assessed as providing an adequate level of data protection. sm bet will not transfer your personal data to a foreign country or international organization unless such safeguards are in place.

sm bet reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform features. When material changes are made, we will update the "Last Updated" date at the top of this page and, where reasonably practicable, notify registered players via email or an in-Platform notification.

Your continued use of the sm bet Platform after any amendments have been posted constitutes your acknowledgment of the updated Policy. We encourage you to review this Privacy Policy periodically. The most current version will always be available at sm-bet.app/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way sm bet handles your personal data, please contact our designated Data Protection Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.

If you are not satisfied with sm bet's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. For more information on your rights as a data subject, visit the NPC's official resources.

For questions about responsible gaming tools and self-exclusion, please visit our Responsible Gaming page. For the full terms governing your use of the Platform, please review our Terms & Conditions.