start107 Privacy Policy

1. Introduction

start107 ("start107," "we," "us," or "our") is committed to protecting the privacy and personal data of all users who access or register on the start107 platform, including the website at start107.one and any associated mobile applications or services (collectively, the "Platform").

This Privacy Policy describes how start107 collects, processes, stores, and protects personal information in connection with the operation of our online casino and sports betting services in the Philippines. It applies to all registered players, visitors, and any other individuals whose personal data we process in the course of our business.

By registering an account on start107 or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Privacy Policy, you should discontinue use of the Platform immediately.

This Privacy Policy should be read alongside our Terms & Conditions, which govern your use of the start107 Platform and are incorporated herein by reference.

2. Data We Collect

start107 collects personal data that is necessary for the provision of our services, compliance with legal obligations, and the improvement of the Platform experience. The categories of personal data we collect include:

start107 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by law or where you have provided such information voluntarily in the context of a responsible gaming self-assessment.

3. How We Collect Data

start107 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 participate in promotions, you provide personal data directly to start107.
• Automated technologies: When you access the start107 Platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party payment providers: When you transact via GCash, PayMaya, BPI, BDO, Metrobank, or other payment partners, we receive transaction confirmation data from those providers.
• Identity verification services: We may use third-party KYC and identity verification providers to validate the documents you submit during account verification.
• Fraud prevention services: We receive data from fraud detection and anti-money laundering screening services to protect the integrity of the Platform.

4. How We Use Your Data

start107 uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and manage your start107 player account, including processing your registration and verifying your identity.
• Service delivery: To provide access to games, process bets, handle deposits and withdrawals, and deliver the full range of start107 services.
• Legal and regulatory compliance: To comply with applicable Philippine laws, PAGCOR regulatory requirements, anti-money laundering (AML) obligations, and know-your-customer (KYC) requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: To monitor player activity for signs of problem gambling, enforce self-exclusion requests, and apply deposit or wagering limits set by the player.
• Customer support: To respond to your queries, resolve disputes, and provide assistance via live chat or email.
• Marketing and promotions: To send you information about start107 promotions, bonuses, and seasonal campaigns — but only where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the start107 Platform.

5. Legal Basis for Processing

start107 processes your personal data on the following legal bases, consistent with the Republic Act No. 10173 (Data Privacy Act of 2012) of the Philippines and its implementing rules and regulations:

• Contractual necessity: Processing is necessary to perform the contract between you and start107 — i.e., to provide you with the gaming services you have registered for.
• Legal obligation: Processing is required to comply with applicable laws and regulations, including AML laws, KYC requirements, and PAGCOR regulatory obligations.
• Legitimate interests: Processing is necessary for start107's legitimate interests, including fraud prevention, security, and Platform improvement, provided those interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as marketing communications — we rely on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing Your Data

start107 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners, to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and document verification services used to validate your identity during account registration or withdrawal processing.
• Game providers: Licensed game software providers whose games are available on the start107 Platform may receive limited technical data necessary to deliver their games.
• Regulatory authorities: PAGCOR and other Philippine government agencies, where disclosure is required by law or regulation.
• Law enforcement: Philippine law enforcement agencies or courts, where disclosure is required by a valid legal order or where necessary to prevent or investigate criminal activity.
• Fraud prevention services: Third-party fraud detection and AML screening providers used to protect the integrity of the Platform.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by start107, subject to confidentiality obligations.

start107 does not transfer your personal data to recipients outside the Philippines except where necessary to deliver our services (e.g., where a game provider or technical service provider is based abroad), and only where appropriate safeguards are in place.

7. Cookies & Tracking Technologies

start107 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session, and collect usage analytics. The types of cookies we use include:

• Essential cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in to your start107 account. These cannot be disabled without affecting Platform functionality.
• Analytics cookies: Used to collect aggregated, anonymized data about how users interact with the start107 Platform, helping us identify areas for improvement.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats.
• Preference cookies: Used to remember your settings and preferences, such as language and display options.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the start107 Platform. Continued use of the Platform following the display of our cookie notice constitutes your consent to our use of cookies as described in this Policy.

8. Data Retention

start107 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable law.
• KYC and verification documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory authority.
• Customer support communications: Retained for up to three (3) years from the date of the interaction, for dispute resolution and quality assurance purposes.
• Marketing data: Retained until you withdraw your consent or opt out of marketing communications, whichever is earlier.

When personal data is no longer required, start107 will securely delete or anonymize it in accordance with our internal data retention and disposal procedures.

9. Data Security

start107 implements a range of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the start107 Platform.
• Encrypted storage of sensitive personal and financial data at rest.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Two-factor authentication options for player accounts.
• Continuous monitoring for suspicious activity and unauthorized access attempts.

10. Your Rights

Under the Republic Act No. 10173 (Data Privacy Act of 2012) of the Philippines, you have the following rights in relation to your personal data held by start107:

• Right to be informed: You have the right to be informed about how your personal data is collected and processed. This Privacy Policy fulfils that obligation.
• Right of access: You have the right to request a copy of the personal data start107 holds about you.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have 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: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used format where processing is based on your consent or a contract.
• Right to lodge a complaint: You have the right to lodge 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 these rights, please contact the start107 Data Privacy team via live chat or by emailing [email protected]. We will respond to all verified requests within thirty (30) days.

11. Minors

If start107 discovers or is notified that personal data has been collected from a person under the age of 21, we will immediately suspend the relevant account, delete the associated personal data, and take appropriate action in accordance with our responsible gaming policies.

If you are a parent or guardian and believe that your child has registered on the start107 Platform, please contact us immediately at [email protected] so that we can take prompt action.

12. Third-Party Services

The start107 Platform integrates with third-party services — including payment processors, game providers, and analytics tools — that may collect or process personal data independently of start107. These third parties operate under their own privacy policies, and start107 is not responsible for their data practices.

start107 carefully selects third-party partners and requires them to implement appropriate data protection measures. However, we encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the start107 Platform.

The start107 Platform does not contain links to external third-party websites for general browsing purposes. Any third-party integrations are solely for the purpose of delivering the start107 service (e.g., payment processing, game delivery).

13. Policy Changes

start107 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. When material changes are made, we will notify registered players via the email address associated with their account or via a prominent notice on the Platform.

The date of the most recent revision is indicated at the top of this page. Your continued use of the start107 Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed about how start107 protects your data.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way start107 handles your personal data, please contact our Data Privacy team. We are committed to addressing all privacy-related inquiries promptly and transparently.

You may reach us via live chat on the Platform (available 24/7) or by email at: [email protected]

Please include your registered username and a clear description of your request so we can assist you as efficiently as possible. All data subject requests will be acknowledged within five (5) business days and resolved within thirty (30) days.