filplay Privacy Policy

1 Introduction

filplay ("filplay", "the Company", "we", "us", "our") is committed to protecting the privacy and personal data of all players and users of the filplay Platform at filplay.club ("Platform"). This Privacy Policy describes how filplay collects, uses, stores, shares, and protects personal data in connection with your use of the Platform.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the data governance requirements imposed by the Philippine Amusement and Gaming Corporation (PAGCOR) as part of filplay's operating license conditions.

By registering, accessing, or using any service on the filplay Platform, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. If you do not agree, you must discontinue use of filplay immediately. This Privacy Policy should be read together with filplay's Terms & Conditions.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, filplay is the Personal Information Controller with respect to personal data collected through the Platform. filplay has appointed a Data Protection Officer ("DPO") responsible for overseeing data privacy compliance. Contact details for the DPO are provided in Section 15 of this Policy.

3 Data We Collect

filplay collects the following categories of personal data from players and Platform users:

4 How We Collect Your Data

filplay collects personal data through the following means:

• Direct collection: Information you provide when registering a filplay account, completing KYC verification, making deposits or withdrawals, contacting filplay support, or completing surveys;
• Automated collection: Technical and gaming data collected automatically through cookies, web beacons, server logs, and session tracking technologies as you use the filplay Platform;
• Third-party sources: Identity verification data from KYC service providers; financial transaction data from payment processors including GCash, PayMaya, BPI, BDO, and Metrobank; fraud prevention data from anti-money laundering screening services; and data from PAGCOR-mandated reporting systems.

5 How We Use Your Personal Data

filplay uses your personal data for the following purposes:

• To register and maintain your filplay account and verify your identity;
• To process deposits, withdrawals, and account transactions in PHP;
• To deliver gaming services, including personalizing game recommendations and promotional offers;
• To comply with PAGCOR licensing requirements, including player activity monitoring, responsible gaming enforcement, and mandatory regulatory reporting;
• To fulfill anti-money laundering (AML) and counter-terrorism financing (CTF) obligations under Philippine law;
• To detect, investigate, and prevent fraud, cheating, and prohibited account activity;
• To provide customer support and respond to your inquiries and complaints;
• To send you account-related notifications (e.g., deposit confirmations, security alerts, bonus updates) — these are non-optional service communications;
• To send marketing communications about filplay promotions, if you have opted in to receive them;
• To conduct internal analytics and improve the filplay Platform, including technical performance and user experience optimization.

6 Legal Basis for Processing

filplay processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill the agreement between you and filplay (account management, payments, game delivery);
• Legal obligation: Processing required to comply with PAGCOR regulations, AML/CTF obligations, tax reporting requirements, and other applicable Philippine laws;
• Legitimate interests: Processing necessary for fraud detection, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights;
• Consent: Processing for marketing communications, where you have given explicit opt-in consent. You may withdraw this consent at any time.

7 Data Sharing & Disclosure

filplay does not sell, rent, or trade your personal data. We share personal data only in the following circumstances:

• PAGCOR and regulatory authorities: filplay is required by its operating license to share player activity data, AML reports, and other specified data with PAGCOR and relevant Philippine government agencies;
• Payment processors: Financial data necessary to process deposits and withdrawals is shared with GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers solely for transaction processing purposes;
• Identity verification providers: KYC documentation is shared with licensed identity verification service providers who process data on behalf of filplay under strict data processing agreements;
• Fraud and AML screening: Data may be shared with fraud prevention networks and AML screening services as required by law;
• Legal proceedings: filplay may disclose personal data when required by a valid court order, subpoena, or lawful request by Philippine law enforcement agencies;
• Business transfers: In the event of a merger, acquisition, or sale of the filplay business, personal data may be transferred as part of that transaction, subject to equivalent privacy protections.

All third parties with whom filplay shares personal data are bound by contractual obligations to process your data only for specified purposes and to maintain appropriate security measures.

8 Cookies & Tracking Technologies

The filplay Platform uses cookies and similar tracking technologies to operate essential Platform functions and improve your experience. The following categories of cookies are used:

• Strictly necessary cookies: Required for login sessions, security, and core Platform functionality. These cannot be disabled without impacting Platform operation;
• Functional cookies: Remember your preferences such as language settings and game categories;
• Analytics cookies: Collect anonymized usage data to help filplay understand how players interact with the Platform and identify areas for improvement;
• Responsible gaming cookies: Track session duration and activity for the purpose of responsible gaming monitoring tools.

You can manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of parts of the filplay Platform.

9 Data Retention

filplay retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by PAGCOR and Philippine law:

• Account and identity data: Retained for the duration of your filplay account and for a minimum of five (5) years after account closure, as required by PAGCOR and AML regulations;
• Financial transaction records: Retained for a minimum of five (5) years in accordance with PAGCOR and Philippine AML/CTF legislation;
• Gaming activity data: Retained for a minimum of three (3) years from the date of each gaming session;
• Support communications: Retained for a minimum of two (2) years from the date of resolution;
• Marketing consent records: Retained for the duration of your opt-in consent and for one (1) year thereafter as evidence of consent.

After the applicable retention period, personal data will be securely deleted or anonymized so that it can no longer be linked to you as an individual.

10 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the filplay Platform;
• Encryption at rest for all stored personal data and financial records;
• Password hashing using industry-standard cryptographic algorithms — filplay never stores your password in plain text;
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing conducted by independent security firms;
• Two-factor authentication available for all player accounts and mandatory for all filplay administrative systems.

While filplay takes every reasonable precaution to protect your data, no digital system is entirely risk-free. In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, filplay will notify affected players and the National Privacy Commission in accordance with the Philippine Data Privacy Act's 72-hour breach notification requirement.

11 Your Privacy Rights

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

• Right to be informed: The right to know what personal data filplay holds about you and how it is used;
• Right of access: The right to request a copy of your personal data held by filplay;
• Right to rectification: The right to correct inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to filplay's legal retention obligations;
• Right to data portability: The right to receive your personal data in a structured, commonly used electronic format;
• Right to object: The right to object to the processing of your data for marketing purposes at any time;
• Right to lodge a complaint: The right to file 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 the above rights, contact filplay's Data Protection Officer at [email protected]. filplay will respond to all valid data rights requests within fifteen (15) calendar days of receipt.

12 Children & Minors

The filplay Platform is strictly intended for persons aged 21 years and older, as required by PAGCOR. filplay does not knowingly collect personal data from individuals under 21 years of age. If filplay becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account closed. If you believe a minor has provided personal data to filplay, please contact us immediately at [email protected].

13 Third-Party Links

The filplay Platform may contain links to third-party websites or services (for example, payment provider portals). filplay is not responsible for the privacy practices or data handling of any third-party website. This Privacy Policy applies solely to the filplay Platform. We recommend reviewing the privacy policies of any third-party sites you visit in connection with filplay transactions.

14 Updates to This Privacy Policy

filplay may update this Privacy Policy periodically to reflect changes in our data practices, regulatory requirements, or Platform features. When material changes are made, filplay will notify registered players via email or a prominent notice within the Platform at least seven (7) days before the changes take effect. The date of the most recent revision is always displayed at the top of this page. Your continued use of the filplay Platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

15 Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data held by filplay, please contact our Data Protection Officer through the following channels:

• Email: [email protected] (subject line: "Data Privacy Request")
• Live Chat: Available 24/7 on the filplay Platform — please state "DPO inquiry" at the start of your message

filplay is committed to resolving all privacy-related inquiries within fifteen (15) calendar days. For unresolved disputes, you may escalate your complaint to the National Privacy Commission of the Philippines at privacy.gov.ph.