Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how batpk ("batpk", "we", "us", "our") collects, uses, stores, shares, and protects the personal information of individuals ("you", "User", "Player") who access or use the batpk online casino and sports betting platform at https://batpk.bet and its associated interfaces (collectively, the "Platform").

batpk is committed to handling your personal data responsibly and in full compliance with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). We also align our practices with the responsible gaming data standards promoted by PAGCOR.

By registering an account on or otherwise using the batpk Platform, you acknowledge that you have read, understood, and agreed to the practices described in this Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform and contact batpk support to arrange account closure.

This Policy should be read together with batpk's Terms & Conditions and any product-specific privacy notices that may be presented to you at relevant points of use on the Platform.

02 Data Controller

batpk is the personal information controller responsible for the personal data collected and processed through the Platform. As a personal information controller under the Data Privacy Act of 2012, batpk determines the purpose and means of processing your personal information and is accountable for ensuring that processing activities comply with applicable data protection law.

batpk has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and Philippine data privacy law. Contact details for the DPO are provided in Section 14 of this Policy. You may direct any data privacy concerns, requests, or complaints directly to the DPO.

03 Personal Data We Collect

batpk collects the following categories of personal data in connection with the operation of the Platform and fulfillment of our legal obligations:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID
• Date of birth and age verification information
• Nationality and country of residence
• Government-issued identification numbers (e.g., Philippine passport number, driver's license number, SSS/UMID number, PhilSys reference number)
• Profile photograph or selfie where requested for KYC purposes

3.2 Contact Data

• Registered mobile number (including GCash/PayMaya-linked numbers)
• Email address
• Residential or billing address

3.3 Financial & Transaction Data

• Deposit and withdrawal history
• Payment method identifiers (e.g., masked GCash account number, bank account details for transfer verification)
• Transaction amounts, dates, and reference numbers
• Currency and PHP conversion records where applicable

3.4 Gameplay & Activity Data

• Game participation records, bet history, and game outcomes
• Session start and end times
• Responsible gaming settings you have configured (deposit limits, session reminders, self-exclusion status)
• Bonus and promotion uptake records

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Session tokens and login timestamps
• Cookies and similar tracking technologies (see Section 9)

3.6 Communications Data

• Records of your interactions with batpk customer support, including live chat transcripts, email correspondence, and call logs where applicable
• Feedback, survey responses, and voluntary information you provide

04 How We Collect Your Data

batpk collects personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make deposits or withdrawals, participate in games, contact support, or respond to surveys.
• Automatically through the Platform: Technical and device data is collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• From third-party service providers: Identity verification services, fraud detection platforms, and payment processors may provide us with data about you in connection with the services they perform on our behalf.
• From public sources: Where permitted by law, we may verify information against publicly available records, including government databases for KYC compliance purposes.

05 Purpose & Legal Basis for Processing

batpk processes your personal data only for specific, legitimate purposes. The table below summarizes the key purposes and the corresponding legal basis under the Data Privacy Act of 2012:

Where batpk processes your personal data on the basis of your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent for marketing communications, update your preferences in your account settings or contact batpk support.

06 Data Sharing & Disclosure

batpk does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We may share your personal data only in the following circumstances:

6.1 Service Providers

batpk engages trusted third-party service providers who process personal data on our behalf under strict data processing agreements. These include:

• Payment processors and e-wallet providers (GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency processing partners)
• KYC and identity verification service providers
• Fraud detection and anti-money laundering compliance platforms
• Cloud hosting and data storage infrastructure providers
• Customer support software and live chat platform operators
• Game content providers whose certified games are offered through the batpk Platform

All service providers are contractually required to process your data only as instructed by batpk, to maintain appropriate security measures, and to comply with applicable data protection law.

6.2 Regulatory & Legal Disclosure

batpk may be required to disclose your personal data to government authorities, regulatory bodies, or law enforcement agencies where required by Philippine law or pursuant to a valid court order. This includes disclosures to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent authorities. batpk will notify you of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of batpk's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material change in the processing of your data that results from it.

6.4 With Your Consent

batpk may share your data with additional third parties in circumstances not described above where you have given your express prior consent to such sharing.

07 Data Retention

batpk retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations. 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 compliance with PAGCOR recordkeeping requirements and anti-money laundering regulations.
• Transaction and financial records: Retained for a minimum of five (5) years as required under the Anti-Money Laundering Act (AMLA) of the Philippines and its amendments.
• Gameplay and activity data: Retained for three (3) years following the date of the activity, or longer where required for dispute resolution or regulatory audit purposes.
• Customer support communications: Retained for two (2) years from the date of the interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the period of consent and for one (1) year following withdrawal of consent as evidence of the withdrawal.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification. Where anonymized data is retained for analytics purposes, it is no longer considered personal data and is not subject to this Policy.

