free200 Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") is issued by free200 ("free200," "we," "us," "our"), the operator of the online gaming platform accessible at free200.net and any associated mobile applications or digital services (collectively, the "Platform").

free200 is committed to protecting the privacy and personal data of all users ("Player," "User," "you") who access or use the Platform. This Policy describes what personal data we collect, why we collect it, how we use and share it, how long we retain it, and what rights you have as a data subject under Philippine law.

By registering for and using the free200 Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, please do not use the Platform.

2. Personal Data We Collect

free200 collects the following categories of personal data from Users:

Identity and Contact Data:

• Full legal name as it appears on a government-issued identification document
• Date of birth (used to verify the 21+ age requirement)
• Email address
• Philippine mobile number
• Residential address (city, province, region)
• Government-issued ID type and number (for KYC verification)

Financial Data:

• GCash or PayMaya mobile number linked to your account
• Bank account details (for bank transfer withdrawals via BPI, BDO, Metrobank, UnionBank)
• Transaction history including deposit amounts, withdrawal amounts, and dates

Usage and Technical Data:

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type
• Session duration and login timestamps
• Game history including games played, bet amounts, win/loss records
• Platform navigation behavior and clickstream data

Communications Data: Records of live chat sessions, support email correspondence, and any feedback or complaint submissions you make to free200.

3. How We Collect Your Data

free200 collects personal data through the following means:

• Direct collection: Data you provide voluntarily when you register an account, complete identity verification (KYC), make a deposit or withdrawal, contact support, or respond to a promotion.
• Automated collection: Data collected automatically through your use of the Platform, including via cookies, web beacons, server logs, and similar tracking technologies as described in Section 9 of this Policy.
• Third-party sources: Data received from payment providers (GCash, PayMaya, banks) to verify transaction status; identity verification service providers for KYC purposes; fraud detection and anti-money laundering screening services.

free200 does not purchase personal data from third-party data brokers or marketing list providers.

4. 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 login authentication and account security.
• Identity and age verification: To verify that you meet the 21+ age requirement and to confirm your identity as required by Philippine gaming regulations and our KYC obligations.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers in Philippine Pesos (PHP).
• Legal and regulatory compliance: To comply with applicable Philippine laws including the Anti-Money Laundering Act (RA 9160 as amended), relevant PAGCOR regulations, and the Data Privacy Act (RA 10173).
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, bonus abuse, unauthorized account access, and other prohibited conduct.
• Responsible gaming: To monitor gaming behavior and enforce responsible gaming tools such as deposit limits, loss limits, session timers, and self-exclusion where requested or required.
• Customer support: To respond to your inquiries, process complaints, and provide technical assistance.
• Platform improvement: To analyze usage patterns and improve the functionality, content, and user experience of the free200 Platform.
• Marketing communications: Where you have given separate consent, to send you information about free200 promotions, bonuses, and new game releases. You may withdraw marketing consent at any time via your account settings or by contacting support.

free200 does not use your personal data for automated decision-making that produces legal effects concerning you, except where required for fraud screening or AML compliance, in which case you have the right to request human review of any adverse decision.

5. Legal Basis for Processing

Under Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, free200 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the free200 Terms & Conditions and service agreement you entered into upon registration (e.g., account creation, payment processing).
• Legal obligation: Processing required to comply with applicable Philippine laws and regulatory requirements (e.g., AML reporting, KYC, PAGCOR compliance).
• Legitimate interests: Processing necessary for free200's legitimate interests in fraud prevention, platform security, and responsible gaming enforcement, where those interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for optional marketing communications and non-essential cookies.

