Personal Data Processing Policy

1. Purpose and Scope

This Personal Data Processing Policy (hereinafter, the "Policy") establishes the rules and procedures governing the collection, processing, storage, transfer, and protection of personal data of users by Caecus N.V., operator of the 1xBet website, in accordance with applicable laws and regulations of Vietnam, including Decree No. 13/2023/ND-CP (Personal Data Protection), Law on Cyberinformation Security (No. 86/2015/QH13), and related legislation.

This Policy applies to all personal data collected and processed from individuals accessing, using, or interacting with the 1xBet website and related services, regardless of method or device of access.

2. Definitions

Terms used in this Policy are as defined in Article 3 of Decree No. 13/2023/ND-CP and other relevant Vietnamese legal instruments:

• Personal data: Information in the form of symbols, letters, numbers, images, sounds, or equivalents that are associated with a particular individual, which enables the identification of that individual.
• Data subject: An individual whose personal data is collected, held, and processed.
• Processing of personal data: Any operation or set of operations performed upon personal data, including collection, storage, editing, use, disclosure, transfer, provision, sharing, or deletion.

3. Legal Basis for Processing

Processing of personal data is performed on the basis of the following legal grounds under Vietnamese law:

• Consent granted by the data subject in accordance with Article 16 of Decree No. 13/2023/ND-CP, except where permitted without consent by law.
• Compliance with obligations under Vietnamese legal and regulatory requirements concerning gambling, anti-money laundering, consumer protection, taxation, or other applicable laws.

4. Categories of Personal Data Collected

Depending on the nature of the relationship and services provided, the Operator may collect the following categories of personal data:

• Identity data: full name, date of birth, nationality, identification/passport number, address.
• Contact data: telephone number, email address.
• Account data: username, password, account identifiers.
• Payment and financial data: payment instrument details, bank account information, transaction history.
• Gambling and activity data: betting history, gaming preferences, transaction records.
• Technical and device data: IP address, browser type, operating system, cookies, location data.
• Sensitive data (if and where applicable): data revealing criminal record, biometric data, only as permitted or required by law.

5. Purposes of Personal Data Processing

• Provision and operation of the gambling and gaming services.
• Verification of identity and age in compliance with Decree No. 03/2017/ND-CP, Decree No. 06/2017/ND-CP and relevant regulations.
• Processing of payments, prevention of fraud, anti-money laundering activities.
• Compliance with legal and regulatory requirements.
• Personalization of user experience and functionalities.
• Provision of customer support and communication regarding the services.
• Statistical and analytical purposes as allowed by law.

6. Data Subject Rights

Data subjects are entitled to exercise the rights provided under Articles 11-13 of Decree No. 13/2023/ND-CP, including:

• Right to be informed about the purpose and method of processing personal data;
• Right to access and request correction or updating of personal data;
• Right to withdraw consent at any time, except for data processing required by law or for contract performance;
• Right to request deletion of personal data (with lawful exceptions);
• Right to request restriction or objection to specific types of processing;
• Right to file complaints with competent Vietnamese authorities regarding the processing of personal data.

To exercise these rights, data subjects may contact the Operator using the contact methods set out in section 11 of this Policy.

7. Data Retention and Storage

Personal data is stored for the period strictly necessary to fulfill the processing purposes described above, or as otherwise required by Vietnamese law. Pursuant to Article 26 of Decree No. 13/2023/ND-CP, all personal data collected from data subjects in Vietnam is required to be stored onshore within the territory of Vietnam.

Upon expiry of the retention period or following a data subject's valid request for deletion (unless a legal retention obligation applies), the Operator will securely delete or anonymize the personal data.

8. Cookies and Similar Technologies

The Operator uses cookies and similar technologies on the website. Cookies may be used for the following purposes:

• Strictly necessary (essential) cookies: required for the operation of the website and core services.
• Analytical/performance cookies: assessment of visitor numbers, usage patterns, and website performance.
• Targeting/advertising cookies: delivery of tailored content or advertisements.
• Third-party cookies: cookies set by authorized third parties.

Consent for the use of non-essential cookies is obtained in accordance with Art. 16 of Decree No. 13/2023/ND-CP and Art. 17 of the Law on Cyberinformation Security. Users have the right to refuse or withdraw their consent to cookies at any time, and can manage cookie preferences by using the relevant cookie management features on the website.

9. Data Transfer to Third Parties

Personal data may only be disclosed or transferred to third parties (including cross-border transfers) with the explicit consent of the data subject, except as otherwise required or permitted by Vietnamese law. For any cross-border transfer of personal data, notification to the Ministry of Public Security is undertaken in accordance with Article 25 of Decree No. 13/2023/ND-CP. Any third party receiving personal data must ensure a level of protection equivalent to that under Vietnamese law.

10. Data Security

The Operator implements technical and organizational measures to ensure the safety and confidentiality of personal data, and to prevent unauthorized access, loss, or disclosure, as required by Vietnamese law.

11. Data Protection Officer (DPO)

Where required under Article 42 of Decree No. 13/2023/ND-CP, the Operator appoints a Data Protection Officer (DPO). Data subjects may contact the DPO or designated data protection representative for any inquiry regarding data processing, data subject rights, or complaints, via the following means:

• Email: [email protected]
• Telephone: +441273256987
• Postal address: Chuchubiweg 17, Willemstad, Curaçao
• Live chat: available 24/7 through the website
• Telegram: https://t.me/xBetConsultbot_bot or Vn1xbetOfficial

12. Complaint Handling

If a data subject believes that their personal data has been processed unlawfully or in breach of this Policy, they may submit a complaint to the Operator using any of the contact details listed above. Complaints will be acknowledged and processed in accordance with the requirements of Vietnamese law, with a recommended response timeframe of within 15 working days. If the data subject does not accept the Operator’s resolution, a complaint may be submitted to the Department of Cybersecurity and High-Tech Crime Prevention (A05), Ministry of Public Security, 44 Yet Kieu, Hoan Kiem, Hanoi, Vietnam.

13. Amendments

This Policy may be updated to ensure ongoing compliance with Vietnamese legal requirements or to reflect changes in processing activities. The date of the latest revision is indicated below. Material changes will be communicated by publication on the website.

14. Legal and Regulatory Disclosures

• Minimum age for participation: 18 years (betting); 21 years (casino)
• Participation in gambling for minors is prohibited by law. Play responsibly.
• This website is not licensed for physical establishment operation in Vietnam. For any engagement in gambling activities, users are required to comply with all applicable Vietnamese laws and restrictions.

Date of last revision: July 14, 2026