be100 Privacy Policy

1.Introduction

be100 ("be100," "we," "us," or "our") operates the online gaming platform accessible at be100.vip. We are committed to protecting the privacy and personal data of all players, visitors, and users ("you") of the be100 Platform in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations.

This Privacy Policy describes what personal information be100 collects, why we collect it, how we use and protect it, with whom we may share it, and what rights you have in relation to your personal data. By registering on or using the be100 Platform, you acknowledge that you have read and understood this Privacy Policy.

be100 acts as the Personal Information Controller (as defined under the DPA) with respect to the personal data of its players and users. Our designated Data Protection Officer ("DPO") can be contacted using the details provided in Section 15 of this Policy.

2.Personal Data We Collect

be100 collects the following categories of personal data:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., PhilSys National ID, driver's license, passport, SSS/UMID/PRC ID).
• Contact Data: Email address, Philippine mobile number, and residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, Makati).
• Account Data: Username, encrypted password, account preferences, and communication settings.
• Financial Data: Payment method details (e.g., GCash account reference, PayMaya/Maya reference, bank account details for BPI, BDO, UnionBank, Metrobank, Landbank, PNB, or Security Bank), transaction history, deposit and withdrawal records.
• Gaming Data: Game history, wagering activity, session duration, win/loss records, and bonus usage.
• Technical Data: IP address, device type, browser type and version, operating system, time zone, and cookies or similar tracking identifiers.
• Usage Data: Pages visited, features used, click-stream data, and interaction logs on the be100 Platform.
• Communications Data: Records of your correspondence with be100 customer support, including live chat transcripts and email exchanges.
• Responsible Gaming Data: Self-exclusion requests, deposit limit settings, cool-off period activations, and any information you provide in connection with responsible gaming tools.

3.How We Collect Your Data

be100 collects personal data through the following means:

• Direct Interactions: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or use any feature of the be100 Platform.
• Automated Technologies: When you access the Platform, we automatically collect Technical Data and Usage Data through cookies, web beacons, server logs, and similar technologies.
• Third-Party Sources: We may receive data from identity verification providers, payment processors, fraud prevention services, and regulatory bodies as required by law.
• Publicly Available Sources: In limited circumstances, we may supplement your data with information from publicly available sources for fraud prevention or AML compliance purposes.

4.How We Use Your Personal Data

be100 uses your personal data for the following purposes:

• To create, verify, and manage your be100 account.
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP).
• To verify your identity and age (21+) in compliance with PAGCOR requirements and Philippine law.
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities.
• To provide customer support and respond to your inquiries.
• To personalize your gaming experience and deliver relevant promotions (subject to your marketing preferences).
• To operate and improve the be100 Platform, including analyzing usage patterns and fixing technical issues.
• To comply with legal and regulatory obligations, including AML reporting requirements under Republic Act No. 9160 (Anti-Money Laundering Act).
• To administer responsible gaming tools, including self-exclusion and deposit limit enforcement.
• To send you transactional communications, security alerts, and (where you have opted in) promotional messages.

5.Legal Basis for Processing

Under the Data Privacy Act of 2012, be100 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you (the Terms & Conditions), including account management and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AML obligations, and tax reporting.
• Legitimate Interests: Processing necessary for be100's legitimate business interests, such as fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Where we rely on your consent (e.g., for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

6.Data Sharing & Disclosure

be100 does not sell or rent your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Processors: GCash, PayMaya/Maya, and Philippine banking partners (BPI, BDO, UnionBank, Metrobank, Landbank, PNB, Security Bank) to process your financial transactions.
• Identity Verification Providers: Third-party KYC and age verification services to confirm your identity and eligibility.
• Game Providers: Software providers whose games are available on the be100 Platform, to the extent necessary to deliver the gaming service.
• Fraud Prevention & Security Services: Providers that help us detect and prevent fraudulent activity and ensure platform integrity.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law.
• Professional Advisers: Lawyers, auditors, and accountants bound by professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to equivalent privacy protections.

All third-party service providers engaged by be100 are contractually required to process your data only on our instructions and in accordance with applicable data protection law.

7.Cookies & Tracking Technologies

be100 uses cookies and similar tracking technologies (such as web beacons and pixel tags) to operate and improve the Platform. Cookies are small text files stored on your device when you visit be100.vip. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting core functionality.
• Functional Cookies: Remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics Cookies: Help us understand how players interact with the Platform by collecting aggregated, anonymized usage data. This information is used solely to improve be100's features and performance.
• Marketing Cookies: Used to deliver relevant promotional content to players who have opted in to marketing communications. These cookies track your activity on the Platform to help us tailor offers to your interests.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the be100 Platform. For detailed guidance on managing cookies in your browser, refer to your browser's help documentation.

8.Data Retention

be100 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AML obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act.
• KYC and Identity Verification Documents: Retained for a minimum of five (5) years following the end of the business relationship.
• Customer Support Communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Technical and Usage Data: Retained for up to twelve (12) months from collection, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, be100 will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

9.Data Security

be100 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and be100.vip.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of the Platform.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

10.Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by be100:

• Right to Be Informed: The right to know what personal data be100 collects about you and how it is used — as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data be100 holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to be100'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 file 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 our Data Protection Officer using the details in Section 15. be100 will respond to all verified requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11.Children's Privacy

The be100 Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gambling regulations. be100 does not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from an underage individual, we will immediately suspend the associated account, delete the data, and, where appropriate, report the matter to the relevant regulatory authority.

If you are a parent or guardian and believe that a minor has registered on the be100 Platform, please contact our support team immediately so that we can take appropriate action.

12.International Data Transfers

be100 primarily stores and processes personal data within the Philippines. In certain circumstances, your data may be transferred to or accessed by service providers located outside the Philippines — for example, game software providers or cloud infrastructure partners operating in other jurisdictions.

Where such transfers occur, be100 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual data processing agreements incorporating standard data protection clauses approved by the National Privacy Commission.

13.Third-Party Links

The be100 Platform may contain references to third-party services (such as payment processors) that operate under their own privacy policies. be100 is not responsible for the privacy practices of any third-party service. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of be100.

14.Updates to This Privacy Policy

be100 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or regulatory requirements. When we make material changes, we will notify registered players via email or 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 page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically. Your continued use of the be100 Platform following the effective date of any update constitutes your acceptance of the revised Policy.

15.Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by be100, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe that be100 has not handled your personal data in accordance with the Data Privacy Act of 2012.