6. Data Sharing and Disclosure

free200 does not sell your personal data to third parties. We share personal data only in the following limited circumstances:

• Payment processors: GCash (Mynt — Globe Fintech Innovations, Inc.), PayMaya (Maya Philippines, Inc.), BPI, BDO, Metrobank, UnionBank, and other payment service providers, solely for the purpose of processing your financial transactions.
• Identity verification providers: Third-party KYC and identity verification services engaged by free200 to fulfill age verification and AML compliance obligations.
• Game providers: Game studios (e.g., PG Soft, Pragmatic Play, Jili Games) receive anonymized session and bet data necessary to deliver game content. No personally identifiable data is shared with game providers beyond what is technically necessary.
• Regulatory authorities: Philippine regulatory bodies including PAGCOR and the Anti-Money Laundering Council (AMLC) where disclosure is required by law or pursuant to a valid legal order.
• Law enforcement: Philippine law enforcement authorities where required by a valid court order, warrant, or applicable legal obligation.
• Corporate successors: In the event of a merger, acquisition, or sale of substantially all of free200's assets, your personal data may be transferred to the successor entity, subject to equivalent privacy protections.

Any third party with whom free200 shares personal data is contractually bound to process that data only for the specific purpose for which it was shared and in accordance with applicable data protection law.

7. Data Retention

free200 retains your personal data only for as long as necessary to fulfill the purposes described in this Policy and to comply with applicable legal and regulatory retention requirements. Specific retention periods are as follows:

• Account and identity data: Retained for the duration of your account plus a minimum of five (5) years following account closure, as required by AML regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of transaction.
• Support communications: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained until consent is withdrawn, plus a reasonable period to demonstrate compliance.

When personal data is no longer required, free200 will securely delete or anonymize it in accordance with industry-standard data disposal practices.

8. 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:

• 256-bit SSL/TLS encryption for all data transmitted between your device and free200 servers
• Passwords stored using industry-standard one-way cryptographic hashing — plain-text passwords are never stored
• Two-factor authentication (2FA) available for all accounts
• Regular penetration testing and vulnerability assessments by independent security professionals
• Role-based access controls limiting internal staff access to personal data on a need-to-know basis
• Intrusion detection systems and real-time anomaly monitoring

In the event of a personal data breach that is likely to result in harm to affected data subjects, free200 will notify the National Privacy Commission (NPC) and affected Users within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

9. Cookies and Tracking Technologies

free200 uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device. We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function (e.g., session authentication, security tokens). These cannot be disabled.
• Functional cookies: Remember your preferences such as language and display settings.
• Analytics cookies: Collect anonymized data about how Users navigate the Platform, used to improve functionality and content. No personally identifiable data is transmitted to analytics services.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use the core features of the free200 Platform, but may affect certain personalization features.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules, you have the following rights with respect to your personal data held by free200:

• Right to be informed: The right to know that free200 is collecting and processing your personal data and the purposes for which it is being processed.
• Right of access: The right to request a copy of the personal data free200 holds about you.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected.
• Right to erasure ("Right to be Forgotten"): The right to request deletion of your personal data, subject to free200's legal retention obligations.
• Right to data portability: The right to receive your personal data in a structured, commonly used format and transmit it to another controller where technically feasible.
• Right to object: The right to object to processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact free200's Data Protection Officer (DPO) at the contact details in Section 13. Requests will be acknowledged within 72 hours and resolved within 30 days. If you are not satisfied with free200's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

11. Children's Privacy

The free200 Platform is strictly intended for users who are 21 years of age or older. free200 does not knowingly collect personal data from individuals under 21 years of age. If free200 discovers that personal data has been collected from a minor, the account will be immediately closed, all data securely deleted, and any deposited funds returned to the verified payment source. If you believe a minor has registered on the Platform, please contact free200 support immediately.

12. Changes to This Privacy Policy

free200 may update this Privacy Policy periodically to reflect changes in our data practices, legal requirements, or Platform features. Material changes will be communicated to registered Users via the email address or mobile number on their account, or via a prominent notice on the Platform, at least seven (7) days before the changes take effect. The "Last Updated" date at the top of this Policy will always reflect the most recent revision. Continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.

13. Contact — Data Protection Officer

For any questions, concerns, requests to exercise your data subject rights, or to report a suspected data breach, please contact the free200 Data Protection Officer:

• Email: support [at] free200.net (subject line: "Data Privacy Request")
• Live Chat: Available 24/7 through the free200 Platform
• Response Time: Acknowledgment within 72 hours; full resolution within 30 days