filbit Privacy Policy

Introduction

1.1 filbit ("filbit", "we", "us", "our") is committed to protecting the privacy and personal data of all players and users of the filbit platform at filbit.org. This Privacy Policy ("Policy") sets out in detail how filbit collects, uses, stores, shares, and protects your personal information, and explains the rights you have in relation to that information.

1.2 This Policy is intended for players based in the Philippines and is written in compliance with Republic Act 10173, also known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations, as administered by the National Privacy Commission ("NPC") of the Philippines.

1.3 filbit takes its obligations under Philippine data protection law seriously. We process personal data only for lawful purposes, in a manner that is fair and transparent, and we implement appropriate technical and organisational safeguards to protect that data from unauthorised access, loss, or misuse.

1.4 This Policy should be read together with filbit's Terms & Conditions, available at /terms-conditions, and our Responsible Gaming policy at /responsible-gaming.

Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, filbit is the personal information controller in respect of personal data collected through the filbit platform.

2.2 filbit's designated Data Protection Officer ("DPO") is responsible for overseeing compliance with this Policy and applicable data protection law. Players may contact the DPO directly with any privacy-related concerns at the contact address provided in Section 14 of this Policy.

2.3 filbit processes data in alignment with PAGCOR (Philippine Amusement and Gaming Corporation) requirements, which may impose additional obligations regarding the retention and reporting of certain player data.

Personal Data We Collect

3.1 filbit collects personal data from you in the following ways: directly from you during registration and account management; automatically as you use the filbit platform; and from third parties where necessary for identity verification or fraud prevention.

3.2 The categories of personal data we collect include:

3.3 filbit does not intentionally collect sensitive personal information beyond what is strictly required for KYC compliance. Where sensitive data is collected (e.g., copies of government-issued ID), it is stored with heightened security controls.

How We Use Your Personal Data

4.1 filbit uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your filbit player account, including processing your filbit login credentials and authenticating your identity;
• Service Delivery: To operate casino games, process bets and payouts, and deliver all filbit services you access;
• Financial Processing: To process deposits via GCash, PayMaya, BPI, BDO, and Metrobank, and to process withdrawal requests to your registered payment method;
• KYC & AML Compliance: To verify your identity, age (must be 21+), and source of funds in accordance with PAGCOR requirements and Philippine anti-money laundering law;
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, account compromise, and abuse of the filbit platform;
• Customer Support: To respond to your queries, resolve disputes, and provide assistance via live chat or email;
• Responsible Gaming: To monitor play patterns for signs of problem gambling and to apply player protection tools including deposit limits and self-exclusion;
• Platform Improvement: To analyse usage patterns and improve the filbit product, game catalogue, and user experience;
• Legal & Regulatory Compliance: To comply with obligations imposed by PAGCOR, the NPC, and other applicable Philippine regulatory bodies.

4.2 filbit will not use your personal data for automated decision-making that produces significant legal effects without human review, unless required by law.

Legal Basis for Processing

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

• Contractual Necessity: Processing that is necessary to perform our obligations to you under the filbit Terms & Conditions — including account creation, game operation, and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR licensing requirements, Philippine AML law, NPC regulations, and tax obligations;
• Legitimate Interest: Processing for fraud prevention, security monitoring, and platform improvement, where these interests are not overridden by your privacy rights;
• Consent: Where you have provided specific consent, such as for marketing communications. You may withdraw such consent at any time without affecting the lawfulness of prior processing.

Data Sharing & Disclosure

6.1 filbit does not sell, rent, or trade your personal data to any third party for their independent marketing or commercial purposes. We share personal data only in the following circumstances:

• Game Providers: Third-party game software providers may receive limited technical data (such as session tokens) necessary to deliver game content. These providers are contractually bound to use this data only for the purpose of service delivery to filbit;
• Payment Processors: GCash, PayMaya, BPI, BDO, and Metrobank receive the financial data necessary to process your transactions. These are independent entities subject to their own privacy policies and Philippine financial regulations;
• KYC/AML Service Providers: filbit may use third-party identity verification services to assist with KYC compliance. These providers process data under strict data processing agreements with filbit;
• Regulatory Authorities: filbit is required by law to disclose certain player data to PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine authorities when legally compelled to do so;
• Legal Proceedings: filbit may disclose data to courts or law enforcement authorities in response to valid legal process, court orders, or where necessary to protect the rights and safety of filbit, its players, or the public.

