bat100 Privacy Policy

01 Introduction

bat100 is committed to safeguarding the privacy and personal data of every Filipino player who entrusts us with their information. As a PAGCOR-regulated online casino platform, bat100 operates in full compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

This Policy governs all personal data processing activities carried out by bat100 in connection with the operation of the bat100.org platform, including account registration, identity verification (KYC), deposits and withdrawals, game activity, customer support communications, and marketing outreach. We process your data only to the extent necessary to deliver a safe, regulated, and enjoyable gaming experience — nothing more.

Where bat100 acts as a data controller, we determine the purposes and means of processing your personal data. Where bat100 engages third-party service providers who process data on our behalf, those parties act as data processors under contractual data processing agreements that meet DPA standards.

02 Personal Data We Collect

bat100 collects the following categories of personal data, depending on how you interact with the platform:

• Full legal name as it appears on your government-issued ID;
• Date of birth (used to verify the 21+ age requirement under PAGCOR regulations);
• Residential address, city, and province (e.g., Manila, Cebu, Davao, Quezon City, Makati);
• Email address and mobile phone number;
• Username and encrypted password credential.

• Scanned or photographed copies of government-issued photo identification (e.g., Philippine passport, PhilSys national ID, SSS ID, UMID, driver's license, PRC ID, voter's ID);
• Proof of residential address documents (e.g., utility bills, bank statements dated within 90 days);
• Selfie photographs submitted for liveness verification where required;
• Proof of payment method ownership where applicable.

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references;
• GCash account references, Maya account references, bank account numbers (BPI, BDO, Metrobank, UnionBank), and Coins.ph wallet identifiers — stored as masked references only, never full credentials;
• Cryptocurrency wallet addresses for USDT TRC20 transactions;
• Bonus and promotional credit history.

• Game session records including games played, wager amounts, win/loss outcomes, session durations, and timestamps;
• Responsible gaming tool settings, including deposit limits, session reminders, and self-exclusion status;
• Game provider interaction logs (Pragmatic Play, PG Soft, Jili, Habanero, Ezugi, and others).

• IP address and approximate geolocation data (country, region);
• Device type, operating system, browser type and version;
• Session logs, access timestamps, and platform navigation data;
• Cookie identifiers and similar tracking technology data (see Section 7).

• Support ticket contents, live chat transcripts, and email correspondence between you and the bat100 support team;
• Survey responses and feedback submitted voluntarily.

03 How We Collect Your Data

bat100 collects personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions on bat100;
• Automatically — through cookies, server logs, and analytics tools when you browse or interact with the bat100 platform (see Section 7);
• From third-party payment processors — when you initiate a financial transaction via GCash, Maya, BPI, BDO, or other supported payment channels, transaction confirmation data is transmitted to bat100 by the payment provider;
• From identity verification partners — where bat100 uses a third-party KYC verification service to process identity documents, that service transmits a verification result and relevant identity data to bat100;
• From game providers — game session data including wager amounts and outcomes is transmitted from licensed game providers (e.g., Pragmatic Play, Ezugi) to bat100's systems in real time;
• From regulatory and fraud-prevention databases — where permitted by law, bat100 may verify account details against PAGCOR self-exclusion registers or anti-money laundering screening databases.

04 How We Use Your Personal Data

bat100 processes your personal data for the following specific purposes:

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, bat100 relies on the following lawful bases for processing your personal data:

• Contractual necessity — processing required to perform our obligations under the bat100 Terms and Conditions, including account management, payment processing, and game delivery;
• Legal obligation — processing required to comply with PAGCOR regulations, Anti-Money Laundering Act (AMLA) requirements, and other applicable Philippine law;
• Legitimate interests — processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improvement of bat100 services, where such interests are not overridden by your data protection rights;
• Consent — processing for optional purposes such as marketing communications, where your freely given, specific, and informed consent has been obtained and may be withdrawn at any time.

06 Data Sharing & Disclosure

bat100 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We disclose personal data only in the following strictly limited circumstances:

bat100 engages trusted third-party service providers who process personal data on our behalf under written data processing agreements. These include payment processors (GCash, Maya, BPI, BDO, Metrobank, UnionBank, Coins.ph), KYC/identity verification providers, game content providers (Pragmatic Play, PG Soft, Jili, Habanero, Ezugi), cloud hosting and infrastructure providers, and fraud detection and cybersecurity services.

bat100 is required by law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities when lawfully requested, or as required for regulatory reporting, investigations, or court proceedings.

In the event of a merger, acquisition, restructuring, or sale of bat100's business assets, personal data held by bat100 may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and any material change in data controller identity.

