Table of Contents
- Who We Are and Scope of This Policy
- What Personal Data We Collect
- How We Collect Your Data
- Why We Use Your Data (Legal Bases)
- How Long We Keep Your Data
- Who We Share Your Data With
- Cookies and Tracking Technologies
- Your Rights as a Data Subject
- Data Security Measures
- Children's Privacy
- Updates to This Privacy Policy
- How to Contact Us
1. Who We Are and Scope of This Policy
100 Panalo ("we," "us," "our") is an online gaming platform operating under the domain 100panalo.app, built specifically for Filipino players. This Privacy Policy explains how we handle the personal data of everyone who visits, registers on, or uses the 100 Panalo platform — including all games such as Bingo, Pusoy, Card Games, Slots, MMA Betting, and Virtual Sports.
We are a data controller under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), which means we are responsible for deciding how and why your personal data is processed. We take that responsibility seriously, and this policy is our commitment to transparency about our data practices.
This policy applies to data collected through our website, mobile interface, customer support channels, and any related services offered by 100 Panalo. By using our platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree to how we handle your data, please stop using the platform.
2. What Personal Data We Collect
We collect the minimum data necessary to provide our services. Here is a clear breakdown of the categories of personal data we process:
| Category | Examples | Purpose |
|---|---|---|
| Identity Data | Full name, date of birth, government-issued ID number | Account verification, KYC compliance, age verification |
| Contact Data | Email address, mobile number, home address | Account communication, support, notifications |
| Financial Data | GCash number, bank account details, card last four digits | Processing deposits and withdrawals in PHP |
| Technical Data | IP address, device type, browser, operating system | Security monitoring, fraud prevention, platform optimization |
| Usage Data | Games played, betting history, login timestamps, session duration | Responsible gaming monitoring, personalization, legal compliance |
| Communication Data | Support chat transcripts, email history | Dispute resolution, quality assurance |
We do not collect sensitive personal information such as biometric data, religious affiliation, health records, or political opinions unless required by law and with your explicit consent.
3. How We Collect Your Data
3.1 Directly From You
Most of the data we hold comes directly from you when you:
- Register and create a 100 Panalo account
- Complete identity verification (KYC) by uploading a valid Philippine government ID
- Make a deposit or request a withdrawal through GCash, Maya, BDO, BPI, or any of our supported payment methods
- Contact our customer support team via email or live chat
- Participate in surveys, promotions, or feedback requests
- Update your account profile or responsible gaming settings
3.2 Automatically From Your Device
When you access 100 Panalo, our servers and analytics tools automatically collect certain technical information including your IP address, browser type, device model, operating system version, pages visited, time spent on each page, and referring URLs. This data helps us detect fraud, maintain platform stability, and improve your gaming experience.
3.3 From Third Parties
We may receive data from identity verification providers (for KYC), payment processors (to confirm transaction status), and our licensed gaming software partners. Any third-party data sharing is governed by data processing agreements that require those parties to handle your data securely and only for the stated purpose.
4. Why We Use Your Data (Legal Bases)
Under the Philippine Data Privacy Act, we must have a lawful basis for processing your personal data. Here are the main reasons we use your information:
4.1 To Perform Our Contract With You
When you register at 100 Panalo, a contract is formed between you and us. To deliver our services — creating your account, processing your deposits and withdrawals in PHP, crediting your winnings, applying bonuses — we must process your personal data. Without it, we simply cannot operate your account.
4.2 To Comply With Legal Obligations
As an online gaming platform serving Filipino players, we are subject to various regulatory requirements including anti-money laundering (AML) laws, Know Your Customer (KYC) regulations, and tax reporting obligations. We are legally required to collect and retain certain data to comply with these rules.
4.3 For Our Legitimate Interests
We process some data based on our legitimate business interests, provided those interests do not override your rights. This includes fraud detection and prevention, platform security monitoring, responsible gaming monitoring, and improving the overall 100 Panalo experience for all players.
4.4 With Your Consent
For certain activities — such as sending you promotional emails about new games or special offers on the Promotions page — we will ask for your explicit consent. You can withdraw that consent at any time by updating your communication preferences in your account settings or contacting our support team.
Note for Filipino players: Your gaming data may be used to monitor for signs of problem gambling. This is done in your best interest and in compliance with responsible gaming obligations. You can manage your gaming limits at any time through the Responsible Gaming section of your account.
5. How Long We Keep Your Data
We keep your personal data only for as long as necessary to fulfil the purpose it was collected for, or as required by Philippine law. Here are the key retention periods:
- Account and identity data: Retained for the duration of your account plus 5 years after closure, as required by AML regulations.
- Transaction records: Minimum 5 years from the date of the transaction, in line with financial recordkeeping requirements.
- Gameplay and betting history: Retained for 3 years to support dispute resolution and responsible gaming monitoring.
- Customer support communications: Retained for 2 years after the issue is resolved.
- Marketing consent records: Retained until consent is withdrawn, plus 1 year thereafter as evidence of the consent given.
When your data is no longer needed, we securely delete or anonymise it so it can no longer be linked back to you.