6.2 In all cases of data sharing, filbit applies appropriate contractual and technical safeguards to ensure that shared data is used only for the stated purpose.

Cookies & Tracking Technologies

7.1 filbit uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit filbit.org.

7.2 The types of cookies used by filbit include:

• Strictly Necessary Cookies: Required for the platform to function, including maintaining your filbit login session, remembering your preferences, and ensuring security features work correctly. These cannot be disabled;
• Analytics Cookies: Used to understand how players interact with filbit — which games are most popular, how long sessions last, and where players encounter difficulty. This data is aggregated and anonymised;
• Functionality Cookies: Used to remember your settings and preferences across sessions, such as language preference and display settings.

7.3 You may control cookie settings through your browser preferences. Note that disabling strictly necessary cookies may affect your ability to use certain filbit features, including secure login.

Data Retention

8.1 filbit retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and Identity Data: Retained for a minimum of five (5) years following account closure, as required by Philippine AML and PAGCOR regulations;
• Financial and Transaction Records: Retained for a minimum of five (5) years following the date of each transaction, in compliance with applicable financial record-keeping requirements;
• KYC Documentation: Retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later;
• Technical and Usage Data: Retained for up to twenty-four (24) months from collection, unless a specific incident or investigation requires longer retention.

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with filbit's data disposal procedures.

Data Security

9.1 filbit implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• SSL/TLS encryption for all data in transit between your device and filbit servers;
• Encryption of sensitive data at rest, including financial data and KYC documents;
• Two-factor authentication (2FA) available on all filbit player accounts;
• Role-based access controls ensuring only authorised personnel can access player data;
• Regular security audits and penetration testing of the filbit platform;
• Incident response procedures for detecting, containing, and reporting data breaches.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, filbit will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay.

9.3 While filbit takes all reasonable precautions to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your filbit login password and for ensuring your device is secure.

Your Rights as a Data Subject

10.1 Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by filbit:

• Right to Be Informed: You have the right to be told how your data is being used — which this Policy fulfils;
• Right of Access: You may request a copy of the personal data filbit holds about you;
• Right to Rectification: You may request correction of inaccurate or incomplete personal data;
• Right to Erasure: You may request deletion of your personal data, subject to filbit's legal retention obligations;
• Right to Object: You may object to the processing of your data for direct marketing or where processing is based on legitimate interest;
• Right to Data Portability: You may request your personal data in a structured, machine-readable format;
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe filbit has violated your data privacy rights.

10.2 To exercise any of the above rights, please contact filbit's Data Protection Officer using the details in Section 14. filbit will respond to all data subject requests within thirty (30) calendar days.

Children's Privacy

11.1 filbit's services are strictly intended for individuals who are at least 21 years of age. filbit does not knowingly collect personal data from persons under the age of 21. This restriction is consistent with PAGCOR's age requirements for online gambling in the Philippines.

11.2 If filbit becomes aware that personal data has been collected from a person under 21 years of age, the account will be suspended immediately, any deposits will be returned, and the data will be deleted in accordance with our data disposal procedures.

11.3 If you have reason to believe that a minor has registered on filbit, please contact us immediately using the details in Section 14.

Cross-Border Data Transfers

12.1 Some of filbit's technology infrastructure and service providers may process data in locations outside the Philippines. Where personal data is transferred internationally, filbit ensures that appropriate safeguards are in place, including contractual clauses that impose data protection obligations equivalent to those under Philippine law.

12.2 filbit will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without first ensuring appropriate safeguards are in place and, where required, obtaining your explicit consent.

Updates to This Privacy Policy

13.1 filbit may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via their registered mobile number or by prominent notice on the filbit platform, with a minimum of seven (7) days' notice before changes take effect.

13.2 The effective date at the top of this Policy indicates when it was last reviewed. Continued use of filbit following the effective date of any update constitutes your acknowledgement of the revised Policy.

13.3 We encourage you to review this Policy periodically to stay informed about how filbit protects your information.

Contact & Complaints

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or filbit's data practices, please contact our Data Protection Officer:

Email: [email protected] (plain text — this is not a clickable link)

14.2 filbit's support team is available 24/7 via live chat on the filbit platform. Players from Metro Manila, Cebu, Davao, Quezon City, and all regions of the Philippines can reach us at any time.

14.3 If you are not satisfied with filbit's response to a privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012 in the Philippines.

14.4 filbit is committed to resolving all privacy-related complaints promptly and in good faith. We aim to acknowledge written complaints within 24 hours and to provide a substantive response within 14 business days.