07 Cookies & Tracking Technologies

bat100 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit bat100.org. They help us remember your session, maintain your login state, and understand how players navigate the platform.

bat100 uses the following categories of cookies:

• Strictly Necessary Cookies — essential for the bat100 platform to function. These include session authentication cookies that keep you logged in to your bat100 account and security tokens. These cannot be disabled without breaking core platform functionality.
• Functional Cookies — remember your preferences such as language, game filters, and responsible gaming settings within your bat100 account session.
• Analytics Cookies — collect anonymized data about how players use bat100, including which game categories are most popular and where players encounter navigation difficulties. bat100 uses this data to improve the platform experience.
• Marketing Cookies — used only where you have given consent, to deliver relevant bat100 promotional content. These are not used to track you across third-party websites.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from accessing your bat100 account. bat100 does not respond to "Do Not Track" signals from browsers at this time.

08 Data Retention

bat100 retains personal data for as long as necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, and enforce bat100's Terms and Conditions. Specific retention periods are governed by the following principles:

• Account data — retained for the lifetime of your bat100 account and for a minimum of five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and AMLA obligations;
• KYC and identity documents — retained for a minimum of five (5) years after the conclusion of the customer relationship, per AMLC requirements;
• Transaction records — retained for a minimum of five (5) years from the date of the transaction;
• Gaming activity logs — retained for a minimum of three (3) years for platform integrity and dispute resolution purposes;
• Support communications — retained for a minimum of two (2) years from the date of the last interaction;
• Marketing data — retained until you withdraw consent or request erasure, whichever comes first.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Where data cannot be immediately deleted due to ongoing legal proceedings or regulatory hold obligations, it will be restricted from active processing until deletion becomes possible.

09 Data Security

bat100 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption — all data transmitted between your device and bat100.org is encrypted using industry-standard Transport Layer Security (TLS) protocols;
• Password hashing — bat100 account passwords are stored using strong one-way cryptographic hashing algorithms and are never stored in plaintext;
• Access controls — personal data is accessible only to bat100 personnel and authorized service providers who require it to perform their role, enforced through role-based access control systems;
• Two-factor authentication — optional 2FA is available to all bat100 account holders to add an additional layer of login security;
• Regular security audits — bat100 conducts periodic vulnerability assessments and security testing of its platform infrastructure;
• Data breach response — bat100 maintains a documented data breach response procedure. In the event of a personal data breach that poses a real risk of serious harm, bat100 will notify the National Privacy Commission within 72 hours and affected players as required by the DPA.

10 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by bat100. To exercise any of these rights, contact bat100 at [email protected] with the subject line "Data Privacy Request":

• Right to be Informed — the right to know what personal data bat100 holds about you, how it is being used, and with whom it is shared. This Privacy Policy serves as bat100's primary disclosure of this information.
• Right of Access — the right to request a copy of the personal data bat100 holds about you. bat100 will respond to access requests within thirty (30) days.
• Right to Rectification — the right to request correction of inaccurate or incomplete personal data. You may update most account details directly through your bat100 account dashboard.
• 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 bat100's legal retention obligations under PAGCOR and AMLA regulations.
• Right to Object — the right to object to processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability — the right to receive a copy of the personal data you have provided to bat100 in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint — if you believe bat100 has not handled your personal data in accordance with the DPA, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.

11 Children's Privacy & Age Restriction

bat100 strictly prohibits access to its platform by persons under the age of 21 years, in compliance with PAGCOR regulations governing online casino gaming in the Philippines. bat100 does not knowingly collect, process, or store personal data belonging to individuals under 21.

Where bat100 has reasonable grounds to suspect that a registered account holder is under 21, bat100 will immediately suspend the account, initiate age verification procedures, and withhold all account balances pending resolution. If age verification confirms the account holder is below the minimum age, the account will be permanently closed and any deposited funds will be returned to the originating payment method after deduction of any winnings, which are not payable to underage players under any circumstances.

12 Third-Party Links

The bat100 platform may contain links to third-party payment processors (such as GCash, Maya, or BPI online banking portals) for the purpose of completing financial transactions. Once you leave bat100.org and navigate to a third-party site or application, this Privacy Policy no longer applies. bat100 is not responsible for the privacy practices or data handling of third-party platforms.

bat100 encourages you to review the privacy policies of any third-party service you use in connection with bat100 transactions, particularly those of your chosen payment provider, before transmitting personal financial information.

13 Updates to This Privacy Policy

bat100 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, PAGCOR regulations, or platform features. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision.

Where changes to this Policy are material — meaning they significantly affect how we collect, use, or share your personal data — bat100 will notify registered players by email to the address on file, or by a prominent notice displayed on the bat100 platform upon next login, at least fourteen (14) days before the changes take effect.

Your continued use of bat100 following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree with the updated Policy, you must stop using bat100 and may request account closure by contacting [email protected].

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or bat100's personal data practices, please contact our Data Protection team using the following details:

• Email: [email protected]
• Subject Line: Data Privacy Request / Privacy Policy Inquiry
• Website: bat100.org
• Operating Hours: 24 hours a day, 7 days a week
• Regulatory Authority: National Privacy Commission of the Philippines (NPC)
• Gaming Regulator: Philippine Amusement and Gaming Corporation (PAGCOR)

For responsible gaming support, please visit our Responsible Gaming page. For a full overview of our platform terms, visit our Terms & Conditions page.