betcup Privacy Policy

This Privacy Policy ("Policy") describes how betcup ("betcup," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal data of individuals ("you," "your," or "Player") who access or use the betcup online gaming platform at betcup.app and all associated services, features, and content (collectively, the "Platform").

betcup is committed to protecting the privacy and security of your personal data. This Policy is designed to help you understand what information we collect about you, why we collect it, and the choices you have in relation to your personal data. We encourage you to read this Policy carefully and in full before using the betcup Platform.

By registering an account on betcup or otherwise using 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 this Policy, please do not use the betcup Platform.

betcup is an online gaming platform operating at betcup.app, providing casino games, bingo, slots, live dealer games, and related entertainment services to eligible players in the Philippines. betcup operates in compliance with PAGCOR guidelines applicable to online gaming in the Philippines.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, betcup acts as the Personal Information Controller in respect of the personal data it collects and processes through the Platform.

betcup has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for our DPO are provided in Section 14 of this Policy.

betcup collects the following categories of personal data in connection with your use of the Platform:

betcup does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive personal information is collected — such as government ID numbers — it is handled with additional safeguards as required by the Data Privacy Act of 2012.

betcup collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and use the Platform, including through cookies, web beacons, and similar tracking technologies (see Section 8).
• Third-party sources: Identity and fraud-check data received from KYC verification service providers, payment processors (such as GCash and PayMaya), and fraud prevention partners, where you have authorized such sharing or where betcup is required to conduct such checks by law.
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with betcup's compliance obligations.

betcup uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your betcup player account, including verifying your identity and eligibility to use the Platform.
• Platform delivery: To provide you with access to betcup's games, features, and services, and to process your bets, deposits, and withdrawals.
• KYC and AML compliance: To verify your identity, age, and source of funds in accordance with our Know Your Customer and Anti-Money Laundering obligations under Philippine law.
• Responsible gaming: To monitor your gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Legal compliance: To comply with applicable laws, regulations, and regulatory requirements, including reporting obligations to PAGCOR and other authorities.
• Platform improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the betcup Platform.
• Marketing communications: To send you promotional offers, bonuses, and news about betcup, where you have consented to receive such communications. You may opt out at any time.

betcup processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its implementing rules:

• Contractual necessity: Processing required to perform our contract with you — including account registration, game delivery, and financial transaction processing.
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC, AML, and PAGCOR reporting requirements.
• Legitimate interests: Processing necessary for betcup's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — including for marketing communications and certain cookie-based tracking. You may withdraw consent at any time without affecting the lawfulness of prior processing.

betcup 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:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers engaged to assist with identity verification, age verification, and fraud screening.
• IT and platform service providers: Cloud hosting, data storage, cybersecurity, and analytics service providers who process data on betcup's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other government authorities, where disclosure is required by law or regulation.
• Professional advisers: Legal counsel, auditors, and other professional advisers, where necessary for betcup's legal and compliance obligations.

All third parties with whom betcup shares personal data are required to handle such data in accordance with applicable data protection laws and betcup's data protection standards. betcup remains responsible for ensuring that any third-party processing of your data is conducted lawfully and securely.

betcup uses cookies and similar tracking technologies to enhance your experience on the Platform, to analyze usage patterns, and to support security and fraud prevention functions. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management, authentication, and security. These cookies cannot be disabled without affecting Platform functionality.
• Functional cookies: Used to remember your preferences and settings, such as language preferences and responsible gaming tool configurations.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping betcup identify areas for improvement. These cookies do not identify you personally.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the betcup Platform. betcup does not use third-party advertising or behavioral tracking cookies.

betcup retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a period of at least 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, as required by the Anti-Money Laundering Act and related regulations.
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer support records: Retained for three (3) years from the date of the interaction, or longer where required for dispute resolution or legal proceedings.
• Marketing data: Retained until you withdraw your consent to receive marketing communications, after which it will be deleted or anonymized within a reasonable period.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized so that it can no longer be associated with you as an individual.

betcup 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 betcup Platform;
• Encryption of sensitive data at rest, including financial data and identity documents;
• Role-based access controls limiting access to personal data to authorized personnel only;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for administrative access to betcup's systems;
• 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, betcup will notify the National Privacy Commission and, where required, affected individuals in accordance with the timeframes prescribed by the Data Privacy Act of 2012 and its implementing rules.

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights in relation to your personal data held by betcup:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data betcup holds about you, together with information about how it is being processed.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected without undue delay.
• Right to erasure: 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 betcup's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to damages: The right to claim compensation for any damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.

To exercise any of these rights, please contact betcup's Data Protection Officer using the contact details provided in Section 14. betcup will respond to all valid requests within thirty (30) days of receipt, or within such other period as may be prescribed by applicable law.

If you are not satisfied with betcup's response to your request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

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

If betcup becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete such data and close the associated account. If you believe that betcup may have collected personal data from a minor, please contact us immediately using the details in Section 14.

betcup employs age verification procedures during the account registration process and reserves the right to request documentary proof of age at any time. Accounts that cannot be verified as belonging to a person aged 21 or over will be suspended pending verification or permanently closed.

betcup 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. When we make material changes to this Policy, we will notify registered players by posting a prominent notice on the Platform and, where practicable, by sending a notification to the email address associated with your account.

The date of the most recent revision to this Policy is indicated at the top of this page. We encourage you to review this Policy periodically to stay informed of how betcup is protecting your personal data. The current version of this Policy will always be accessible at betcup.app/privacy-policy.

Your continued use of the betcup Platform following the posting of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree with the revised Policy, you must cease using the Platform and close your account.

If you have any questions, concerns, or requests relating to this Privacy Policy or betcup's handling of your personal data, please contact our Data Protection Officer:

• Data Protection Officer: betcup Privacy Team
• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the betcup Platform

betcup will acknowledge receipt of all privacy-related requests within 72 hours and will endeavor to provide a substantive response within thirty (30) days. For complex requests, we may require additional time, in which case we will notify you of the extended timeline and the reasons for the delay.