Privacy Policy

1. Introduction

holliganbet ("we," "us," or "our") is committed to protecting the privacy and personal data of all users ("you" or "Player") who access or use the holliganbet platform at holliganbet.club (the "Platform"). This Privacy Policy describes how holliganbet collects, uses, discloses, stores, and safeguards your personal information in connection with your use of the Platform.

This Privacy Policy is incorporated into and forms part of holliganbet's Terms & Conditions. By registering an account or using the Platform, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy.

holliganbet operates in the Philippines and processes personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

2. Personal Data We Collect

holliganbet collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Identity Data: Full name, date of birth, nationality, and government-issued identification number;
• Contact Data: Email address, mobile number, and residential address (city, province, region);
• Account Data: Username, password (stored in hashed form), security questions and answers;
• Financial Data: Payment method details (e.g., GCash account reference, Maya account reference, bank account details for BPI, BDO, Metrobank, UnionBank, and other supported banks), transaction history, deposit and withdrawal records;
• Verification Documents: Copies of government-issued ID, proof of address, and selfie photographs submitted for KYC purposes.

2.2 Data Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device identifiers, and screen resolution;
• Usage Data: Pages visited, games played, session duration, betting history, click-stream data, and feature interactions;
• Location Data: General geographic location derived from your IP address (country and city level only; holliganbet does not collect precise GPS location);
• Cookie Data: Information collected via cookies and similar tracking technologies as described in Section 8.

2.3 Data from Third Parties

holliganbet may receive personal data about you from third-party identity verification providers, payment processors, fraud prevention services, and analytics partners, where such sharing is permitted by applicable law.

3. How We Use Your Personal Data

holliganbet uses your personal data only for legitimate, specified purposes. The primary purposes for which we process your data are as follows:

• Account Management: To create, maintain, and administer your holliganbet account, including verifying your identity and eligibility to use the Platform;
• Service Delivery: To process deposits and withdrawals, settle bets, award bonuses, and provide customer support;
• Legal & Regulatory Compliance: To comply with anti-money laundering (AML) obligations, know-your-customer (KYC) requirements, and other applicable Philippine laws and regulations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, cheating, collusion, and other prohibited activities on the Platform;
• Responsible Gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, and to enforce self-exclusion and account restriction requests;
• Platform Improvement: To analyse usage patterns, conduct research, and improve the features, performance, and content of the holliganbet Platform;
• Marketing Communications: To send you promotional offers, newsletters, and updates about holliganbet products and services, where you have consented to receive such communications;
• Legal Claims: To establish, exercise, or defend legal claims involving holliganbet.

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

4. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your holliganbet account and deliver the services you have requested;
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including AML, KYC, and tax reporting obligations;
• Legitimate Interests: Processing is necessary for holliganbet's legitimate interests, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and interests;
• Consent: Where we rely on your consent — for example, for marketing communications — you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

holliganbet does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

5.1 Service Providers

holliganbet engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, Maya, and banking partners), identity verification providers, cloud hosting providers, customer support platforms, and analytics services. These providers are contractually bound to process your data only on holliganbet's instructions and in accordance with applicable data protection law.

5.2 Regulatory & Law Enforcement Authorities

holliganbet may disclose your personal data to government agencies, regulatory bodies, law enforcement authorities, or courts where required to do so by applicable Philippine law, court order, or regulatory directive. This includes disclosures required under AML legislation and PAGCOR licensing conditions.

5.3 Business Transfers

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

5.4 With Your Consent

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

6. Data Retention

holliganbet retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

• Active Accounts: Personal data is retained for the duration of your holliganbet account and for a minimum of five (5) years following account closure, in accordance with Philippine AML record-keeping requirements;
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction;
• KYC Documents: Identity verification documents are retained for the period required by applicable law, typically five (5) years from the end of the business relationship;
• Marketing Data: Data processed on the basis of consent for marketing purposes is retained until you withdraw your consent or request deletion, whichever is earlier;
• Technical & Usage Data: Log files and usage data are typically retained for up to twenty-four (24) months.

When personal data is no longer required, holliganbet will securely delete or anonymise it in accordance with our internal data retention and disposal procedures.

7. Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by holliganbet:

• Right to Be Informed: You have the right to be informed about how holliganbet collects and processes your personal data, as set out in this Privacy Policy;
• Right of Access: You have the right to request a copy of the personal data holliganbet holds about you;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• 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 holliganbet's legal and regulatory 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, and machine-readable format;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe holliganbet has processed your personal data in violation of applicable law.

To exercise any of these rights, please contact holliganbet's Data Protection Officer at [email protected]. holliganbet will respond to all verified requests within thirty (30) days, or such other period as permitted by applicable law.

8. Cookies & Tracking Technologies

holliganbet uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and support our security and fraud prevention measures.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These cookies enable core features such as account login, session management, and security. They cannot be disabled;
• Performance & Analytics Cookies: Help us understand how players interact with the Platform by collecting aggregated, anonymised usage data. This allows us to identify areas for improvement;
• Functional Cookies: Remember your preferences and settings (such as language and display preferences) to provide a more personalised experience;
• Marketing Cookies: Used to deliver relevant promotional content to you. These cookies are only set where you have provided consent.

8.2 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the holliganbet Platform. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is set. Refer to your browser's help documentation for instructions.

9. Data Security

holliganbet implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the holliganbet Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Access controls ensuring that only authorised holliganbet personnel can access personal data, on a strict need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Incident response procedures to detect, report, and address personal data breaches promptly.

While holliganbet takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, holliganbet will notify you and the National Privacy Commission in accordance with applicable law.

10. Children's Privacy

The holliganbet Platform is strictly intended for individuals aged 21 years and older, in accordance with Philippine regulations governing casino-style gambling. holliganbet does not knowingly collect personal data from individuals under the age of 21.

If holliganbet becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the holliganbet Platform, please contact us immediately at [email protected].

11. Third-Party Links

The holliganbet Platform may contain links to third-party websites or services for informational purposes. holliganbet is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to the holliganbet Platform.

12. Changes to This Privacy Policy

holliganbet reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. The revised Privacy Policy will be published on this page with an updated "Last Updated" date.

Where changes are material, holliganbet will endeavour to notify registered players via email or in-platform notification prior to the changes taking effect. Your continued use of the holliganbet Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms.

13. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or holliganbet's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Response Time: Within 30 days for formal data subject requests; within 24 hours for general enquiries via live chat
• Regulator: National Privacy Commission of the Philippines — privacy.gov.ph

You also have the right to lodge a complaint directly with the National Privacy Commission if you are not satisfied with holliganbet's response to your data privacy concern.