Privacy Policy – qo123 Casino Philippines

1. Scope & Data Controller

This Privacy Policy applies to all personal data processed by qo123 in connection with the qo123 online gaming platform accessible at qo123.club (the "Platform"). It covers personal data collected when you register an account, make deposits or withdrawals, place wagers, contact qo123 support, or otherwise interact with the Platform in any way.

The data controller responsible for your personal data is qo123, a PAGCOR-licensed online gaming operator registered and operating in the Republic of the Philippines. As data controller, qo123 determines the purposes and means by which your personal data is processed, in accordance with the Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations.

2. Personal Data We Collect

qo123 collects personal data in the following categories:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued ID.
• Date of birth (for age verification — qo123 requires members to be at least 21 years old).
• Philippine mobile number used as your account identifier.
• Username and hashed password (plaintext passwords are never stored).
• Email address (optional, where provided during registration).

2.2 Identity Verification (KYC) Data

• Scanned or photographed copy of a valid Philippine government-issued ID (e.g., PhilSys ID, UMID, Passport, Driver's License, VHAP).
• Selfie photograph for biometric comparison against the presented ID.
• Proof of address documentation where required by enhanced due diligence procedures.
• Source of funds declarations for high-value accounts as required under the Anti-Money Laundering Act (AMLA).

2.3 Financial Data

• GCash or Maya account reference numbers (not full account credentials) used for deposit and withdrawal matching.
• Bank account names and numbers for BPI, BDO, Metrobank, or other bank transfer methods.
• Transaction history: deposit amounts, withdrawal amounts, dates, and payment method identifiers.

2.4 Gaming & Betting Activity Data

• Game session logs: games played, bet amounts, win/loss outcomes, session duration.
• Sports betting selections, odds accepted, and settlement results.
• Bonus activation and wagering progress records.

2.5 Technical & Device Data

• IP address at time of login and gameplay.
• Device type, operating system, and browser type.
• Approximate geolocation derived from IP address (not GPS location).
• Session timestamps and Platform navigation logs.

2.6 Communications Data

• Live chat transcripts and support ticket content when you contact qo123 support.
• Emails, SMS, and in-platform messages sent between you and qo123.

3. Legal Basis for Processing

qo123 processes your personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contractual Necessity: Processing your registration data, KYC documents, payment details, and gaming activity is necessary to enter into and perform the contract with you — i.e., to operate your qo123 account and provide the services you have signed up for.
• Legal Obligation: qo123 is required by law to collect and retain certain data to comply with PAGCOR's licensing requirements, the Anti-Money Laundering Act (AMLA), and other applicable Philippine regulations. This includes KYC verification, transaction records, and reporting obligations.
• Legitimate Interest: qo123 processes technical and device data to detect fraud, prevent unauthorised account access, and maintain Platform security. These processing activities serve qo123's legitimate interest in operating a secure and compliant gaming environment.
• Consent: Marketing communications, optional personalisation features, and non-essential cookies are processed on the basis of your explicit consent, which you may withdraw at any time.

4. How We Use Your Personal Data

qo123 uses your personal data for the following purposes:

• To create and manage your qo123 account, including identity verification, login authentication, and account security.
• To process deposits and withdrawals through GCash, Maya, BPI, BDO, and other approved Philippine payment channels.
• To verify your age and eligibility as required by PAGCOR — all members must be 21 years of age or older.
• To settle bets, apply bonuses, and maintain accurate game and transaction records.
• To detect and prevent fraud, money laundering, unauthorised account access, and other prohibited activities.
• To comply with PAGCOR reporting requirements and to fulfil AMLA obligations, including the filing of Covered Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) where required.
• To provide customer support when you contact the qo123 team via live chat or other channels.
• To send transactional notifications (deposit confirmations, withdrawal updates, OTP codes) and — where you have consented — promotional communications about bonuses and new games.
• To monitor responsible gaming indicators and apply protective measures where signs of problem gambling are identified.
• To improve and optimise the Platform based on aggregated, anonymised usage data.

5. Data Sharing & Disclosure

qo123 does not sell your personal data. We share personal data only in the following circumstances:

• PAGCOR and Regulatory Authorities: qo123 is legally required to share account and transaction data with PAGCOR and other competent Philippine government authorities (including the AMLC) upon lawful request or as part of routine regulatory reporting.
• Payment Processors: Transaction data (amounts, timestamps, reference numbers) is shared with GCash, Maya, BPI, BDO, and other payment partners solely for the purpose of processing deposits and withdrawals.
• Game Software Providers: Gaming activity data (bets placed, session identifiers) is shared with qo123's licensed game software providers (such as JILI, PG Soft, and Evolution Gaming) as necessary to deliver game services and certify RNG integrity.
• KYC / Identity Verification Service Providers: Identity documents and selfie photographs may be processed by certified third-party KYC verification providers operating under strict data processing agreements with qo123.
• IT and Security Service Providers: Technical data may be shared with trusted IT infrastructure, cloud hosting, and cybersecurity partners who process data on qo123's behalf under data processing agreements that bind them to the same data protection standards as qo123.
• Law Enforcement: qo123 will disclose personal data to law enforcement or judicial authorities in response to a valid court order or lawful legal process under Philippine law.

