filplay Privacy Policy

Introduction and Scope

filplay ("filplay," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the filplay platform ("Platform"). This Privacy Policy ("Policy") describes how filplay collects, processes, stores, shares, and protects personal data in connection with your use of the Platform, including the filplay website at filplay.net, any associated mobile applications, and all related services.

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). filplay is registered as a personal information controller under the DPA.

This Policy applies to all registered players, visitors, and any other individuals whose personal data is processed by filplay in connection with the Platform. It should be read alongside filplay's Terms & Conditions and Responsible Gaming Policy.

Personal Data We Collect

filplay collects personal data that is necessary for the operation of the Platform, compliance with legal obligations, and the delivery of a safe and personalized gaming experience. The categories of personal data we collect include:

filplay does not intentionally collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. Where sensitive data is collected, it is handled with heightened security measures in accordance with the DPA.

How We Use Your Personal Data

filplay processes your personal data for the following purposes:

• Account Registration and Management: To create and maintain your filplay player account, verify your identity, and manage your account settings and preferences.
• Service Delivery: To provide access to filplay games, process deposits and withdrawals, and deliver the core features of the Platform.
• Legal and Regulatory Compliance: To fulfill our obligations under Philippine law, including anti-money laundering (AML) requirements, PAGCOR licensing conditions, and the Data Privacy Act of 2012.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, and other prohibited conduct on the filplay Platform.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance related to your filplay account.
• Responsible Gaming: To monitor gaming patterns, enforce self-exclusion requests, apply deposit and session limits, and identify players who may be at risk of problem gambling.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where we have a legitimate interest in doing so. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct internal research, and improve the features, performance, and user experience of the filplay Platform.
• Legal Claims: To establish, exercise, or defend legal claims involving filplay or its players.

filplay will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

Legal Basis for Processing

filplay processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your filplay account and deliver the services described in our Terms & Conditions.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for filplay's legitimate interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications or placing non-essential cookies — filplay relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Sharing Your Personal Data

filplay does not sell, rent, or trade your personal data to third-party marketers. We 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: Licensed Philippine payment service providers (including GCash, Maya, and partner banks such as BPI, BDO, Metrobank, UnionBank, Landbank, PNB, and Security Bank) to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged to verify your identity and screen against sanctions and watchlists.
• Game Software Providers: Licensed game developers and content providers whose games are available on the filplay Platform, to the extent necessary for game delivery and fairness auditing.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or regulatory directive.
• IT and Infrastructure Providers: Cloud hosting, cybersecurity, and technical support providers engaged by filplay to operate and maintain the Platform, subject to strict data processing agreements.
• Legal and Professional Advisers: Lawyers, auditors, and other professional advisers engaged by filplay in connection with legal proceedings, compliance reviews, or corporate transactions, subject to professional confidentiality obligations.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other lawful process.

All third parties with whom filplay shares personal data are required to handle such data in accordance with the DPA and filplay's data protection standards. filplay does not transfer personal data outside the Philippines except where necessary and subject to appropriate safeguards.

Data Retention

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

• Account Data: Retained for the duration of your active filplay account, plus a minimum of five (5) years following account closure, in compliance with PAGCOR licensing conditions and Philippine AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act of 2001 (as amended) and PAGCOR regulations.
• KYC and Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution or legal proceedings.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years thereafter, to demonstrate compliance with consent requirements.
• Technical and Usage Data: Retained for up to twenty-four (24) months from collection, after which it is anonymized or deleted.

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

Cookies and Tracking Technologies

filplay uses cookies and similar tracking technologies on the Platform to ensure proper functionality, enhance your user experience, and gather analytics data. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as secure login sessions, account authentication, and navigation. These cookies cannot be disabled without impairing Platform functionality.
• Functional Cookies: These cookies remember your preferences and settings — such as your preferred language and display options — to provide a more personalized experience on filplay.
• Analytics Cookies: These cookies collect aggregated, anonymized data about how players use the filplay Platform, including pages visited, time spent, and features used. This data helps filplay improve the Platform's performance and content.
• Marketing Cookies: These cookies are used to deliver relevant promotional content and measure the effectiveness of filplay's marketing campaigns. They are only placed with your prior consent.

You may manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the filplay Platform. For strictly necessary cookies, no consent is required as they are essential to service delivery.

Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by filplay. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13.

• Right to Be Informed: You have the right to be informed about how filplay collects and processes your personal data, as set out in this Policy.
• Right of Access: You have the right to request a copy of the personal data filplay holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data filplay holds 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 filplay's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on filplay's legitimate interests.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request its transfer to another controller where technically feasible.
• 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 filplay has violated your data privacy rights.

filplay will respond to all verified data subject requests within thirty (30) days of receipt. We may require proof of identity before processing any request to protect against unauthorized access to your data.

Data Security Measures

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

• SSL/TLS Encryption: All data transmitted between your device and the filplay Platform is encrypted using industry-standard SSL/TLS protocols.
• Secure Data Storage: Personal and financial data is stored on secure, access-controlled servers with encryption at rest.
• Access Controls: Access to personal data within filplay is restricted to authorized personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Regular Security Audits: filplay conducts periodic security assessments, penetration testing, and vulnerability scans to identify and remediate potential security risks.
• Incident Response: filplay maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, filplay will notify the NPC and affected players in accordance with the DPA's breach notification requirements.
• Staff Training: All filplay personnel with access to personal data receive regular data protection and security awareness training.

While filplay takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are encouraged to use a strong, unique password for your filplay account and to enable any available two-factor authentication features.

Children's Privacy and Age Restrictions

The filplay Platform is strictly intended for adults aged twenty-one (21) years and above, in accordance with PAGCOR regulations governing online gambling in the Philippines. filplay does not knowingly collect personal data from individuals under the age of 21.

If filplay becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the filplay Platform, please contact our support team immediately at [email protected].

filplay employs age verification procedures during the registration process and reserves the right to request additional proof of age at any time. Accounts where age cannot be verified will be suspended pending resolution.

Third-Party Links and Services

The filplay Platform may contain references to third-party services, such as licensed payment providers and game software suppliers. filplay is not responsible for the privacy practices of any third-party services. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of filplay.

filplay's Privacy Policy applies solely to data collected and processed by filplay through the filplay Platform. It does not extend to data collected by third-party payment processors, game providers, or any other external services, even where those services are integrated into or accessible through the Platform.

Changes to This Privacy Policy

filplay reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. Where changes are material, filplay will notify registered players via email or an in-platform notification prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the filplay Platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. We encourage you to review this Policy periodically to stay informed about how filplay protects your data.

Contact Us and Data Protection Officer

filplay has appointed a Data Protection Officer ("DPO") in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by filplay, please contact our DPO:

• Data Protection Officer, filplay
• Email: [email protected]
• General Support: [email protected]
• Response Time: We aim to acknowledge all privacy-related requests within five (5) business days and to provide a substantive response within thirty (30) days.

If you are not satisfied with filplay's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. For more information about your rights under the DPA, visit the NPC's official resources.

For responsible gaming support, self-exclusion requests, or concerns about problem gambling, please visit our Responsible Gaming page or contact our support team directly.