free200 Privacy Policy

1Who We Are

This Privacy Policy is issued by free200 ("free200," "Company," "we," "us," "our"), the operator of the online gaming platform available at free200.club. Free200 is a PAGCOR-licensed online casino and sports betting platform serving Filipino players across the Philippines, including Manila, Cebu, Davao, Quezon City, Makati, and all regions of the archipelago.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act 10173, "DPA"), free200 acts as the Personal Information Controller with respect to the personal data of its registered players and website visitors. Free200 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing the Company's data protection practices and ensuring compliance with applicable privacy law.

2Data We Collect

Free200 collects the following categories of personal data from players and visitors:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., PhilSys, UMID, passport, or driver's licence number) collected during account registration and KYC verification.
• Contact Data: Email address, Philippine mobile number, and residential address as provided during registration or account updates.
• Financial Data: GCash account number, PayMaya account details, bank account information (BPI, BDO, Metrobank, or other linked institution), transaction records, and USDT wallet addresses where applicable.
• Account Data: Username, encrypted password hash, account balance, deposit and withdrawal history, bonus activity, game history, session logs, and responsible gaming settings.
• Technical Data: IP address, device identifiers, operating system and browser type, time zone, language preference, and connection type collected automatically when you access the Platform.
• Usage Data: Pages visited, games played, session duration, click behaviour, and feature usage within the free200 Platform.
• Communications Data: Records of your correspondence with free200 customer support, including live chat transcripts and email exchanges.
• Verification Documents: Scanned copies or photographs of government-issued ID documents submitted during KYC verification, and proof of payment method documents where required.

3How We Collect Data

Free200 collects personal data through the following means:

• Direct Collection: Data you provide when registering an account, completing KYC verification, depositing or withdrawing funds, contacting support, or updating your account profile.
• Automated Collection: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar technologies when you access or use the free200 Platform.
• Third-Party Sources: Identity verification and fraud prevention data from third-party KYC service providers; transaction data from GCash, PayMaya, and other payment processors; and publicly available information used for AML screening purposes.

4How We Use Your Data

Free200 uses your personal data for the following purposes:

• To create, verify, and maintain your player account on the free200 platform
• To process deposits, withdrawals, and bonus transactions through GCash, PayMaya, and other accepted payment methods
• To verify your identity and age in compliance with PAGCOR licensing requirements and Philippine AML regulations
• To detect and prevent fraud, money laundering, cheating, and other prohibited conduct
• To provide customer support and respond to your enquiries
• To enforce our Terms & Conditions and Responsible Gaming Policy
• To personalise your gaming experience, including game recommendations based on your play history
• To send transactional communications such as deposit confirmations, withdrawal notifications, and security alerts
• To send promotional communications about free200 bonuses and offers, where you have not opted out
• To comply with legal obligations under Philippine law, including reporting obligations to PAGCOR and AMLC
• To improve the free200 Platform through analytics and product development

5Legal Basis for Processing

Free200 processes your personal data on the following legal bases as recognised under the Philippine Data Privacy Act:

• Performance of Contract: Processing necessary to create and maintain your account, process transactions, and provide the gaming services you have requested.
• Legal Obligation: Processing required for compliance with PAGCOR licensing conditions, AMLC reporting obligations, NPC regulations, and other applicable Philippine law.
• Legitimate Interests: Processing for fraud prevention, platform security, and service improvement where these interests are not overridden by your privacy rights.
• Consent: Where required by law, we will obtain your explicit consent before processing your data, particularly for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6Sharing Your Data

Free200 does not sell your personal data. We may share your data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment Processors: GCash (Mynt), PayMaya (Maya Bank), BPI, BDO, Metrobank, and other payment service providers, to process your financial transactions.
• KYC & Fraud Prevention Providers: Third-party identity verification and fraud detection services that assist free200 in verifying player identities and detecting suspicious activity.
• Game Suppliers: Software providers whose games are hosted on the free200 Platform may receive limited technical data (such as player ID and session tokens) necessary to operate their games.
• Regulatory Authorities: PAGCOR, AMLC (Anti-Money Laundering Council), the NPC, and other Philippine government agencies, where disclosure is required by law or court order.
• IT & Infrastructure Providers: Cloud hosting, security, and technical service providers who process data on free200's behalf under binding data processing agreements.
• Professional Advisors: Lawyers, auditors, and accountants, subject to professional confidentiality obligations, where necessary for legitimate business purposes.

