ber100 Privacy
Policy

1 Introduction

ber100 is a PAGCOR-licensed online gaming platform operating in the Philippines. As an operator serving Filipino players, ber100 is subject to the Data Privacy Act of 2012 (Republic Act No. 10173), the regulations and circulars issued by the National Privacy Commission (NPC), and the data protection requirements imposed by PAGCOR on all licensed gaming operators.

We take the protection of your personal information seriously. This Policy sets out transparently what information we collect, why we collect it, how we use and protect it, with whom we may share it, how long we keep it, and what rights you have over it.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable Philippine data protection regulations, ber100 acts as the Personal Information Controller for all personal data processed in connection with the ber100 platform.

ber100 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO at the details provided in Section 15 of this Policy.

3 Personal Data We Collect

ber100 collects personal data that is necessary, adequate, and not excessive for the purposes described in this Policy. The categories of personal data we collect include the following:

4 How We Collect Your Data

ber100 collects personal data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or responding to surveys.
• Automated collection: Technical and usage data collected automatically when you access and interact with the ber100 platform, including through cookies, log files, and session tracking technologies described in Section 8.
• Third-party payment providers: Transaction confirmation and account name data received from GCash, PayMaya, BPI, BDO, and Metrobank in connection with deposit and withdrawal processing.
• Identity verification services: Data returned from authorised identity verification providers during KYC processing, including confirmation of government ID validity.
• PAGCOR and regulatory authorities: In limited circumstances, ber100 may receive data from PAGCOR or other Philippine regulatory authorities in connection with compliance obligations.

5 How We Use Your Personal Data

ber100 uses the personal data it collects for the following specific, legitimate purposes:

To create and manage your ber100 account, authenticate your identity at login, deliver the games and services you request, process your deposits and withdrawals, send OTP codes and transaction notifications, and maintain your account history.

To verify your identity and age (21+) as required by PAGCOR and Philippine law, comply with the Anti-Money Laundering Act (AMLA) and AMLC reporting obligations, and fulfill all other reporting and record-keeping obligations imposed on ber100 as a PAGCOR-licensed operator.

To monitor gaming activity for signs of problem gambling, enforce player-set deposit limits and self-exclusion elections, and ensure that responsible gaming obligations under PAGCOR's framework are met.

To detect and prevent unauthorised account access, fraudulent transactions, money laundering, and other illegal activity. IP addresses, device fingerprints, and session data are used for these security purposes.

To respond to your questions, process complaints, resolve disputes, and improve the quality of our support services. Support interactions are retained for quality assurance and dispute resolution purposes.

Where you have provided explicit consent, ber100 may send you promotional messages about bonuses, new games, and platform updates via your registered mobile number or email. You may withdraw this consent at any time by contacting ber100 support.

Aggregated and anonymised usage data is analysed to improve platform performance, user experience, and game selection. This analysis does not identify individual players.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, ber100 processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to perform our contract with you as a registered ber100 player — account management, game delivery, payment processing.
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws.
• Legitimate interests: Processing conducted for ber100's legitimate business interests where not overridden by your rights — fraud prevention, platform security, service improvement.
• Consent: Where processing is based on your consent — notably for direct marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

ber100 does not sell your personal data. We do not share your personal information with third parties for their independent marketing purposes. We may disclose your personal data in the following limited circumstances:

• Payment providers: GCash, PayMaya, BPI, BDO, and Metrobank — solely to process your deposits and withdrawals. These providers are bound by their own data protection obligations.
• Identity verification partners: Authorised KYC and identity verification service providers engaged to support ber100's age and identity verification obligations under PAGCOR regulations.
• Game content providers: Licensed game software providers who may receive session and gameplay data for game operation, jackpot processing, and RNG audit purposes. These providers are subject to contractual data protection obligations.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where legally required to report or disclose.
• Law enforcement: Philippine law enforcement and judicial authorities where disclosure is required by valid legal process, court order, or applicable law.
• IT and security service providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process personal data on ber100's behalf under strict data processing agreements.