All third-party service providers who process personal data on behalf of qo123 are subject to contractual obligations that restrict their use of that data to the specified purpose and require them to maintain appropriate technical and organisational security measures.

6. Cookies & Tracking Technologies

qo123 uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function, including session authentication, login state maintenance, and security token management. These cookies cannot be disabled without affecting Platform functionality.
• Performance & Analytics Cookies: Used to collect aggregated, anonymised data about how members navigate the Platform — which pages are visited most often, where users drop off, and how long sessions last. This data helps qo123 improve the user experience.
• Preference Cookies: Used to remember your language preference, display settings, and other non-essential personalisation options.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from accessing qo123 core features but may affect personalisation and some analytics-driven features.

7. Data Retention

qo123 retains personal data for the periods required by applicable law and regulatory obligation:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR's data retention rules and the AMLA's record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years per AMLA requirements.
• Gaming activity logs: Retained for three (3) years following the relevant game session, unless a longer retention period is required for dispute resolution or regulatory purposes.
• Support communications: Retained for two (2) years from the date of the last communication.
• Marketing consent records: Retained until withdrawal of consent plus one (1) year for compliance audit purposes.

After the applicable retention period expires, personal data is securely deleted or anonymised in a manner that prevents re-identification.

8. Data Security

qo123 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and qo123's servers.
• Encryption at rest for sensitive personal data stored in qo123's databases, including hashed password storage using bcrypt.
• Role-based access controls that limit employee access to personal data on a strict need-to-know basis.
• Regular independent security audits and penetration testing of the Platform infrastructure.
• Mandatory two-factor authentication for qo123 employee access to production systems.
• Incident response procedures for the detection, investigation, and notification of personal data breaches, in compliance with NPC breach notification requirements.

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, qo123 will notify you and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required under NPC Circular 16-03.

9. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by qo123:

• Right to be Informed: You have the right to know what personal data qo123 collects about you, the purpose of collection, and how it is used — as set out in this Privacy Policy.
• Right of Access: You may request a copy of the personal data qo123 holds about you. qo123 will respond to access requests within ten (10) business days.
• Right to Rectification: If any personal data held by qo123 is inaccurate or incomplete, you have the right to request correction. Some corrections may require submission of supporting documentation.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to qo123's legal retention obligations under PAGCOR and AMLA regulations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interest where you believe your rights and freedoms override qo123's interests.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to File a Complaint: If you believe that qo123 has processed your personal data in violation of the Data Privacy Act, you have the right to file a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please contact qo123's Data Protection Officer using the contact details provided in Section 13 of this Policy.

10. Children's Privacy & Age Restriction

qo123 is strictly for adults aged twenty-one (21) years and older in compliance with PAGCOR regulations and Philippine law governing casino-style online gaming. qo123 does not knowingly collect personal data from persons below the age of 21.

All registration attempts are subject to mandatory date-of-birth verification. Where qo123 discovers that a member account was created by a person below the minimum age, the account will be immediately closed, all balances will be returned to the payment source (where practicable), and all personal data associated with the account will be deleted in accordance with applicable law.

If you are a parent or guardian and believe that a minor has created a qo123 account, please contact qo123 support immediately so the matter can be investigated and the account closed.

11. Cross-Border Data Transfers

Some of qo123's third-party service providers — including game software providers and cloud infrastructure partners — may be located outside the Philippines. Where personal data is transferred to a jurisdiction outside the Philippines, qo123 ensures that such transfers are subject to appropriate safeguards, including contractual data processing agreements that require the receiving party to maintain data protection standards equivalent to those required under Philippine law.

qo123 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing additional contractual or technical safeguards.

12. Amendments to This Policy

qo123 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or the Platform's data processing practices. When material changes are made, qo123 will notify registered members via in-platform notification or email at least seven (7) days before the changes take effect.

Continued use of the Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised Policy. We encourage you to review this page periodically. The "Last updated" date at the top of this page indicates when the most recent revision was made.

13. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or qo123's data processing practices, please contact the qo123 Data Protection Officer:

• Email: [email protected] (please include "Privacy" in the subject line)
• Live Chat: Available 24/7 via the qo123 Platform
• Response Time: qo123 will acknowledge all written privacy requests within two (2) business days and provide a substantive response within ten (10) business days.

For complaints that remain unresolved after contact with qo123, you may file a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph. qo123 fully cooperates with NPC investigations and adheres to NPC decisions.