ber100 Privacy Policy

1. Data Controller

ber100 ("ber100," "we," "us," or "our") is the data controller responsible for the personal information collected through the ber100 online gaming platform at ber100.net and all associated services (collectively, the "Platform"). As data controller, ber100 determines the purposes and means of processing your personal data in accordance with applicable Philippine data privacy laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

This Privacy Policy applies to all personal data collected from registered players, visitors, and prospective users of the ber100 Platform, regardless of whether you are located in Metro Manila, Cebu, Davao, Quezon City, Makati, or any other part of the Philippines.

2. Data We Collect

ber100 collects personal data from you in the following categories, depending on how you interact with the Platform:

2.1 Registration & Identity Data

• Full legal name, date of birth, and nationality.
• Government-issued identification number (e.g., Philippine National ID, passport, driver's licence).
• Residential address, city, and province within the Philippines.
• Email address and mobile phone number.
• Username and encrypted password.

2.2 Financial & Transaction Data

• GCash mobile number or PayMaya / Maya account details used for deposits and withdrawals.
• Philippine bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for bank transfer transactions.
• Debit card details (card number is tokenised and never stored in full).
• Transaction history, including deposit amounts, withdrawal requests, and gaming activity in Philippine Peso (₱).

2.3 Technical & Usage Data

• IP address, device type, operating system, and browser type.
• Session duration, pages visited, and features used on the Platform.
• Geolocation data (country and region level) to verify eligibility.
• Log files and error reports generated during your use of the Platform.

2.4 Communications Data

• Records of your interactions with ber100 customer support, including live chat transcripts and email correspondence.
• Responses to surveys, feedback forms, and promotional communications.
• Marketing preferences and communication opt-in / opt-out records.

2.5 Responsible Gaming Data

• Self-exclusion requests, cooling-off periods, and deposit limit settings.
• Responsible gaming assessments and any referrals to support resources.

3. How We Use Your Data

ber100 uses the personal data we collect for the following purposes:

ber100 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by applicable law or regulatory obligation.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012 and applicable regulations, ber100 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with PAGCOR regulations, anti-money laundering laws, tax obligations, and other applicable Philippine legal requirements.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing for direct marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Sharing Your Data

ber100 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 and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya / Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory requirements.
• Game software providers: Licensed game studios and live dealer operators whose games are available on the ber100 Platform, to the extent necessary to provide gameplay services.
• IT and infrastructure providers: Cloud hosting, cybersecurity, and technical support providers who process data on our behalf under strict data processing agreements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or regulatory directive.
• Professional advisers: Legal, accounting, and auditing firms, subject to professional confidentiality obligations.

All third-party service providers who process personal data on behalf of ber100 are required to implement appropriate technical and organisational security measures and to process data only in accordance with ber100's instructions.

6. Cookies & Tracking Technologies

ber100 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how you use the Platform.

6.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function, including session management, login authentication, and security. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits.
• Analytics cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data is aggregated and anonymised where possible.
• Marketing cookies: Used to deliver relevant promotional content to you, subject to your consent. You may opt out at any time via your account settings.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

7. Data Retention

ber100 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and contractual 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 after account closure, in accordance with PAGCOR and AML regulatory requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine tax and AML regulations.
• Customer support records: Retained for three (3) years from the date of the interaction, or longer if required for ongoing dispute resolution.
• Marketing consent records: Retained until you withdraw consent, plus a reasonable period thereafter to demonstrate compliance.
• Technical and usage data: Retained for up to twelve (12) months in identifiable form, after which it is anonymised or deleted.

When personal data is no longer required, ber100 will securely delete or anonymise it in accordance with our data disposal procedures.

8. Data Security

ber100 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ber100 Platform.
• Encryption of sensitive data at rest, including financial account details and identity documents.
• Multi-factor authentication options for player accounts.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Continuous monitoring of the Platform for suspicious activity, fraud, and security incidents.
• A documented data breach response procedure, including notification to the National Privacy Commission (NPC) and affected players within the timeframes required by Philippine law.

9. Your Rights

Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights with respect to your personal data held by ber100:

• Right to be informed: The right to know what personal data ber100 collects, 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 ber100 holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update most of your account information directly through your ber100 account dashboard.
• 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 ber100's legal and regulatory retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to ber100's overriding legitimate grounds.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller, where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe ber100 has processed your personal data in violation of applicable law.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14 of this Policy. ber100 will respond to all verified requests within thirty (30) days, or within such other period as required by applicable law.

10. Minors & Age Restriction

The ber100 Platform is strictly intended for persons who are at least 21 years of age, in accordance with Philippine gaming regulations. ber100 does not knowingly collect personal data from individuals under 21 years old.

If ber100 discovers or is notified that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data, and return any deposited funds in accordance with applicable regulations.

If you are a parent or guardian and believe that a minor has registered on the ber100 Platform, please contact our support team immediately via live chat or at the email address provided in Section 14.

11. International Data Transfers

ber100 primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines — for example, to international game software providers or cloud infrastructure providers — ber100 ensures that such transfers are subject to appropriate safeguards, including:

• Data processing agreements incorporating standard contractual clauses approved by the National Privacy Commission.
• Transfers only to jurisdictions that provide an adequate level of data protection as recognised under Philippine law.
• Technical and organisational security measures equivalent to those applied within the Philippines.

ber100 will not transfer your personal data internationally in a manner that reduces the protections afforded to you under the Data Privacy Act of 2012.

12. Third-Party Links

The ber100 Platform may contain links to third-party websites or services for informational purposes. ber100 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 personal data collected by ber100 through the ber100 Platform.

13. Policy Amendments

ber100 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes, we will post a notice on the Platform and update the "Last Updated" date at the top of this page.

Where required by applicable law, we will seek your consent before implementing material changes that affect how we process your personal data. Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acknowledgement of the changes.

We encourage you to review this Privacy Policy periodically to stay informed about how ber100 protects your personal information.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by ber100, please contact our Data Protection Officer (DPO):

• Live Chat: Available 24/7 from your ber100 account dashboard — the fastest way to reach us.
• Email: [email protected]
• Data Protection Officer: [email protected]

All email addresses above are displayed as plain text and are not clickable links. Please copy the address manually into your email client.

If you are not satisfied with ber100's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent authority responsible for enforcing the Data Privacy Act of 2012.