6. Who We Share Your Data With
We do not sell, rent, or trade your personal data. We share it only in the following limited circumstances and always under strict contractual protections:
6.1 Service Providers and Processors
We work with trusted third-party service providers who process data on our behalf. These include:
- Payment processors: GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet, BDO, BPI, UnionBank, Visa, and Mastercard — solely to process your transactions.
- Identity verification providers: To conduct KYC checks and verify your identity before withdrawals are released.
- Gaming software providers: Who supply and host our games. They receive only the technical data needed to run the games.
- Customer support platforms: Used to manage and track support tickets and live chat sessions.
- Analytics and security tools: Used for fraud detection, platform monitoring, and performance analytics.
All service providers are bound by data processing agreements requiring them to protect your data and use it only for the specified purpose.
6.2 Legal and Regulatory Authorities
We may disclose your data to Philippine regulatory bodies, law enforcement agencies, or courts when required by law, court order, or to protect the rights and safety of 100 Panalo and its players. This includes reporting to anti-money laundering authorities when transactions trigger legal thresholds.
We will never share your data with third-party advertisers or data brokers. Your personal information is not a product — it is your private data, and we treat it that way.
7. Cookies and Tracking Technologies
100 Panalo uses cookies and similar tracking technologies to make the platform work properly and to improve your experience. Here is how we use them:
- Essential cookies: Required for the platform to function. These keep you logged in, maintain your session, and enable security features. You cannot opt out of essential cookies.
- Functional cookies: Remember your preferences such as language settings and responsible gaming limits.
- Analytics cookies: Help us understand how players use 100 Panalo — which pages are popular, how long sessions last, and where players encounter issues. This data is aggregated and does not identify individuals.
- Security cookies: Used to detect and prevent fraudulent activity and bot access.
We do not use third-party advertising cookies. You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect how the platform functions for you.
8. Your Rights as a Data Subject
Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal data. 100 Panalo is committed to making these rights easy to exercise:
Right to Access
You can request a copy of all personal data we hold about you, including what we collected, why we collected it, and who we have shared it with.
Right to Rectification
If any of your personal data is inaccurate or incomplete, you have the right to have it corrected. Update basic details directly in your account settings.
Right to Erasure
You may request that we delete your personal data. Note that we may need to retain certain data to comply with legal obligations even after account closure.
Right to Object
You can object to processing based on legitimate interests, including profiling for marketing purposes. We will stop unless we have compelling legitimate grounds to continue.
Right to Data Portability
You can request a structured, machine-readable copy of the data you have provided to us, so you can transfer it to another service if you wish.
Right to Lodge a Complaint
If you believe we have mishandled your data, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.
To exercise any of these rights, email us at privacy@100panalo.app with your full name, registered email address, and a description of your request. We will respond within 15 business days, as required by the Data Privacy Act.
9. Data Security Measures
Protecting your personal data is a priority at 100 Panalo. We have implemented a range of technical and organisational security measures, including:
- TLS/SSL encryption for all data transmitted between your browser and our servers
- AES-256 encryption for sensitive data stored in our databases
- Multi-factor authentication (MFA) for internal system access by our staff
- Role-based access controls ensuring only authorised personnel can access specific types of data
- Regular security audits and penetration testing conducted by independent cybersecurity professionals
- Intrusion detection systems and 24/7 monitoring to identify and respond to suspicious activity
- Secure data centres with physical access controls and redundant infrastructure
Despite these measures, no digital system is 100% impenetrable. In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify you and the National Privacy Commission within 72 hours of discovering the breach, as required by Philippine law.
You also play a role in keeping your account secure. Always use a strong, unique password for your 100 Panalo account, enable any available security features, and never share your login credentials with anyone — including anyone claiming to be from our support team.
10. Children's Privacy
100 Panalo is strictly for adults aged 21 and above. We do not knowingly collect personal data from minors. Our registration process includes age verification steps to prevent underage access to the platform.
If we discover that a minor has registered an account or provided personal data, we will immediately suspend the account, delete the associated data, and take appropriate action. If you believe a minor has gained access to 100 Panalo, please contact us at support@100panalo.app immediately.
11. Updates to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements, or improvements to our services. When we make material changes, we will:
- Post a prominent notice on the 100 Panalo homepage or your account dashboard
- Send a notification to the email address registered on your account
- Update the "Effective Date" at the top of this page
We encourage you to review this Privacy Policy regularly. Your continued use of 100 Panalo after the effective date of any update constitutes your acceptance of the revised policy. If you disagree with the changes, you have the right to close your account and request deletion of your data before the new policy takes effect.
12. How to Contact Us
We take privacy seriously and are happy to answer any questions you have about how your data is handled at 100 Panalo. If you want to exercise your data rights, report a concern, or just want more clarity on anything in this policy, reach out to us through the following channels:
- Privacy enquiries: privacy@100panalo.app
- General support: support@100panalo.app
Our Data Protection Officer is responsible for overseeing compliance with this Privacy Policy and the Philippine Data Privacy Act. All privacy-related requests are handled by the DPO's office and will be acknowledged within 3 business days.
If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.
This Privacy Policy was last updated on 1 January 2025. We are committed to keeping it clear, honest, and up to date. At 100 Panalo, your trust is as important as your next big win — and we will always work hard to earn it, kabayan.