7International Transfers

Some of free200's service providers and game suppliers are located outside the Philippines. Where personal data is transferred to a recipient in a country that does not provide an equivalent level of data protection, free200 will implement appropriate safeguards such as standard contractual clauses or will ensure that the transfer is otherwise permitted under the DPA. By using the free200 Platform, you acknowledge that your data may be transferred internationally as described in this section.

8Cookies & Tracking Technologies

Free200 uses the following types of cookies and similar technologies on the Platform:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in to your free200 account and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Store your preferences such as language setting, remembered username, and game display options to improve your experience on return visits.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate and use the Platform. This helps free200 identify areas for improvement.
• Marketing Cookies: Used to measure the effectiveness of free200's promotional campaigns. These are only set with your consent where required.

You may manage non-essential cookies through your browser's settings or privacy tools. Note that disabling certain cookies may affect the functionality of your free200 account.

9Data Retention

Free200 retains personal data for as long as necessary to fulfil the purposes set out in this Policy, subject to the following specific retention periods:

• Active Account Data: Retained for the duration of your account registration plus a further five (5) years after account closure, to comply with PAGCOR record-keeping requirements and Philippine tax law.
• KYC Documents: Retained for a minimum of five (5) years following account closure, as required by AMLC regulations.
• Transaction Records: Retained for a minimum of five (5) years, in compliance with AMLC and Bureau of Internal Revenue (BIR) requirements.
• Support Communications: Retained for three (3) years after the last interaction, for quality assurance and dispute resolution purposes.
• Technical and Usage Data: Retained in identifiable form for up to twelve (12) months, after which it is anonymised or deleted.

When retention periods expire, personal data is securely deleted using industry-standard methods or permanently anonymised so that it can no longer be linked to any individual.

10Your Rights

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

• Right to be Informed: The right to know what personal data we collect, how we use it, and with whom we share it — which is what this Policy provides.
• Right to Access: The right to request a copy of the personal data free200 holds about you, and information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data. You can update most account information directly through your free200 account settings.
• 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 our legal retention obligations.
• Right to Object: The right to object to processing based on legitimate interests, including direct marketing. If you opt out of marketing communications, we will stop sending them.
• 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: If you believe your data rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact free200 support via live chat or email at [email protected]. We will respond to verified requests within thirty (30) calendar days.

11Children's Privacy

The free200 Platform is strictly for individuals aged 21 years and older. Free200 does not knowingly collect personal data from persons under 21 years of age. Age verification is performed during account registration and before any withdrawal is processed. If free200 becomes aware that personal data has been collected from a person under 21, that account will be closed immediately and any data collected will be deleted, except where retention is required by law.

12Security

Free200 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit AES encryption for data stored at rest
• TLS 1.3 encryption for all data transmitted between your browser and the free200 Platform
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular penetration testing and security audits by independent cybersecurity firms
• Multi-factor authentication for all internal systems with access to player data
• Documented incident response procedures for data breach detection, containment, and NPC notification

While free200 takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the security of your free200 login credentials and for notifying us immediately if you suspect unauthorised access to your account.

13Changes to This Policy

Free200 may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable law. Material changes will be communicated to registered players via email or a notice displayed prominently on the free200 Platform at least seven (7) days before taking effect. The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the Platform after the effective date of any update constitutes your acceptance of the revised Policy.

14Contact & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data rights, or need to report a potential data protection concern, please contact the free200 Data Protection Officer:

Email: [email protected]
Subject line: Privacy / Data Rights Request
Response time: Within 30 calendar days of verified request

You also have the right to contact the National Privacy Commission of the Philippines directly if you believe your data rights have not been respected.