8 Cookies & Tracking Technologies

ber100 uses cookies and similar browser-based technologies on the ber100.org platform. A cookie is a small data file placed on your device when you access a website. Cookies help the platform function properly and enable us to understand how players use our services.

ber100 uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function. These include session cookies that maintain your logged-in state, security tokens, and CSRF protection tokens. These cannot be disabled without breaking platform functionality.
• Functional cookies: Remember your preferences — such as language settings, last-visited game category, and responsible gaming settings you have configured.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate the platform. This data is used to improve platform performance and user experience. No individual player is identified from analytics data.
• Security cookies: Support ber100's fraud detection and account security systems by identifying unusual session behaviour patterns.

ber100 does not use advertising or retargeting cookies. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from using the ber100 platform.

9 Data Retention

ber100 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law and PAGCOR regulations:

• Account and KYC data: Retained for a minimum of five (5) years from account closure, as required by PAGCOR and anti-money laundering regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction in compliance with AMLA record-keeping obligations.
• Gaming records: Retained for a minimum of three (3) years from the date of each session for PAGCOR reporting and dispute resolution purposes.
• Support records: Retained for two (2) years from case closure for dispute resolution and service quality purposes.
• Marketing consent records: Retained until consent is withdrawn plus one (1) year for compliance documentation purposes.

After the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual.

10 Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ber100. To exercise any of these rights, please contact ber100's Data Protection Officer using the details in Section 15.

11 Data Security

ber100 implements technical and organisational security measures appropriate to the nature of the personal data processed and the risks involved. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and ber100's servers.
• Encryption of sensitive data fields at rest in ber100's databases, including passwords (stored as irreversible cryptographic hashes) and payment account identifiers.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Multi-factor authentication requirements for all internal staff accessing systems that process personal data.
• Intrusion detection and security event monitoring systems operating 24/7.
• Regular vulnerability assessments and penetration testing conducted in compliance with PAGCOR's technical security standards.
• Data processor agreements with all third-party providers requiring equivalent security standards.

12 Children's Privacy

The ber100 platform is strictly for individuals aged 21 years and above as required by PAGCOR regulations and Philippine law. ber100 does not knowingly collect personal data from individuals under the age of 21.

If ber100 discovers or is notified that personal data has been collected from an individual under 21, we will immediately suspend the associated account, void any balances accumulated through underage use, and delete the personal data collected, subject to any legal retention obligations that may apply.

Parents or guardians who believe that a minor has registered on ber100 should contact our Data Protection Officer immediately using the contact details in Section 15.

13 International Data Transfers

Some of the third-party service providers used by ber100 — including cloud infrastructure and game software providers — may be located or process data in countries outside the Philippines.

Where personal data is transferred internationally, ber100 ensures that appropriate safeguards are in place to protect your data to the standards required by the Data Privacy Act of 2012, including:

• Executing data processing agreements with all international processors requiring compliance with Philippine data protection standards and, where applicable, equivalent international standards.
• Conducting due diligence on the data protection practices of all international service providers before engagement.
• Limiting the scope of international data transfers to the minimum data necessary for the specific service being provided.

14 Changes to This Privacy Policy

ber100 may update this Privacy Policy from time to time to reflect changes in our data practices, platform services, or applicable law. When material changes are made, we will notify registered players via the email address or mobile number on file, or through a prominent notice on the ber100 platform.

The "Last updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the ber100 platform after the effective date of any update constitutes your acknowledgment of the revised Policy. If you do not agree with any changes, you may request account closure by contacting ber100 support.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or ber100's handling of your personal data, please contact our Data Protection Officer:

• Email: [email protected] (please include "Privacy / DPO" in your subject line)
• Platform: ber100.org
• Regulatory authority: PAGCOR (Philippine Amusement and Gaming Corporation)
• Data privacy regulator: National Privacy Commission (NPC), Philippines

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe that ber100 has processed your personal data in a manner that violates your rights under the Data Privacy Act of 2012.