Privacy Policy

§1 Introduction

This Privacy Policy ("Policy") is issued by qo123 ("the Company", "qo123", "we", "us", "our"), the operator of the online gaming platform accessible at qo123.org. This Policy applies to all personal data collected from users ("you", "Player", "Data Subject") in connection with your use of the qo123 platform, including account registration, gameplay, deposits, withdrawals, customer support interactions, and marketing communications.

qo123 is committed to full compliance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations ("IRR"), as enforced by the National Privacy Commission ("NPC"). All processing of personal data by qo123 is conducted in accordance with the general principles of transparency, legitimate purpose, and proportionality as prescribed under the DPA.

By registering an account on qo123.org or otherwise using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must refrain from using the qo123 platform.

§2 Categories of Personal Data We Collect

qo123 collects personal data that is necessary and proportionate to the purposes for which it is processed. The categories of personal data qo123 collects include, but are not limited to, the following:

• Identity data: Full legal name, date of birth, gender, nationality, and a copy of a government-issued photo ID (e.g., Philippine national ID, passport, or driver's license) as required for KYC verification.
• Contact data: Email address, mobile number, and residential address (including city and province/region within the Philippines).
• Account data: Username, encrypted password, account creation date, account status, and preferences stored within your qo123 profile.
• Financial data: GCash account details, PayMaya account details, bank account information (BPI, BDO, Metrobank, or other Philippine banks), and transaction history including deposits, withdrawals, and bonus credits.
• Gaming data: Game session logs, bet history, win/loss records, game preferences, and responsible gaming tool settings (deposit limits, session limits, self-exclusion status).
• Technical data: IP address, device type, operating system, browser type and version, screen resolution, and session timestamps.
• Communications data: Records of customer support interactions conducted via live chat or email, including transcripts and resolution notes.
• Marketing data: Your marketing communication preferences, promotion participation history, and bonus claim records.

qo123 does not collect sensitive personal information (as defined under Section 3(l) of the DPA) unless strictly necessary for a specific regulatory compliance purpose, and only with your explicit informed consent where required by law.

§3 How We Collect Your Data

qo123 collects personal data through the following channels and methods:

• Direct registration: Data you provide when creating your qo123 account, completing KYC verification, or updating your profile settings.
• Transaction processing: Data collected automatically when you make deposits or withdrawals via GCash, PayMaya, BPI, BDO, or other supported payment methods.
• Platform usage: Data collected automatically through your interactions with the qo123 platform, including game sessions, page navigation, and feature usage.
• Cookies and tracking technologies: Data collected via cookies, web beacons, and similar technologies as described in Section 9 of this Policy.
• Customer support: Data you provide when contacting qo123 support via live chat or email at [email protected].
• Third-party sources: In limited circumstances, qo123 may receive data about you from third-party identity verification service providers, fraud prevention databases, or payment processing partners, where this is necessary for regulatory compliance or fraud prevention purposes.

§4 Purposes of Processing

qo123 processes your personal data only for legitimate, specified purposes. The primary purposes for which your data is processed include:

• Account management: To create, maintain, and administer your qo123 player account, including authentication and security.
• KYC and identity verification: To verify your identity and age in compliance with PAGCOR regulations and Philippine anti-money laundering laws (Republic Act No. 9160, as amended).
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and other supported Philippine payment channels.
• Gaming services: To deliver the gaming experience — including live casino, slots, sports betting, bingo, and sabong — and to maintain game integrity.
• Regulatory compliance: To comply with PAGCOR licensing requirements, anti-money laundering obligations, and any lawful orders from Philippine regulatory authorities or courts.
• Responsible gaming: To monitor gaming behavior and apply responsible gaming tools including deposit limits, loss limits, cooling-off periods, and self-exclusion, in accordance with our duty of care obligations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account compromise, collusion, and other prohibited conduct.
• Customer support: To respond to your inquiries, complaints, and support requests.
• Marketing (with consent): To send you promotional offers, bonus notifications, and gaming updates where you have consented to receive marketing communications. You may withdraw this consent at any time by contacting [email protected].
• Platform improvement: To analyze aggregated, anonymized usage data for the purpose of improving the qo123 platform's features, performance, and user experience.

§5 Legal Bases for Processing

qo123 processes your personal data on one or more of the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary for the performance of our contract with you — i.e., to operate your qo123 account and deliver the gaming services you have requested.
• Legal obligation: Processing is necessary to comply with applicable Philippine laws, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and other regulatory requirements binding on qo123.
• Legitimate interests: Processing is necessary for qo123's legitimate interests — including fraud prevention, platform security, and business analytics — provided those interests are not overridden by your privacy rights.
• Consent: For processing activities that are not strictly necessary for the above purposes — such as direct marketing communications — qo123 relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent for marketing communications at any time without affecting the lawfulness of prior processing.

