filgame Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") describes how filgame ("filgame," "we," "us," or "our") collects, uses, stores, and protects the personal data of individuals ("you," "Player," or "User") who access or use the filgame platform at filgame.net, including all games, services, promotions, and features offered therein.

This Policy applies to all personal data collected through the filgame website, mobile-optimised platform, customer support channels, and any other touchpoint where filgame interacts with you. It should be read alongside our Terms & Conditions, which govern your use of the filgame platform.

filgame is committed to protecting your privacy in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). By registering a filgame account or using the platform, you acknowledge that you have read and understood this Policy.

2. Data Controller Information

filgame is the data controller responsible for your personal data collected through the filgame platform. As data controller, filgame determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable data protection laws.

If you have any questions, concerns, or requests relating to your personal data, you may contact our Data Protection Officer (DPO) at:

• Email: [email protected]
• Subject Line: Data Privacy Request — [Your Name]

3. Personal Data We Collect

filgame collects personal data that you provide directly, data generated through your use of the platform, and data received from third parties where permitted by law. The categories of personal data we collect include:

3.1 Registration & Identity Data:

• Full legal name;
• Date of birth (to verify the 21+ age requirement);
• Philippine mobile number and email address;
• Username and encrypted password;
• Government-issued ID details (where required for identity verification).

3.2 Financial & Transaction Data:

• GCash or PayMaya/Maya account details (account number only — filgame does not store full e-wallet credentials);
• Philippine bank account details for bank transfer transactions;
• Debit card details (processed securely through our payment processor — filgame does not store full card numbers);
• Deposit and withdrawal history;
• Wagering and game history.

3.3 Technical & Usage Data:

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, pages visited, and features used;
• Login timestamps and activity logs.

3.4 Communications Data:

• Records of your communications with filgame customer support (live chat transcripts, email correspondence);
• Feedback, survey responses, and promotional opt-in preferences.

4. How We Use Your Personal Data

filgame uses your personal data for the following purposes:

• Account Management: To register and maintain your filgame account, verify your identity and age (21+), and manage your account settings and preferences;
• Service Delivery: To provide access to filgame games, process deposits and withdrawals, and deliver customer support;
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct; to protect the integrity of the filgame platform;
• Legal & Regulatory Compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR-aligned requirements, and NPC data protection obligations;
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion;
• Communications: To send you transactional notifications (deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about filgame offers and events;
• Platform Improvement: To analyse usage patterns, troubleshoot technical issues, and improve the filgame platform experience for all players;
• Dispute Resolution: To investigate and resolve complaints, disputes, and legal claims.

5. Legal Basis for Processing

filgame processes your personal data on the following legal bases under the DPA:

• Contractual Necessity: Processing required to perform our contract with you (the filgame Terms & Conditions), including account management, game delivery, and payment processing;
• Legal Obligation: Processing required to comply with applicable Philippine laws, including AML regulations and PAGCOR-aligned requirements;
• Legitimate Interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms;
• Consent: Processing for optional purposes such as marketing communications, where you have provided explicit opt-in consent. You may withdraw consent at any time by contacting support or updating your account preferences.

6. Sharing Your Personal Data

filgame does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Processors: GCash, PayMaya/Maya, and Philippine banking partners, solely to process deposits and withdrawals on your behalf;
• Identity Verification Providers: Third-party KYC (Know Your Customer) service providers engaged to verify your identity and age in compliance with regulatory requirements;
• Technology Service Providers: Cloud hosting, platform infrastructure, and analytics providers who process data on filgame's behalf under strict data processing agreements;
• Regulatory & Law Enforcement Authorities: The National Privacy Commission, PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where required by law or court order;
• Professional Advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third-party service providers engaged by filgame are contractually required to process personal data only on filgame's instructions and in accordance with applicable data protection laws.

7. Data Retention

filgame retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Active Account Data: Retained for the duration of your filgame account and for a period of five (5) years following account closure, in compliance with Philippine AML record-keeping requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction;
• Customer Support Records: Retained for three (3) years from the date of the last interaction;
• Marketing Preferences: Retained until you withdraw consent or request deletion, whichever is earlier;
• Technical Logs: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, filgame will securely delete or anonymise your personal data in accordance with its data disposal procedures.

8. Data Security

filgame implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and filgame.net;
• Encryption of sensitive data at rest, including payment details and identity documents;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for internal systems accessing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, filgame will notify the National Privacy Commission and affected individuals in accordance with the DPA and NPC Circular No. 16-03.

9. Cookies & Tracking Technologies

filgame uses cookies and similar tracking technologies on filgame.net to ensure the platform functions correctly and to improve your experience. The types of cookies we use are:

• Essential Cookies: Required for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled without affecting platform functionality;
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use filgame.net, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers;
• Preference Cookies: Used to remember your language and display preferences across sessions.

filgame does not use third-party advertising or retargeting cookies. You can manage or delete cookies through your browser settings at any time. Note that disabling essential cookies may affect your ability to use certain features of the filgame platform.

10. Your Rights as a Data Subject

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

• Right to be Informed: The right to be informed of how your personal data is collected, used, and processed — which this Policy fulfils;
• Right of Access: The right to request a copy of the personal data filgame holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to filgame's legal retention obligations;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format;
• Right to Object: The right to object to the processing of your personal data for direct marketing or on grounds relating to your particular situation;
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." filgame will respond to all verified requests within fifteen (15) business days in accordance with NPC guidelines.

11. Children's Privacy

The filgame platform is strictly intended for individuals aged 21 years and older. filgame does not knowingly collect personal data from individuals under the age of 21. If filgame becomes aware that personal data has been collected from a person under 21, that account will be closed immediately and all associated data will be deleted.

If you believe that a minor has registered a filgame account, please contact our support team immediately at [email protected].

12. International Data Transfers

filgame primarily processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers located outside the Philippines (for example, cloud infrastructure providers), filgame ensures that such transfers are subject to appropriate safeguards, including contractual data processing agreements that impose data protection standards equivalent to those required under the DPA.

filgame will not transfer your personal data to a country that does not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining your consent.

13. Changes to This Privacy Policy

filgame reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. Where changes are material, filgame will notify you via email or an in-platform notification prior to the changes taking effect. The "Last Updated" date at the top of this Policy will always reflect the most recent revision.

Your continued use of the filgame platform following the effective date of any update constitutes your acceptance of the revised Policy. If you do not agree to the updated Policy, you must cease using the platform and may request account closure.

14. Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or filgame's data practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Data Privacy Request — [Your Name]
• Response Time: Within 15 business days for formal data subject requests; within 24 hours for general privacy enquiries

If you are not satisfied with filgame's response to your complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC)
• 5th Floor, Delegation Building, PICC Complex, Pasay City, Metro Manila