extbo Privacy Policy

1 Introduction

extbo ("we," "us," "our," or "the Company") is committed to protecting the privacy and personal data of all users of the extbo platform. This Privacy Policy has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

This policy describes in detail how extbo collects, processes, stores, shares, and protects personal data in connection with your use of the extbo online casino platform. It also explains the rights available to you as a data subject under Philippine law and how you can exercise those rights.

We encourage you to read this Privacy Policy carefully and in full. If you have questions about any part of this policy, please contact our Data Protection Officer using the details provided in Section 15.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, extbo is the personal information controller responsible for the personal data collected through the extbo platform. This means extbo determines the purposes and means of processing your personal data.

extbo has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. You may contact the DPO at any time using the contact details in Section 15 of this policy.

3 Personal Data We Collect

extbo collects the following categories of personal data from users of the platform:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — you must be 21 or older)
• Email address and mobile phone number
• Residential address (province, city, barangay)
• Government-issued ID number (e.g., PhilSys, passport, UMID, SSS, driver's license)

3.2 Financial Data

• GCash account number or registered mobile number
• PayMaya / Maya account details
• Bank account details (bank name, account number) for bank transfer transactions
• Transaction history, including deposits, withdrawals, and gaming activity

3.3 Technical and Usage Data

• IP address and approximate geographic location
• Device type, operating system, and browser information
• Pages visited, features used, and time spent on the extbo platform
• Login timestamps and session duration
• Cookies and similar tracking technologies (see Section 9)

3.4 Communications Data

• Records of your communications with extbo customer support
• Feedback, complaints, and survey responses you submit to extbo

4 How We Collect Your Data

extbo collects personal data through the following means:

• Direct collection: Information you provide when registering for an extbo account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the extbo platform, including through cookies, web beacons, and server logs.
• Third-party sources: Information received from payment processors (e.g., GCash, Maya, Philippine banks) in connection with your transactions, and from identity verification service providers used for KYC compliance.
• Regulatory sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with licensing, compliance, or investigation requirements.

5 How We Use Your Personal Data

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

• Account management: To create, maintain, and manage your extbo account, including verifying your identity and age (21+ requirement).
• Service delivery: To provide you with access to extbo's games, process your deposits and withdrawals, and deliver the features of the extbo platform.
• Legal and regulatory compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) requirements, PAGCOR regulations, and the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the extbo platform.
• Customer support: To respond to your inquiries, resolve complaints, and provide assistance through extbo's 24/7 support channels.
• Responsible gaming: To monitor gaming behavior and identify users who may be at risk of problem gambling, in order to offer appropriate support tools and interventions.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your explicit consent to receive such communications.
• Platform improvement: To analyze usage patterns and improve the features, performance, and user experience of the extbo platform.

6 Legal Basis for Processing

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

• Contractual necessity: Processing required to fulfill our obligations to you under the extbo Terms and Conditions, including account management and transaction processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, PAGCOR requirements, and tax reporting.
• Legitimate interests: Processing necessary for extbo's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights.
• Consent: Processing based on your explicit consent, including the sending of marketing communications. You may withdraw your consent at any time without affecting the law fulness of processing carried out before withdrawal.

7 Sharing Your Personal Data

extbo 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:

• Payment processors: GCash, PayMaya (Maya), and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to facilitate deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers engaged to verify your identity and age in compliance with Philippine regulatory requirements.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where disclosure is required by law or court order.
• Technology service providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on extbo's behalf under strict data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants engaged by extbo, subject to professional confidentiality obligations.

All third parties with whom extbo shares personal data are required to handle that data in accordance with applicable Philippine data protection laws and extbo's data processing standards.

8 Data Retention

extbo retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account data: Retained for the duration of your active extbo account, plus a minimum of five (5) years following account closure, in accordance with Philippine AML and gaming regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act of 2001 (Republic Act No. 9160) and its amendments.
• KYC and identity documents: Retained for the duration of your account plus five (5) years following closure, or longer if required by a regulatory investigation or legal proceeding.
• Customer support records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing consent records: Retained for as long as you remain opted in, plus three (3) years following opt-out, as evidence of consent management.

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

9 Cookies and Tracking Technologies

extbo uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the extbo platform. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the extbo platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as your preferred language, display settings, and responsible gaming limits you have set on your extbo account.
• Analytics cookies: Used to collect aggregated, anonymized data about how users interact with the extbo platform, helping us identify areas for improvement. No personally identifiable information is included in analytics reports.
• Marketing cookies: Used only where you have given explicit consent, to deliver relevant promotional content within the extbo platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the extbo platform. For strictly necessary cookies, no opt-out is available as they are required for the platform to operate.

10 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by extbo:

• Right to be informed: The right to know what personal data extbo collects about you, how it is used, and with whom it is shared — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data extbo holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data extbo holds about you.
• 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 extbo's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on extbo's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe extbo has violated your data privacy rights.

To exercise any of the above rights, please contact extbo's Data Protection Officer using the details in Section 15. We will respond to all verified requests within fifteen (15) business days, in accordance with NPC guidelines.

11 Children's Privacy and Age Restriction

The extbo platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. extbo does not knowingly collect personal data from individuals under the age of 21.

If extbo becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and report the matter to the appropriate Philippine regulatory authority where required.

If you are a parent or guardian and believe that a minor has registered on the extbo platform or provided personal data to extbo, please contact our support team immediately at [email protected] so that we can take prompt action.

12 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the extbo platform.
• Encryption at rest for sensitive personal and financial data stored on extbo's servers.
• Role-based access controls ensuring that only authorized extbo personnel with a legitimate business need can access personal data.
• Regular security audits and penetration testing conducted by independent cybersecurity professionals.
• Multi-factor authentication for extbo staff accessing internal systems containing personal data.
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, extbo will notify the National Privacy Commission and affected users within the timeframes prescribed by the Data Privacy Act and NPC regulations.

While extbo takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are also responsible for keeping your extbo login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

13 Third-Party Links

The extbo platform may contain references to third-party services, such as payment processors and identity verification providers. While extbo takes care to work only with reputable partners, we are not responsible for the privacy practices of third-party services.

Each third-party service provider has its own privacy policy governing how they handle your data. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of extbo, particularly your chosen payment provider (e.g., GCash, Maya, or your Philippine bank).

14 Updates to This Privacy Policy

extbo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made, we will notify registered users via email or an in-platform notification prior to the changes taking effect.

The effective date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how extbo protects your personal data.

Your continued use of the extbo platform following the publication of any updates to this Privacy Policy constitutes your acceptance of the revised terms.

15 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by extbo, please contact our Data Protection Officer through the following channels:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 directly within the extbo platform
• Response Time: extbo aims to acknowledge all privacy-related requests within 5 business days and resolve them within 15 business days.

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