§6 Disclosure and Sharing of Personal Data

qo123 does not sell your personal data to third parties. qo123 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 (GXI), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and other Philippine payment service providers, to the extent necessary to process your transactions.
• Identity verification providers: Third-party KYC and age verification service providers engaged by qo123 to verify the identity and age of players in compliance with PAGCOR requirements.
• Game content providers: Third-party game developers and live casino platform providers who supply game software and live streaming services to qo123, to the extent necessary to deliver those gaming services.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and any other Philippine government authority that is lawfully entitled to receive your personal data.
• Professional advisors: Legal counsel, auditors, and other professional service providers engaged by qo123 in connection with the operation of its business, subject to professional confidentiality obligations.
• Fraud prevention services: Industry fraud prevention databases and service providers, where disclosure is necessary to detect or prevent money laundering, fraud, or other prohibited conduct.

All third-party recipients of personal data from qo123 are required to process such data in accordance with applicable Philippine data protection law and are contractually prohibited from using it for any purpose other than the specific purpose for which it was shared.

§7 Data Retention

qo123 retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, subject to any applicable legal or regulatory retention requirements. The following general retention periods apply:

• Active account data: Retained for the duration of your account relationship with qo123, plus a minimum of five (5) years following account closure, in compliance with the Anti-Money Laundering Act's record-keeping requirements.
• Transaction and financial records: Retained for a minimum of five (5) years following the date of the transaction, in compliance with PAGCOR and AMLC record-keeping obligations.
• KYC documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Customer support communications: Retained for three (3) years from the date of the support interaction.
• Marketing preferences: Retained until you withdraw your consent or for three (3) years of inactivity, whichever comes first.

At the expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with qo123's data disposal procedures.

§8 Security Measures

qo123 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and qo123.org — the same standard used by Philippine banks including BPI and BDO for online banking;
• Encryption at rest for all sensitive personal data and financial information stored in qo123's systems;
• Access controls restricting access to personal data to qo123 personnel who require it for their specific job function, with multi-factor authentication required for all staff access to production systems;
• Regular security assessments including penetration testing and vulnerability scanning of the qo123 platform;
• Incident response procedures designed to detect, contain, and respond to personal data breaches, with notification to the NPC and affected data subjects within the timeframes required by the DPA.

While qo123 takes all reasonable precautions to protect your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own qo123 account credentials. If you suspect your account has been compromised, contact qo123 support immediately via live chat or at [email protected].

§9 Cookies and Tracking Technologies

qo123.org uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device by your web browser. qo123 uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function. These include session authentication cookies that keep you logged in to your qo123 account. These cannot be disabled without breaking core platform functionality.
• Functional cookies: Enable the platform to remember your preferences — such as language, game lobby layout, and responsible gaming settings — so you do not need to re-configure them on every visit.
• Analytics cookies: Used to collect aggregated, anonymized data about how players navigate the qo123 platform, which pages are visited most frequently, and where technical issues occur. This data is used solely for platform improvement.
• Security cookies: Used to detect and prevent fraudulent activity, including account takeover attempts and bot traffic.

qo123 does not use third-party advertising cookies or share tracking data with advertising networks. You can manage your cookie preferences through your browser settings; however, disabling strictly necessary cookies will prevent you from accessing your qo123 account.

§10 Your Rights as a Data Subject

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: The right to be notified of how your personal data is collected, used, and shared — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data qo123 holds about you and information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held by qo123.
• Right to erasure or blocking: The right to request deletion or blocking of your personal data where processing is no longer necessary or lawful, subject to qo123's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes. You may withdraw marketing consent at any time by contacting [email protected].
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format, where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe qo123 has handled your personal data unlawfully.

To exercise any of the above rights, please contact qo123's Data Protection Officer at [email protected]. qo123 will respond to all valid data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

§11 Children's Privacy

The qo123 platform is strictly for adults aged 21 years and above in compliance with PAGCOR regulations governing online gaming in the Philippines. qo123 does not knowingly collect personal data from persons under the age of 21. If qo123 discovers or is notified that personal data has been collected from a person under 21, such data will be immediately deleted and the associated account will be permanently closed.

If you are a parent or guardian and believe that a minor has registered an account on qo123.org, please contact qo123 immediately at [email protected] with relevant details so that appropriate action can be taken without delay.

§12 Amendments to This Privacy Policy

qo123 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Where amendments are material, qo123 will notify registered players via email or a prominent notice on qo123.org prior to the changes taking effect.

The most current version of this Privacy Policy will always be accessible at qo123.org/privacy-policy, with the effective date clearly displayed. Continued use of the qo123 platform following the publication of an amended Policy constitutes your acceptance of the updated terms.

§13 Contact and Data Protection Officer

qo123 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests regarding this Policy or the handling of your personal data, please contact the qo123 DPO through the following channels:

• Email: [email protected] — please include "Privacy Policy" or "Data Subject Request" in the subject line
• Live Chat: Available 24/7 on qo123.org

All data subject requests and privacy-related complaints will be acknowledged within three (3) business days and fully responded to within fifteen (15) business days of receipt, in accordance with NPC requirements.