08 Data Security

batpk implements a range of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the batpk Platform
• Encryption of sensitive data fields at rest within batpk's database infrastructure
• Role-based access controls ensuring that only authorized batpk personnel can access personal data on a need-to-know basis
• Multi-factor authentication requirements for staff accessing data systems
• Regular penetration testing and vulnerability assessments conducted by qualified security professionals
• Documented incident response procedures aligned with NPC breach notification requirements
• Ongoing staff training on data privacy obligations and secure data handling practices

In the event of a personal data breach that poses a real risk of serious harm to affected players, batpk will notify the National Privacy Commission and affected individuals within the timeframe prescribed by the Data Privacy Act and NPC Circular No. 16-03.

09 Cookies & Tracking Technologies

batpk uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, maintain your session, and gather analytics data that helps us improve the user experience. The following types of cookies are used:

9.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be disabled. They are used to maintain your login session, remember your responsible gaming settings, and ensure Platform security. No personal data collected by these cookies is used for marketing purposes.

9.2 Functional Cookies

Functional cookies allow the Platform to remember choices you have made, such as your preferred language, last-used payment method, and lobby view settings. Disabling these cookies may affect the usability of certain features.

9.3 Analytics Cookies

batpk uses analytics tools to understand how players interact with the Platform — including which games are most popular, where players encounter friction, and how the Platform performs across different devices and connection types in the Philippines. Analytics data is aggregated and does not identify individual players for marketing purposes.

9.4 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Note that disabling cookies may affect the functionality of certain parts of the batpk Platform. Strictly necessary cookies cannot be disabled without affecting your ability to use the Platform.

10 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by batpk:

• Right to be Informed: You have the right to be told what personal data batpk collects about you and how it is used — which is the primary purpose of this Policy.
• Right of Access: You may request a copy of the personal data batpk holds about you, along with information about how it has been used and to whom it has been disclosed.
• Right to Rectification: If any of your personal data held by batpk is inaccurate or incomplete, you have the right to request its correction. You may update most profile information directly through your account settings.
• Right to Erasure or Blocking: Subject to batpk's legal retention obligations, you may request the deletion or blocking of personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and there is no other legal basis for processing.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interest. Where you object, batpk will cease processing for that purpose unless compelling legitimate grounds override your interests.
• Right to Data Portability: You may request that batpk provide your personal data in a structured, commonly used, and machine-readable format for transfer to another service provider where technically feasible.
• Right to Damages: You have the right to be indemnified for any damages sustained as a result of batpk's inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data, in accordance with RA 10173.
• Right to Lodge a Complaint: If you believe batpk has violated your data privacy rights, you may lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact the batpk Data Protection Officer using the contact details in Section 14. batpk will respond to all data subject requests within fifteen (15) business days of receipt, and will complete the requested action or provide a reasoned explanation where a request cannot be fulfilled within thirty (30) days.

11 Minors

The batpk Platform is strictly intended for individuals who are at least twenty-one (21) years of age in accordance with PAGCOR guidelines on online gambling in the Philippines. batpk does not knowingly collect personal data from persons under the age of 21. Age verification is a mandatory component of the account registration and KYC process.

If batpk discovers or is notified that personal data has been collected from an individual who is under 21 years of age, that data will be deleted promptly, the account will be permanently closed, and any funds associated with the account will be handled in accordance with applicable regulatory requirements.

If you believe that a minor has accessed the batpk Platform using your account or device, please contact batpk support immediately and change your account credentials without delay.

12 International Data Transfers

batpk's primary data processing infrastructure is located within or proximate to the Philippines. Where personal data is transferred to service providers operating in other countries — for example, cloud infrastructure providers or internationally based game content suppliers — batpk ensures that such transfers are conducted in accordance with the Data Privacy Act of 2012 and NPC guidance on cross-border data flows.

Transfers to third countries are protected through one or more of the following safeguards:

• Contractual clauses that impose data protection obligations on the receiving party equivalent to those applicable under Philippine law
• The receiving party's adherence to internationally recognized data protection frameworks or certifications
• NPC-approved transfer mechanisms where applicable

In all cases, international transfers of Philippine residents' personal data are governed by obligations that ensure an adequate level of protection for your data regardless of where it is processed.

13 Changes to This Policy

batpk may update this Privacy Policy from time to time to reflect changes in our data processing practices, updates to Philippine data privacy law, or changes to the services we offer. When material changes are made, we will notify registered players via email to their registered address or through a prominent notice on the Platform. The revised Policy will display an updated effective date at the top of this page.

Your continued use of the batpk Platform following the effective date of an updated Privacy Policy constitutes your acknowledgment of, and where applicable your consent to, the changes described. We recommend reviewing this Policy periodically to stay informed of how batpk handles your data.

Previous versions of this Policy are available upon request from the batpk Data Protection Officer.

14 Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by batpk, please contact the batpk Data Protection Officer. All communications should be directed to the following contact point:

• Data Protection Officer — batpk
• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please use "Data Privacy Request" or "Privacy Policy Inquiry" in your subject line to ensure prompt routing to the DPO team.

batpk will acknowledge all privacy-related communications within five (5) business days. For formal data subject requests (access, correction, deletion, portability), please include your registered username and a description of your request so that we can verify your identity and process your request efficiently.

If you are not satisfied with batpk's response to a privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. The NPC accepts complaints from data subjects whose rights under RA 10173 have not been adequately addressed by the personal information controller.