free200 Privacy Policy

1 Introduction

free200 ("we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who access or use the free200 platform at free200.org ("Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

This Privacy Policy applies to all personal data collected through the free200 Platform, including data collected during account registration, identity verification, gameplay, financial transactions, customer support interactions, and use of our website and mobile applications.

This Privacy Policy should be read together with the free200 Terms and Conditions, which govern your use of the Platform and are incorporated herein by reference.

2 Data Controller

free200 is the personal information controller responsible for the personal data collected through the Platform. As the data controller, free200 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data privacy laws.

For all privacy-related inquiries, requests, and complaints, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3 Personal Data We Collect

free200 collects the following categories of personal data:

3.1 Identity and Registration Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification purposes);
• Nationality and country of residence;
• Username and account credentials (password stored in hashed form only);
• Government-issued identification documents (e.g., Philippine passport, SSS ID, UMID, driver's license) submitted during KYC verification.

3.2 Contact Data

• Email address;
• Mobile phone number;
• Residential address (city, province, postal code).

3.3 Financial Data

• GCash or PayMaya account number (mobile number associated with the e-wallet);
• Bank account name and number for bank transfer transactions (BPI, BDO, Metrobank, UnionBank);
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment methods used.

3.4 Gaming and Activity Data

• Game history, including games played, wagers placed, outcomes, and winnings;
• Bonus and promotion usage history;
• Session duration and login timestamps;
• Responsible gaming tool settings (deposit limits, self-exclusion status, etc.).

3.5 Technical and Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type;
• Cookies and similar tracking technologies (see Section 8);
• Platform access logs and error reports.

3.6 Communications Data

• Records of your communications with free200 customer support, including live chat transcripts and email correspondence;
• Feedback, complaints, and survey responses submitted to free200.

4 How We Collect Your Data

free200 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions;
• Automatically — through cookies, web beacons, and server logs when you access and use the Platform;
• From third-party service providers — including identity verification services, payment processors, and fraud detection providers, where necessary to operate the Platform and comply with legal obligations;
• From publicly available sources — where permitted by law, for the purpose of verifying information you have provided or for fraud prevention.

5 How We Use Your Personal Data

free200 uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your free200 account, including processing your registration and verifying your identity and age;
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the features and functionality of the Platform;
• Legal compliance: To comply with applicable Philippine laws and regulations, including KYC requirements, anti-money laundering obligations, and data privacy laws;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform;
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Communications: To send you account-related notifications, transaction confirmations, and, where you have consented, promotional communications about free200 offers and updates;
• Platform improvement: To analyze usage patterns, conduct research, and improve the performance, security, and features of the Platform;
• Legal proceedings: To establish, exercise, or defend legal claims involving free200.

6 Legal Basis for Processing

free200 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform our contract with you — specifically, to operate your free200 account, process transactions, and deliver the services you have requested;
• Legal obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, KYC requirements, and gaming regulations;
• Legitimate interests: Processing is necessary for free200's legitimate interests, including fraud prevention, platform security, and improving our services, provided such interests are not overridden by your rights and freedoms;
• Consent: Where processing is based on your consent — for example, for marketing communications — you have the right to withdraw that consent at any time by contacting free200 support or updating your account preferences.

7 Sharing Your Personal Data

free200 does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

7.1 Service Providers. free200 engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank), identity verification providers, cloud hosting providers, customer support platforms, and analytics services. These providers are contractually bound to process your data only on free200's instructions and in compliance with applicable data privacy laws.

7.2 Game Providers. Certain game data may be shared with our licensed game content providers to the extent necessary to deliver game functionality, resolve disputes, and ensure fair play. Game providers are required to maintain appropriate data security standards.

7.3 Regulatory and Law Enforcement Authorities. free200 may disclose your personal data to Philippine government agencies, regulatory bodies, or law enforcement authorities where required by law, court order, or regulatory directive, including for anti-money laundering reporting obligations.

7.4 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of free200's assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections. You will be notified of any such transfer in accordance with applicable law.

8 Cookies and Tracking Technologies

8.1 What Are Cookies. Cookies are small text files placed on your device when you visit the free200 Platform. They allow us to recognize your device, remember your preferences, and collect information about how you use the Platform.

8.2 Types of Cookies We Use.

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, preferred payment method, and responsible gaming tool configurations.
• Analytics Cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Security and Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats on the Platform.

8.3 Managing Cookies. You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the free200 Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate securely.

9 Data Security

free200 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 free200 Platform;
• Encrypted storage of sensitive personal data, including hashed and salted password storage;
• Access controls limiting access to personal data to authorized free200 personnel on a strict need-to-know basis;
• Regular security audits and penetration testing conducted by independent security professionals;
• PCI-DSS compliant payment processing — free200 does not store full payment credentials on its own servers;
• Incident response procedures to detect, contain, and notify affected individuals of any personal data breach in accordance with NPC requirements.

10 Data Retention

free200 retains your personal data 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 and identity data: Retained for a minimum of five (5) years after account closure, as required by anti-money laundering regulations and gaming compliance obligations;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Customer support records: Retained for three (3) years from the date of the last interaction;
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter for compliance documentation purposes;
• Technical logs: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, free200 will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless further retention is required by law or for the establishment, exercise, or defense of legal claims.

11 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by free200:

• Right to be Informed: The right to be informed of how your personal data is collected, used, and processed, as set out in this Privacy Policy;
• Right of Access: The right to request a copy of the personal data free200 holds about you and information about how it is being processed;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by free200;
• 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 free200'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 legitimate interests;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format 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 your data privacy rights have been violated.

To exercise any of the above rights, please contact free200's Data Protection Officer using the contact details in Section 14. free200 will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with NPC guidelines.

12 Children's Privacy

The free200 Platform is strictly intended for individuals aged 21 years and above. free200 does not knowingly collect personal data from individuals under the age of 21. If free200 becomes aware that personal data has been collected from an individual under 21, the associated account will be immediately suspended, all deposited funds will be returned to the originating payment method, and the personal data will be deleted in accordance with our data disposal procedures.

If you are a parent or guardian and believe that a minor has registered on the free200 Platform, please contact our support team immediately at the contact details provided in Section 14.

13 Changes to This Privacy Policy

free200 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. Where changes are material, free200 will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the free200 Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how free200 protects your personal data.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by free200, please contact our Data Protection Officer. Our support team is available 24 hours a day, 7 days a week.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been adequately addressed by free200.